|1.0 General Principles:|
Policy") to comply with regulations and with the highest possible standards for
of any information you provide to us through the Brella Wireless website or by
use such information and the limited circumstances in which such information may
Your information will be stored on Brella's computers located in Canada and may be subject to regulation under the laws of those countries.
If you object to your personal information being transferred or used as described
2.0 Notification of Changes:
on our website so you may review such changes. Any changes will be effective only
after at least 30 days notice. If you do not agree to such changes then discontinue
using our site and/or contact us and request your account and data be deleted. We
your information was collected and to which you agreed.
3.0 Personal Information We Collect:
Information We Collect:
We may collect some or all of the following personal information from you, depending
on your use of our site:
In order to make payments for transactions facilitated through or related to Brella
Wireless, you may be requested to provide additional financial information which
will be required to process your transaction with third party financial transaction
providers. Such information is subject to privacy and other rules set by those third
party financial transaction providers.
- other information as may be required.
3.2 Transaction Information:
To help prevent fraud, and to provide you with high-quality services, we retain
the following information:
information about every transaction you conduct through Brella Wireless; and
- the IP address of whatever device you use to access your Brella Wireless account.
3.3 Information Collected
from Third Parties:
We may obtain information about you from third parties to prevent potential fraud
or to verify credit ratings. These third parties may include credit bureaus, identity
verification services and banks. We use such third-party provided information only
to compare information you provide to us when registering for Brella Wireless against
such third-party provided information and to detect fraud in financial and other
3.4 Web Site Traffic
Due to the technical nature of web-browsing, when you visit the Brella Wireless
website, we obtain the following information:
We use this information only to try to understand our customers' preferences better
and to manage the load on our servers, so as to improve our service, analyze trends,
administer the site, improve site performance, and gather broad demographic information
for aggregate use.
the web address of the website that you came from or are going to;
which pages of our website you visit;
the type of browser you use; and
- the times you access our website
3.5 Site Login and Transaction Activity:
Brella logs all transactions, account login activity and the IP address and geographical
location, ISP provider and routing information associated with each login and transaction.
We will only use this information to help prevent fraud and the information may
be shared with law enforcement authorities and banks ONLY in the case where fraudulent
or other illegal activity has been clearly established.
3.6 Our Use of
"Cookies" are small files of data that reside on your computer and allow us to recognize
you as a Brella Wireless customer if you return to the Brella Wireless site using
the same computer and browser. We send a “cookie" to your computer if and when you
log in to your Brella Wireless account by entering your email address and password.
These cookies allow us to recognize you if you visit multiple pages in our site
during the same session, so that you don't need to re-enter your password multiple
3.7 Customer Service Correspondence:
We will retain all customer support correspondence and other correspondence from
Brella Wireless to you as well any correspondence you send to us. We retain these
records in order to measure and improve our customer service, and to investigate
potential fraud or civil or criminal wrongs.
3.8 Questionnaires, Surveys and Profile
From time to time, we may offer optional questionnaires and surveys to you. The
nature and use of the information collected will be explained in detail in the survey
itself. If we collect personally identifiable information from you in these questionnaires
and surveys, you will be given notice of how the information will be used prior
to their participation in the survey or questionnaire.
4.0 Use and Disclosure of Collected Information:
We use the information we collect about you in order to:
We limit access to personal information about you to those employees and agents
who need to know the information to provide products and services to you.
verify your identity;
provide our services and process your transactions;
provide customer support services; or
- improve our services.
4.2 Disclosure to Third Parties:
Brella will not disclose any of your personally identifiable information to third
parties except in the limited circumstances described below, or with your express
permission. These third parties are limited by law or by contract from using the
information for secondary purposes beyond the purposes for which the information
is disclosed. We disclose information appropriate to the circumstances as determined
in our sole discretion:
We disclose information to companies that help us prevent fraud and that are contracted
to help us process transactions.
We disclose information that we, in good faith, believe is appropriate to cooperate
in investigations of fraud or other illegal activity, or to conduct investigations
of violations of our User Agreement. Specifically, this means that if we conduct
a fraud investigation and conclude that one side has engaged in deceptive practices,
we can give that person or entity's contact information (but not bank account or
debit/credit card information) to victims who request it.
We disclose information in response to a subpoena, warrant, court order, levy, attachment,
order of a court-appointed receiver or other comparable legal process, including
subpoenas from private parties in a civil action.
We disclose information that we are required to disclose by applicable law, treaty,
or fraud-prevention and reporting regulations of networks in which we participate
We disclose information to your agent or legal representative (such as the holder
of a power of attorney that you grant, or a guardian appointed for you).
If Brella merges or is acquired by another company then the successor company would
- We may share your information with our parent company and subsidiaries to help coordinate
the services we provide to you, enforce our terms and conditions, and promote trust
4.3 Our Contacts with Brella Wireless
We communicate with users on a regular basis via email to provide requested services.
We also communicate by phone to resolve customer complaints or investigate suspicious
transactions. We use your email address to confirm your various transactions, to
send information about our products and services, to alert you to public security
or privacy threats (such as email solicitation) and to send notices and other disclosures
required by law.
5.0 How We Store Collected Information:
5.1 Your Responsibilities for Maintaining Your
Access to the information is restricted to a select group of individuals, in accordance
with our security protocols. The security of your Brella Wireless account also
relies on your protection of your Brella Wireless password. You may not share your
Brella Wireless password with anyone. Brella will never ask you to send your password
or other sensitive information to us in an email, though we may ask you to enter
this type of information on the Brella Wireless website, at the following URL:
5.2 Email and Other Communication:
Any email or other communication requesting your password, asking you to provide
sensitive account information via email, or linking to a website with a URL other
than those specified within this document should be treated as unauthorized and
suspicious and should be reported to Brella immediately. If you do share your Brella
Exchange password with a third party for any reason, including because the third
party has promised to provide you additional services such as account aggregation,
the third party will have access to your account and your personal information,
and you may be responsible for actions taken using your password. If you believe
someone else has obtained access to your password, please contact us right away
as described below.
6.0 Updating Your Information:
You can review the personal information you provided us and make changes to some
information, or to the settings for your Brella Wireless account, at any time by
logging in to your account on the Brella Wireless website and changing your preferences
of your account.
7.0 Contacting Us:
If you have any questions about this privacy statement, Brella's information practices,
your dealings with Brella, you can contact us via email at . Our mailing address is at #328 - 13988 Cambie Road
British Columbia, Canada V6V 2K4.
To report privacy or security violations, loss or disclosure of passwords, or any
unauthorized account access or transactions please call us immediately, at 1.866.438.2395.