LAST UPDATED: May 3, 2018
Brightcove Inc. and its affiliates (“Brightcove” or “we”) want our customers (“Customers” or “you”) to be familiar with how we collect, use, share and store information relating to your use of our services and to end users who view your videos via our services (“Viewers”).
We do not have a direct relationship with Viewers. Information collected from Viewers on Customers’ websites or apps is subject to our Customers’ privacy policies. Viewers who have questions or concerns about information collected when they view a video via Brightcove Services, or about the content of any such video, should contact our Customer through the website or app on which such video is available. Viewers who are uncertain about whom to contact may contact us at firstname.lastname@example.org.
- Information We May Collect
- How We May Use Information
- How We May Share Information
- International Data Transfers
- Other Important Notices Regarding Our Privacy Practices
- Right to Request Information
- Additional Notice for Certain European Residents
- Additional Notice for Canadian Residents
- Privacy Shield Notice
- How to Contact Us
Information We May Collect
Information Collected from Viewers. In connection with our provision of Brightcove Services, we may collect certain information about Viewers. Such information may include personal information, which is information that identifies an individual or relates to identifiable person. Information that may be collected when videos are viewed via Brightcove Services includes:
- Unique IDs such as IP addresses or device ID.
- Viewer name, address, email address, title and industry. Note that Brightcove collects this information about Viewers only if a Customer elects to use certain features of Brightcove Services (such as Audience) that are intended to collect such information.
- System information, such as device, browser and operating system type and version, screen resolution and preferred language.
- Referring domain, destination domain and destination path.
- Video-viewing activity, such as player loads, number of views, viewed minutes, percent of content viewed, new Viewers, unique Viewers, attention span, top domains, geography, traffic sources, search terms and other similar information. This information is aggregated and anonymized (meaning it is not connected to an individual Viewer).
- Geolocation data.
- Other personal information of a natural person that may be included in videos or other data that our Customers upload to Brightcove Services.
Information Collected from Customers. To enable us to effectively provide Brightcove Services, we may collect the following information from individuals authorized by Customers (such as a Customer’s employees) to use Brightcove Services:
- Name, business email address, business telephone number, company, title and business billing address and payment information.
- Login credentials.
Cookies, Web Beacons and Other Tracking Technologies. We, and our third-party service providers, may use technologies such as cookies and beacons to quantify use, analyze viewing and engagement with videos displayed using Brightcove Services, conduct benchmarking, generate metrics, report to Customers and assess the quality of Brightcove Services.
Web Beacons. We may also use web beacons, tags and scripts in connection with Brightcove Services. Web beacons, also known as clear GIFs or single-pixel GIFs, are small image files that Brightcove Services use to communicate analytics data on Viewer activity and service usage. Alongside cookies, web beacons allow us to accurately count the number of unique Viewers who have viewed a video and activity during a viewing session. This information enables us to measure the performance of our Customer’s videos and allows Customers to evaluate Viewer interaction with their video content.
HTTP Headers. HTTP headers are information that is transmitted whenever a webpage is viewed, and contain technical information required for communication between a browsing device and a website server. Other electronic communication protocols (such as those used for email) also use headers to transmit information. Information may be transmitted through HTTP (or other electronic communication protocol) headers to Brightcove from the Customer’s use of Brightcove Services or from Viewer interaction with a Customer's video. This may include information about the device browser, the requested webpage and the computer or device being used (such as a carrier or device identifier).
Analytics. We may use third party analytics services, such as Google Analytics, to track the use of Brightcove Services by our Customers. For information on how Google collects and processes information and how to opt out from Google’s collection of your information, please click here.
Do Not Track. Brightcove Services do not recognize if a browser sends a “do not track” signal or similar mechanism to indicate the user does not wish to be tracked or receive interest-based ads.
Security. The security of personal information that Brightcove collects while operating the Brightcove Service is of great importance to Brightcove. We use organizational, technical and administrative measures to protect personal information under our control. No data transmission over the Internet or data storage system, however, can be guaranteed to be 100% secure. If you have any questions about the security of your personal information, you can contact us at email@example.com.
How We May Use Information
To the extent permitted by applicable law, we may use information about our Customers and Viewers for the following purposes or in the following ways:
- To deliver Brightcove Services.
- To provide our Customers with analytical data and reports about video viewing activity.
- To provide Customer support.
- To enable Viewers to register with our Customers in order to be able to watch video content on our Customers’ websites or apps. Brightcove collects this information at the direction of the Customer.
