BullRush Academy LLC (collectively, “BullRush, “we” or “us”) is the data controller responsible for your personal data and is the sole owner of the bullrushacademy.com website (“Website”), BullRush desktop applications, BullRush services (each, a “Service”) and all of the information collected on it. BullRush collects information from users in several ways (explained in detail in this Privacy Policy). If you need assistance in viewing this Privacy Policy, please contact us using the contact information at the end of this Privacy Policy
This Privacy Policy applies to personal data that we collect from you when you visit this Website, create a User Account, use our applications or services (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect personal data, how it is used, how it is stored, and how we share information.
As used in this Privacy Policy, “personal data” or “personal information” means any information that relates to you from which you can be identified.
Updates
We may update this Privacy Policy at our discretion from time to time by posting a new version on our website. You should check our website occasionally to ensure any changes made are suitable for you. If required by applicable law, you will be informed of any significant changes made to this Privacy Policy.
Personal data that we collect
We collect information about you in a variety of ways depending on how you interact with us and our websites and services, including:
Directly from you when you provide it to us, such as when you register for a User Account, sign up to receive communications from us, place an order/make a purchase, or contact us by phone, email, or otherwise.
Automatically through the use of server logs, and other similar technologies when you interact with our websites, advertisements, and emails.
From other sources, including, for example, our affiliates, business partners, service providers, and other third parties, or from publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.
Context
Types of Personal Information
Primary Purpose for Collection
and Use of Personal Information
User Account Registration and Profile Management
We collect your name and contact information, including your username, when you create a User Account. We also collect information relating to the actions that you perform while logged into your User Account.
We have a legitimate interest in providing User Account related functionalities to our users. User Accounts can be used for easy checkout and to save your preferences and transaction history.
Application Programming Interface (“API”) Services
We collect various personal data, i.e., name, address, IP address, when you use our API services.
We have a legitimate interest in providing API services, including support services.
Client Information
We may collect the name, and contact information, of our clients and their employees with whom we may interact.
We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, Services, and billing.
Your Use of Our Website
We may use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. Some of these technologies may use “cookies.” Cookies are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website.
We have a legitimate interest in making our website operate efficiently. We also use it to understand how you interact with our websites to improve them and understand your preferences. Finally, we use this information to help detect and prevent fraud.
Technology on Our Website for Targeted Advertising
We may allow third parties to place technology on our websites (e.g., a cookie or a pixel) that allows them to track you. The third party might also collect data over time and across other websites. They use this data to serve advertisements tailored to your interests, which may include advertisements about our products or Services.
We do not use cookies on our website to participate in behavior-based advertising,
Demographic Information
We may collect personal information, such as your age or location.
We have a legitimate interest in understanding our users and providing tailored Services.
Distance Information
When you use one of our Apps we may collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location.
We have a legitimate interest in understanding our users and providing tailored Services. In some contexts, our use is also based upon your consent to provide us with geo location information.
Customer Service and Feedback
If you provide us feedback or contact us for support, we will collect your name and email address, as well as any other content that you send to us, in order to reply.
We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List
When you sign up for one of our email lists, we collect your email address or postal address.
We share information about our products and Services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or Services.
Order Placement
We may collect your name, billing address, shipping address, email address, phone number, and credit card number when you place an order.
We use your information to perform our contract to provide you with products or Services.
Cookies and other technologies
We do use browser cookies (small text files placed on your device) to administer our website. For more information, please see our Cookies Policy.
Log files
Like most websites, we use web server log files. Records in our log files include internet protocol (IP) addresses (see the “Device Information” section below for further details), browser types, internet service providers, referring pages, exit pages, platform types, and date/time stamps. We use web server log files to administer the site, provide broad traffic information for site planning purposes, and to ensure that our terms of service agreement is being adhered to.
Device information
We collect the following information about the devices you use to interact with our services: IP address of the device (from which we can also infer the country you are connecting from), device type, operating system, application and browser version. We collect this information to prevent spam and abuse of our services. IP addresses may be considered personal data in certain jurisdictions, and will be treated in accordance with this Privacy Policy.
Data we receive from third parties
When you sign in to your User a User Account using your internet service credentials, such service sends us your username and the email address associated with the credentials you’ve used. We neither control nor take any responsibility for the way third parties provide information about you and/or process your personal data.
User Account deleting
You may refuse to use our website and/or application and may ask us to delete your User Account in the Profile settings. Your User Account will be deleted after 30 days, provided there has been no activity on your User Account.
