PRIVACY POLICY

Last modified: January 7, 2022

Introduction

Educational Concepts, L.L.C. d/b/a Brief Media (“Brief Media” or “Company”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the websites, www.cliniciansbrief.com, www.plumbs.com and www.briefmedia.com (our “Websites”), or when you download, install, register with, access, or use the Plumb’s mobile application (the “App”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On the Websites.
  • Through the App. 
  • In email, text, and other electronic messages between you and Brief Media.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website or mobile application operated by us or any third party; or 
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from the Websites or App. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or App. By accessing or using our Websites or App, you agree to this privacy policy. This policy may change from time to time (Changes to Our Privacy Policy). Your continued use of the Websites or App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Websites and App are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Websites or App. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Websites or App. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Websites and App, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number (“personal information”);
  • That is about you but individually does not identify you; or
  • About your internet connection, the equipment you use to access our Websites or App, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Websites or App. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us   The information we collect on or through our Websites or App may include:

  • Information you provide by filling in forms on our Websites or App. This includes information   provided at the time of registering to use our Websites or App, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Websites or App.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Websites or App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Websites or App.
  • Your search queries on the Websites or App.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites or App with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Websites or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Websites or use of our App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites or App.
  • Information about your computer, mobile device, and internet connection, including your IP address, MAC address, operating system, and browser type.

The technologies we use for this automatic data collection may include:

  • Web Beacons. Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Some cookies are essential to enable you to navigate the Websites and use their features, such as accessing secure areas of the Websites or areas with paid content. Without these cookies, services you have asked for cannot be provided. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. For further information about cookies, visit allaboutcookies.org. 

Cookies on the Websites are categorized as follows:

  • Required (required - visitor cannot opt out without cancelling services)
  • Site Performance (optional - visitor may opt out)
  • Tracking (optional - visitor may opt out)
  • General 3rd Party (optional - visitor may opt out)
  • Required with Tracking (optional - visitor may opt out)
  • Advertising (optional - visitor may opt out)
  • Functional (optional - visitor may opt out)

Third-Party Use of Cookies

Some content or applications, including advertisements, on the Websites are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information  that we collect about you or that you provide to us, including any personal information:

  • To present our Websites to you.
  • To personalize content for you. 
  • To improve our Websites and App.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Websites or App, or any products or services we offer or provide through it.
  • To allow you to participate in interactive features on our Websites or App.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at [email protected] For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or that you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Educational Concepts, L.L.C.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Educational Concepts, L.L.C. about our Website/App users is among the assets transferred.
  • To fulfill the purpose for which you provide it. 
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Acceptable Use Policies (Clinician’s Brief AuP, Plumb’s  AuP) https://www.cliniciansbrief.com/acceptable-use-policy https://plumbs.com/acceptable-use-policy and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Educational Concepts, L.L.C., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company and Others. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to [email protected] If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 
  • Targeted Advertising. If you do not want us to use information we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at [email protected] 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into one of the Websites and visiting your account profile page. You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. If you are a Plumb’s subscriber, we cannot fully delete your personal information from our systems except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Websites and App, including User Contributions, is governed by our acceptable use policies: https://www.cliniciansbrief.com/acceptable-use-policy https://plumbs.com/acceptable-use-policy 

California residents and EU residents may have additional personal information rights and choices. Please see Your California Privacy Rights and Your EU Privacy Rights, below, for more information.

Your California Privacy Rights

If you are a California resident, California law provides you with additional rights regarding our use of your personal information, and this section applies to you. 

California’s “Shine the Light” law permits users of our Websites or App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at [email protected] 

We adopt this section of our Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this section of the policy. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and 
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
  • The specific pieces of personal information we collected about you (also called a “data portability request”).

Right to Delete 

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. 

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either emailing us at [email protected]. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

You do not need to create an account with us to submit a request to know or delete. 

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. 

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at [email protected] 

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Required CCPA Disclosures 

In the last twelve (12) months, we have collected the following categories of personal information through our Websites and App:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below:

Personal Information Category Category of Third-Party Recipients
  Business Purpose Disclosures Sales
A: Identifiers.

Advertising networks.

Internet service providers.

Data analytic providers.

Government entities.

Operating systems and platforms.

Social networks.

Data brokers or aggregators.

Service providers.

Affiliates.

Partners.

Parent or subsidiary organizations.

Internet cookie data recipients, like Google Analytics.

Yes
B: California Customer Records personal information categories. None None
C: Protected classification characteristics under California or federal law. None None
D: Commercial information.

Advertising networks.

Internet service providers.

Data analytic providers.

Government entities.

Operating systems and platforms.

Social networks.

Data brokers or aggregators.

Service providers.

Affiliates.

Partners.

Parent or subsidiary organizations.

Internet cookie data recipients, like Google Analytics.

None
E: Biometric information. None None
F: Internet or other similar network activity.

Advertising networks.

Internet service providers.

Data analytic providers.

Government entities.

Operating systems and platforms.

Social networks.

Data brokers or aggregators.

Service providers.

Affiliates.

Partners.

Parent or subsidiary organizations.

Internet cookie data recipients, like Google Analytics.

None
G: Geolocation data. None None
H: Sensory data. None None
I: Professional or employment-related information. None None
J: Non-public education information. None None
K: Inferences drawn from other personal information. None None

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Your EU Privacy Rights

If you are a resident of the European Union (“EU”), you have additional rights under the General Data Protection Regulation (“GDPR”), and this section applies to you. Under GDPR, you have the following rights:

  • The right to access - You have the right to request Company provide copies of your personal data. We may charge you a small fee for this service.
  • The right to rectification - You have the right to request that Company correct any information about you that you believe is inaccurate. You also have the right to request Company to complete information you believe is incomplete.
  • The right to erasure - You have the right to request that Company erase your personal data, under certain conditions.
  • The right to restrict processing - You have the right to request that Company restrict the processing of your personal data, under certain conditions.
  • The right to object to processing - You have the right to object to Company’s processing of your personal data, under certain conditions.
  • The right to data portability - You have the right to request that Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request under this section, we have one month to respond to you. If you would like to exercise any of these rights, our contact information is provided below.

We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Brief Media from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at [email protected]

If we transfer your personal data to the United States from the EU, we will do so pursuant to the EU Standard Contractual Clauses, exemplar text of which is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. 

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Websites or through the App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites or App.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Websites’ home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: 

Data Protection Officer

Brief Media

110 South Hartford Avenue, Suite 2507

Tulsa, OK 74120

Email: [email protected]

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