- To personalize Brightcove Services.
- For internal business purposes, such as data analysis, benchmarking, audits, developing new products, enhancing Brightcove Services, facilitating product, software and applications development, conducting research, analysis, studies or surveys and identifying usage trends.
- To protect the security and integrity of Brightcove Services, our Customers’ video content and data and our business.
- To meet our contractual requirements, to comply with applicable legal or regulatory requirements and our policies and to protect against criminal activity, claims and other liabilities.
- We may also use information about our Customers: to send Customers information and updates regarding Brightcove Services, programs and promotions; to fulfill Customer requests, such as to create Brightcove Services accounts; or complete Customer purchases.
- In other ways with appropriate consent.
How We May Share Information
To the extent permitted by applicable law, we may share, disclose and transfer information, including personal information as follows:
- With the Customer, as part of the Brightcove Services.
- With third-party service providers we use to support Brightcove Services and our business. These parties include third parties providing us with services such as website hosting, data analysis, infrastructure provision, IT services, customer service, analytics and email delivery services. These third parties are authorized to use information related to you only as necessary to provide these services to us.
- With third parties where the Viewer or Customer has requested to use a third-party service (including applications) in connection with Brightcove Services and has requested that we provide information to such third parties.
- With our current affiliates and any future corporate subsidiaries or affiliates.
- With a buyer, investor, new affiliate or other third party in the event that Brightcove, or any portion, group or business unit thereof, undergoes a business transition, such as a merger or acquisition, or during steps in contemplation of such activities (e.g., negotiations and due diligence). You will be notified via email and/or a prominent notice on our website of any change in ownership, change in use of your personal information and choices you may have regarding any change in use of your personal information.
- With third parties for marketing, advertising, promotions, contests or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous and de-identified manner.
- As we believe necessary: under applicable law, including laws outside the Viewer’s or Customer’s country of residence; to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, law enforcement or national security investigation, or as otherwise required or authorized by law; to respond to requests from public and government authorities, including public and government authorities outside the country of residence; to enforce our policies, terms and conditions; to protect our operations or those of any of our affiliates, customers, partners, agents or others; to protect our rights, privacy, safety or property and/or that of our affiliates, customers, partners, agents and any other person or organization; and/or to permit us to pursue available remedies or limit the damages that we may sustain.
Payment Processing. We use third-party payment service(s) (“Payment Service”) to process credit card payments for certain editions of Brightcove Services. Customers acknowledge and agree within their Brightcove Services agreement that when prompted to provide credit card information, that information gets transmitted directly to the Payment Service. Brightcove does not have access to full credit card numbers and does not store such information in its own systems. Information transmitted to the Payment Service is encrypted using SSL technology. The Payment Service is required to comply with all applicable privacy and security laws and the rules and regulations issued by the payment card industry and the credit card companies. Please contact us at firstname.lastname@example.org if you would like Brightcove to faciliate the correction or deletion of your personal information with the Payment Service.
Cross-Device Tracking. When Customers or Viewers use devices to display and/or view a Customer’s video content, we may receive information about their devices, including a unique identifier for each device. We and our service providers and third parties we collaborate with, including ad networks, may use cross-device/cross-context tracking. For example, a Viewer might use multiple browsers on a single device, or use various devices (such as desktops, smartphones and tablets), which can result in the individual having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.
Aggregate Information. To the extent permitted by applicable law, we may use, process, transfer and store any data about Viewers and Customers in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information, collected online and offline, including information from third-party sources. We may also use information in other ways with consent or as otherwise permitted by applicable law. By using Brightcove Services, our Customers agree that we may collect, use, share and store anonymized (or pseudonymized) aggregated data collected through Brightcove Services for benchmarking, analytics, metrics, research, reporting, machine learning and other legitimate business purposes.
Automated Decisions. To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including using machine-learning algorithms, about Viewers and Customers in order to provide and/or optimize Brightcove Services, for security or analytics purposes and for any other lawful purpose.
International Data Transfers
European Residents. If you are a resident of the European Union (“EU”), the European Economic Area or Switzerland, please see our Additional Notice for Certain European Residents and our Privacy Shield Notice below.
Other Important Notices Regarding Our Privacy Practices
Opt-Out. If you no longer wish to receive marketing-related communications from us, you may opt out by following the “unsubscribe” instructions in the latest such message received or by contacting us at email@example.com. Customers may not opt out of certain communications, such as those necessary to keep Customers aware of Brightcove Service status and service issues.