Please note that if you have requested your User Account to be deleted, we will delete the subsequent personal data you have supplied us. However, some data, such as email address, user ID and certain personal data will be saved as they have already integrated into our system. This data must be stored to maintain the integrity of the platform, as well as for data governance protocols, including audits and security purposes.
Marketing
We may send you marketing emails about our products or services that are similar to the products or services you are subscribed to, including information about events and other promotions we feel may interest you. This is unless you have indicated to us that you do not wish to receive communications in this manner. We will send you other promotional information by email only with your consent, which was given at the time you provided us with your personal data. Users can opt out of receiving marketing communications at any time by clicking “unsubscribe” in one of the emails.
Service-Related Announcements
On rare occasions, it may be necessary to send out service-related announcements. For instance, if our service is interrupted for a prolonged period or a major functionality upgrade is released, we might send all users an email message.
Customer Service
When you open a support ticket, we use your contact details as well as information about your device, server logs, a description of the problem, along with any other supporting materials (videos, screenshots, etc.) to help resolve the issue(s).
API
If you are using our API services, then we may process your personal data in order to be able to provide and support those services.
Processes and Protocols
We will process your personal data as necessary for certain processes and protocols, which include the following:
where we are asked to respond to any of your inquiries, comments, or grievances;
to administer our services in order to better understand how visitors interact with the Website and application, and ensure that they are presented in the most effective manner for you and your computer/device;
to develop and improve our applications and services;
to share personal data among our affiliated businesses for administrative purposes, provide subscription services, and in relation to our sales and marketing activities, except where we require your consent, as described above;
to send you information about our products or services that are similar to the products or services you subscribed to (unless you have refused or opted out of receiving these emails at the time you provided us with your email address or you have indicated to us that you do not wish to receive communications in this manner).
we may anonymize and aggregate the data that we collect and use this data for our own internal business purposes, including sharing it with our business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes. For example, to allow those parties to analyze patterns among groups of people and conducting research on demographics, interests, and behavior;
for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and as part of our efforts to keep our website, network, and information systems secure; and
to (a) comply with legal obligations, (b) respond to requests from regulatory authorities and law enforcement organizations; (c) enforce our Terms of Use or House Rules; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforce or defend legal rights, or prevent damage. This means we can store and disclose your information to law enforcement authorities, state, or government agencies if we establish that such disclosure is necessary to comply with the law. This includes responses to court orders or subpoenas, as well as other judicial or regulatory processes.
Third Party Sites
Links to other sites
At our discretion we may add links (web links) to other websites from our website. These websites can be run by third parties with separate and independent privacy policies. We, therefore, have no responsibility nor are we liable for any content, activities or privacy policies of these linked sites. We suggest you read the privacy policy of each and every site that you visit.
United States data subject rights and information
Some jurisdictions provide you with specific rights with respect to our collection and use of your personal information. To exercise one of these rights, see the section below on “Exercising data subject rights.”
Please note, not all of the rights described below are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
You may have the following rights:
Right to request that we disclose certain information to you about our collection and use of your personal information. The list of categories of personal information collected and disclosed about consumers are enlisted in the section ‘Personal data that we collect’ and the list of categories of third parties to whom the personal information may be disclosed are enlisted in the section ‘When would we share personal information’. Please contact us to exercise a data portability request. Separately, we do not sell your personal information for money.
Right to request deletion or modification of personal information we have collected from you.
California Shine the Light.
If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact information section below.
California Sensitive Information Disclosure.
We collect the following categories of sensitive personal information (as defined under California law): a consumer’s User Account log-in, financial User Accounts, or credit card numbers in combination with any required password. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with Services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.
Personal Data Disclosure Table
The table below describes the categories of personal information we collect and disclose for a business purpose. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal data we collect with government entities, as may be needed to comply with law or prevent illegal activity. As discussed elsewhere in the Privacy Policy, we do use cookies or similar tracking technologies for purposes of targeted advertising.
Category of Personal Information
Category of Recipients
Disclosures for a Business Purpose
Sharing for Cross-Context Behavioral Advertising
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, User Account name, or other similar identifiers.
· Affiliates or subsidiaries
· Data analytics providers
· Internet service providers
· Operating systems and platforms
· Other Service Providers
· Payment processors and financial institutions
· Professional services organizations, this may include auditors and law firms
Advertising networks
Government Issued Identification – this may include social security number, driver’s license number, or state issued identification number, passport number.
· Affiliates or subsidiaries
· Operating systems and platforms
· Other Service Providers
· Professional services organizations, this may include auditors and law firms
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.
