Brew Emails Inc. (“we,” “us,” “our,” or “Brew”) offers enterprises the tools they need to create, send, and optimize high-performing email campaigns and automations.
Personal information that we handle on behalf of our customers in our role as a service provider / data processor is governed by our Data Processing Agreement.
1. Personal Information We Collect
Here’s how we collect personal information in providing our Services. 1.1. Personal information we receive from you| Data Categories | Examples |
|---|---|
| Contact Details | First and last name, email address, telephone number, and postal address. |
| Account Information | Username and password. |
| Payment Information | Payment card information, bank account information and other billing details. This information may be processed by our payment service providers, which may handle your payment information in accordance with their own privacy policies. |
| Usage Data | Feature usage, timestamps, latency/errors, and deliverability/engagement events (opens, clicks, bounces, unsubscribes, spam complaints). |
| Preferences | Language, interests, and other feedback/preferences that you might express during your use of our Services. |
| Marketing Data | Choices regarding our newsletters, surveys, and other marketing displayed or provided to you, and preferred methods of receiving such promotional communication. |
| Relationship Information | Purchases you’ve made through the Services, details of your communications with us, and details of your claims, complaints, and queries in general. |
| Data Categories | Examples |
|---|---|
| Online Activity Data | Pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them. |
| Device Information | Your device’s operating system type and version, manufacturer and model, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), advertising ID, and general location information. |
| Data Categories | Examples |
|---|---|
| Cookies | Cookies are pieces of information stored directly on the device that you are using and allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers may use the information for security purposes, to facilitate navigation, display information more effectively, conduct analytics, and personalize your experience. We do not currently respond to browser do-not-track signals. You can read more information about cookies at http://www.allaboutcookies.org/manage-cookies/index.html. |
| Local Storage Technologies | These technologies provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications. |
| Pixel Tags | Also known as web beacons and clear GIFs, pixel tags may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates. |
| Data Categories | Examples |
|---|---|
| Social Media | Information we collect from social media sites may include details such as profile pictures, social media account ID, and other public social media profile information. |
| Single Sign-On (SSO) | If you sign in via a third-party identity provider, we receive basic profile information for authentication and account provisioning. |
| Other Third Parties | We may collect information from sources such as publicly available databases, marketing partners, third-party providers, and data brokers. |
2. How We Use Personal Information
Here’s an overview of how we use personal information in providing our Services.| Purposes | Examples |
|---|---|
| Administering the Services | To manage our contractual relationship with you, we may use your personal information to provide the Services to you, including arranging access to your account, verifying your information, responding to your inquiries, fulfilling your requests, and sending you administrative information such as agreements to provide the Services and changes to our terms, conditions, and policies. |
| Operations and General Business | To manage our contractual relationship with you and to fulfil our legitimate business interests, we may use your personal information when we conduct our operations (such as troubleshooting, diagnostic testing, performance analyses of our systems and Services, testing of new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and hosting data) and to facilitate mergers, acquisitions, and other reorganizations and restructurings of our business (including prospective transactions). |
| Marketing | To fulfil our legitimate business interests, we may use your personal information to send you our newsletters, publications, updates, and invitations that we think may be of interest to you. |
| Relationship Building and Engagement | To manage our contractual relationship with you and to fulfil our legitimate business interests, we may use your personal information to respond to any posts on our social media pages and to conduct other user relationship building activities. |
| Personalizing Our Services | To fulfil our legitimate business interests, we may use your personal information to personalize our interactions with you and to provide you with information and/or offers tailored to your interests, such as delivering content that we believe will be relevant and interesting to you. |
| Improving and Developing Our Services | To fulfil our legitimate business interests, we may use your personal information to conduct data analysis, to monitor and analyze use of the Services, to use data analytics to improve the efficiency of our Services, to develop new features, to enhance, improve, repair, maintain, or modify our Services, to identify usage trends, to understand which parts of our Services are most interesting to users, to determine the effectiveness of our promotional campaigns, and for other similar purposes. |
| Aggregation and/or Anonymization | To fulfil our legitimate business interests, we may anonymize and aggregate personal information that does not identify you or another individual and use and share such data for our own business purposes. |
| Security and Fraud Prevention | To manage our contractual relationship with you, to comply with our legal obligations, and to fulfil our legitimate business interests, we may use your personal information to conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements, to monitor for and prevent fraud, and for security purposes, including maintaining system security. |
| Legal and Compliance | To manage our contractual relationship with you and to comply with our legal obligations, we may use your personal information to fulfill our legal and compliance-related obligations, including complying with applicable laws, complying with legal processes, responding to requests from public and government authorities, meeting national security or law enforcement requirements, complying with requirements set by industry-specific supervisory bodies, enforcing our terms and conditions and standards, protecting our operations, protecting the rights, privacy, or property of our business, responding to auditors, pursuing available legal remedies, making insurance claims, defending claims, and limiting the damages that we may sustain. |
3. How We Disclose Personal Information
Here are the types of entities to which we may disclose personal information in providing the Services.| Entities | Information disclosed |
|---|---|
| Affiliates and Subsidiaries | We may disclose personal information to our subsidiaries and affiliates for purposes consistent with this Privacy Policy. |
| Service Providers | We use service providers that provide hosting, information technology, customer support, payment processing, email and communications delivery, and analytics services for the purposes listed above. |
| Professional Advisors | We use accountants, actuaries, auditors, experts, consultants, lawyers, banks, and financial institutions to support our business. |
| Authorities and Others | If we are required by law or legal process or if we deem the disclosure appropriate for other legal, compliance or fraud-prevention purposes, we may disclose personal information to law enforcement, public, regulatory, and government authorities, courts, or other entities that obtain valid subpoenas. |
| Other Online Services | When you interact with us, you may choose to share information and content on our social media pages and other online services. |
| Business Transferees | We may disclose or transfer your personal information to third parties such as acquiring entities and their advisors in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). |
4. Security
We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.5. Marketing Choices
You have choices regarding marketing-related communications. If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at legal@brew.new. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.6. Privacy Rights Requests
We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:- Information about how we have collected, used, and disclosed personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
- Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
7. Retention Period
We retain personal information for as long as needed or permitted in light of the purposes for which it was obtained as outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. The criteria used to determine our retention periods include:- The length of time we have an ongoing relationship with you (for example, for as long as you keep using our Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records or communications for a certain period before we can delete them); or
- Whether retention is advisable considering our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
8. Third-Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties. This includes any third party operating any website or service to which our Services link. The inclusion of a link on our Services does not imply endorsement of the linked site or service by us or by our affiliates.9. Third-Party Payment Service
The Services may provide functionality allowing you to make payments to us using third-party payment services. When you use such a service to make a payment, your personal information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your personal information.10. Use of the Services by Minors
The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under 18. If you have reason to believe that a child under the age of 18 has provided personal information to us through the Services, please contact us.11. Cross-Border Transfer
Your personal information may be stored and processed in any country or region where we have facilities or engage service providers. By using the Services, you understand that your personal information may be transferred to countries outside of your country or region of residence, which may have data protection rules that are different from those of your country or region. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries or regions may be entitled to access your personal information. Where applicable, we have put in place adequate measures, such as the standard contractual clauses adopted by the relevant authority, to protect your personal information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.12. Updates to This Privacy Policy
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.13. Contacting Us
Brew is the company responsible for collection, use, and disclosure of your personal information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us. You can reach us at legal@brew.new or by mail at: Brew Emails Inc.2248 Broadway 1933
New York, NY 10024