Retention Period. To the extent permitted by applicable law, we may retain information for as long as the account of the Customer for whom we collected the information is active, or as long as is reasonably necessary to provide Brightcove Services, or as needed for other lawful purposes. We may retain cached or archived copies of information. We may retain anonymized or pseudonymized aggregated data indefinitely, to the extent permitted under applicable law. We also will retain information as long as reasonably necessary to comply with our contractual and/or legal obligations, resolve disputes and enforce our agreements.
Accuracy of Information. Accuracy of data is very important to us. Customers should ensure that any information provided to us is up-to-date and Customers may correct information by either logging into their Customer account or by contacting Brightcove’s customer support team. In certain situations, Customers may need assistance from customer support in making a change. We will respond to requests to make changes to Customer records as soon as reasonably practicable. We may require Customer representatives to prove their identity before granting access to, or agreeing to update, correct or delete personal information belonging to Customers.
You may request access to, or correction or deletion of personal information, by contacting us at firstname.lastname@example.org. We will attempt to answer all requests that we correct inaccurate personal information or delete personal information, unless we are required to retain it by law or for legitimate business purposes.
Right to Request Information
You may request, and we will provide you with, information about whether we hold any of your personal information. You may request access to, or correction or deletion of your personal information by contacting us at email@example.com. We will respond to your request within a reasonable timeframe.
Additional Notice for Certain European Residents.
“Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Our lawful bases for the Processing of Personal Data are: (i) consent and/or (ii) any other applicable legal bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of Brightcove Services, preventing fraud, ensuring information and network security, direct marketing and advertising and complying with industry practices.
Additional Rights for European Residents. As a resident of the EU or a country following substantially-similar legislation regarding the protection of personal data, you may have one or more of the following additional rights available to you:
- Access. To request a copy of the Personal Data we have collected about you by contacting us at firstname.lastname@example.org.
- Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
- Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
- Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing pending the verification of whether our legitimate grounds for Processing override yours.
- Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
- Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services.
- Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).
To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at email@example.com. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify your identity before processing your request. Certain information may be reviewed, corrected and updated by logging into your Brightcove Service account and editing the profile information.
If Brightcove receives a request from a Viewer, we may refer the request to the Customer and support the Customer in responding to the request.
Compelled Disclosures. Brightcove may be required to disclose Personal Data in response to lawful requests by public authorities, including disclosures necessary to meet national security or law enforcement requirements, or pursuant to judicial orders.
Additional Notice for Canadian Residents
Canadian residents may have additional rights under Canadian law. Please see the information provided by the Office of the Privacy Commissioner of Canada for additional details.
Privacy Shield Notice
EU-U.S. and Swiss-U.S. Privacy Shield Notice. We have certified our compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (collectively, the “Privacy Shield Framework”) with respect to the Personal Data of users of Brightcove Services who are residents of the European Union (“EU”), European Economic Area (“EEA”) and Switzerland that we receive and process through Brightcove Services. We certify that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (hereinafter, “Privacy Shield Principles”) for personal data of Viewers and Customers in participating European countries. We are responsible for the processing of personal data we receive under the Privacy Shield Framework and subsequently transfer to a third party agent, and may be liable for onward transfers in violation of the Privacy Shield Principles. Our certification is available here. We may also process Personal Data relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses.
Questions and Complaints. If you are a resident of a country participating in the Privacy Shield Framework, you may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact listed below. We will work with you to resolve your issue.
If you have not received timely response to your concern relating to data processed under the Privacy Shield Framework, or we have not addressed your concern satisfactorily, you may contact our U.S.-based dispute resolution provider, at no cost to you, at https://feedback-form.truste.com/watchdog/request. If neither Brightcove nor our independent dispute resolution provider resolves your complaint, you may use the right to invoke binding arbitration through the Privacy Shield Panel. However, prior to initiating such arbitration, a resident of a country participating in the Privacy Shield Framework must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent dispute resolution provider and (3) contact the U.S. Department of Commerce (either directly or through a European DPA) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
U.S. Federal Trade Commission Enforcement. Brightcove’s commitments under the Privacy Shield Framework are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Privacy Shield and Data Protection Contact. Your Privacy Shield and Data Protection Contact for the Personal Data that we Process in connection with Brightcove Services is:
Attn: Chief Privacy Officer
290 Congress Street
Boston, MA 02210
Phone: +1 617 500 4947
Please include sufficient information so we can understand and respond to your specific question.
How to Contact Us
Attn: Privacy Team
290 Congress Street
Boston, MA 02210