· Affiliates or subsidiaries
· Operating systems and platforms
· Other Service Providers
· Payment processors and financial institutions
· Professional services organizations, this may include auditors and law firms
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
· Affiliates or subsidiaries
· Data analytics providers
· Internet service providers
· Operating systems and platforms
· Other Service Providers
· Payment processors and financial institutions
· Professional services organizations, this may include auditors and law firms
· Social networks
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
· Affiliates or subsidiaries
· Data analytics providers
· Internet service providers
· Operating systems and platforms
· Other Service Providers
· Professional services organizations, this may include auditors and law firms
Geolocation data
Operating Systems
Professional or employment-related information
· Affiliates or subsidiaries
· Operating systems and platforms
· Other Service Providers
· Professional services organizations, this may include auditors and law firms
International Users
Individuals subject to European and United Kingdom (“UK”) data protection laws may have data subject rights in relation to the personal data we hold on them (described in detail below). This may, in and of itself, be subject to limitations and/or restrictions.
If you are located in the EEA or UK, please contact us at support@bullrush.com to exercise your rights.
Accessing data
If prompted, we will confirm whether or not we are processing your personal data and if so, we will provide you with a copy of that personal data along with any other pertinent details. If you require additional copies, we may need to charge a reasonable fee, but this can be discussed and depends on the situation.
Restricting the processing of personal data
You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, for example, if you contest the accuracy of the data or object to us processing it. We will notify you before we lift any restriction on processing. If we share your personal data with others, we will notify them of the restriction wherever possible. If prompted, and if it is possible and lawful to do so, we will also notify you with whom we have shared or will share your personal data so you can contact them directly.
Objections
You may:
ask us to stop processing your personal data at any time, and, if required by law, we will do so.;
object to our processing of your data for the purposes of direct marketing at any time. This can be done by clicking the “unsubscribe” button in our marketing emails; and
refuse to receive service notifications via email (for example, when a user you are subscribed to publishes a chart, idea, etc.). This can be adjusted in the user settings.
Withdrawal of consent
If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness with which we process your data before receiving notice of your wish to withdraw your consent. We emphasize that we do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent, we will make this clear to you at that time.
Viewing and correcting data
You have the right to have inaccurate personal data rectified or completed if it is incomplete. In order to do so, each user can view, manage and/or update his/her personal data in the profile section.
If we share your personal data with others, we will notify them of any corrections made whenever possible. If prompted, and where possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.
Deleting data
You have the right to refuse to use our Services and may ask us to delete or remove your personal data in certain circumstances. If we share your data with others, we will notify them of the edits wherever possible. If prompted, and wherever possible and lawful to do so, we will also notify you with whom we have shared your personal data so you can contact them directly if need be.
Please see the “User Account deleting” section for more details.
Data portability
You have the right to obtain your personal data from us, which that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere if you so wish.
Lodge a complaint with the data protection authority
If you have concerns about our privacy practices, including the way we handle or have your personal data, you can report it to any competent data protection authority of an European Union member state that is authorized to hear such concerns (you may find European Union Data Protection Authorities’ contact information here) or to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. If you wish to exercise any of these rights, please contact us. Note that we may need to ask you for further information to verify your identity before we can respond to any request.
International data transfers
BullRush is based in the United States. The information collected through Services will be stored on servers located in the United States, European Union, and other destinations, to our service providers and affiliated businesses for the purposes described above. This is necessary to enable you to navigate and use our Services, and by summitting your personal data to us, you agree to the transfer, storage, and processing of your information in a country other than your country of residence. The data may be transmitted to our service providers and affiliates supporting our business operations (described above).
Note that the countries concerned may not provide the same legal standards for protection of your personal data. If we transfer your personal data to countries outside of your country, we will take the necessary steps to ensure your information receives an adequate level of security protection where it is processed and that your rights continue to be protected.
If you would like to receive more information on the safeguards that we implement, please contact us.
Exercising data subject rights
If you are a resident of a jurisdiction that allows you to exercise certain rights provided by applicable law, you may exercise the rights described above by contacting us as indicated in the “Contact Information” section below. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.”
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a completed Authorized Agent Designation Form indicating that you are able to act on another person’s behalf.
Contact Information
If you have any questions or suggestions regarding personal data processing, please contact us using the contact form here (link), by email at academy@bullrush.com or at the address below:
BullRush Academy LLC
701 S Carson St Ste 200
Carson City, NV 89701
Effective Date: July 1st, 2024
Last Update: July 1st, 2024