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Privacy Policy

Last Updated: June 26, 2026

Welcome, and thank you for your interest in the Brightr platform ("Brightr"), operated by Beacon Mobile, Inc. ("Beacon Mobile," "we," "us," or "our"), our website at www.brightrhq.com (the "Site"), and all related websites, applications, SMS messaging services, and other services provided by us on which a link to this Privacy Policy is displayed (collectively, together with the Site, our "Service").

This Privacy Policy ("Policy") describes the information we collect on or through the Service, how we use and disclose such information, and the steps we take to protect it. By visiting the Site, using the Service, or opting in to our SMS Program, you accept the privacy practices described in this Policy.

This Policy is incorporated into, and subject to, the Beacon Mobile Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.

1. Definitions

"Client" means a customer of Beacon Mobile, such as an event organizer or community partner that uses the Brightr platform.

"Client Data" means personal data, reports, addresses, and other files, folders, or documents in electronic form that a Client or User of the Service stores within the Service.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Public Area" means the area of the Site that can be accessed by both Users and Visitors without logging in.

"Restricted Area" means the area of the Site that can be accessed only by Users and requires logging in.

"User" means an employee, agent, or representative of a Client who uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.

"Visitor" means an individual other than a User who uses the public area of the Site or interacts with the Service, including attendees who use the Brightr concierge or opt in to the SMS Program.

2. Information We Collect

We collect different types of information from or through the Service. The legal bases for our processing of Personal Data are primarily that the processing is necessary for providing the Service in accordance with our Terms of Service and that the processing is carried out in our legitimate interests, as further explained in Section 3.

2.1 Information You Provide. When you use the Service, you may provide, and we may collect, Personal Data, including: (i) name; (ii) email address; (iii) mobile phone number; (iv) mailing address; and (v) any other information you provide when registering for an account, using the concierge, interacting with other users, or contacting us for support.

2.2 SMS Program Opt-In Data. When you opt in to the Brightr SMS Program, we collect and store: (i) your mobile phone number; (ii) a timestamp recording when you opted in; (iii) the exact consent language displayed to you at the time of opt-in; (iv) the event or community context associated with your opt-in; and (v) the source URL or method through which you opted in (for example, the web form at ask.brightrhq.com/signup or a text-keyword opt-in at an event). This information constitutes your consent record and is retained as described in Section 13.

2.3 Information Collected by Clients. A Client or User may store or upload Client Data into the Service. Beacon Mobile has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which it collects their Personal Data and how such data is processed through the Service.

2.4 Automatically Collected Information. When you use the Service, we may automatically record certain information from your device using cookies, clear gifs, web beacons, and similar technologies. This information may include: (i) IP address or other device identifier; (ii) web browser and device type; (iii) the web pages or sites visited before or after using the Service; (iv) pages or content you view or interact with on the Service; (v) dates and times of access; and (vi) information regarding your interaction with email messages we send, such as whether you open, click on, or forward a message.

2.5 Integrated Services. You may access or register for the Service using credentials from third-party services (each, an "Integrated Service"), such as your Google account. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address, and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. Check your privacy settings on each Integrated Service to understand and control what information is shared with us.

3. How We Use Information

3.1 Operations. We use information (other than Client Data) to operate, maintain, enhance, and provide all features of the Service, to respond to comments and questions, and to provide support. We process Client Data solely in accordance with the directions provided by the applicable Client or User.

3.2 SMS Communications. We use your mobile phone number and related opt-in data to send you messages through the SMS Program, including informational, transactional, and occasional promotional messages as described in the Terms of Service. We use your consent record to document and verify your opt-in.

3.3 Other Communications. We may use your email address, phone number, or other contact information (other than Client Data) to contact you: (i) for administrative purposes, such as customer service or to address issues related to the Service; or (ii) with updates on promotions, events, and services offered by us or by third parties we work with. You may opt out of promotional communications as described in Section 6.

3.4 Improvements. We use information to understand and analyze usage trends and preferences, to improve the Service, and to develop new products, services, features, and functionality. If this purpose requires us to process Client Data, the data will only be used in anonymized or aggregated form.

3.5 Cookies and Tracking Technologies. We use automatically collected information and cookies to: (i) personalize the Service; (ii) provide customized content and information; (iii) monitor and analyze the effectiveness of the Service and third-party marketing activities; (iv) monitor aggregate site usage metrics; and (v) track your entries, submissions, and status in promotions or other activities on the Service.

3.6 Analytics. We use analytics services to measure and evaluate access to and traffic on the Site and create usage reports. These analytics providers operate independently and have their own privacy policies. Data collected through analytics is used on a need-to-know basis to resolve technical issues, administer the Site, and identify preferences, in non-identifiable form. We do not use analytics data to identify individual Visitors or Users.

4. Disclosure of Information

Except as described in this Policy, we will not intentionally disclose Personal Data or Client Data to third parties without the consent of the applicable Visitor, User, or Client. We may disclose information in the following circumstances:

4.1 Unrestricted Information. Information you voluntarily include in a Public Area of the Service will be available to any Visitor or User who has access to that content.

4.2 Service Providers. We work with third-party service providers who provide hosting, development, maintenance, messaging, and other services for us. These providers may have access to or process Personal Data or Client Data as part of providing those services. We limit the information provided to what is reasonably necessary and require them by contract to maintain its confidentiality.

4.3 Non-Personally Identifiable Information. We may make aggregated or non-personally identifiable information available to third parties for purposes including compliance with reporting obligations, business or marketing purposes, and understanding usage patterns.

4.4 Law Enforcement and Legal Process. We may disclose Personal Data if required by law or in the good-faith belief that disclosure is necessary to: (i) comply with applicable laws or respond to a valid court order, subpoena, or warrant; (ii) take precautions against liability; (iii) protect ourselves or others from fraudulent, abusive, or unlawful activity; (iv) investigate and defend against third-party claims; (v) protect the security or integrity of the Service; or (vi) protect our property, enforce our contracts, or protect the rights, property, or safety of others.

4.5 Change of Ownership. Information about Users and Visitors, including Personal Data, may be disclosed and transferred to an acquirer, successor, or assignee as part of any merger, acquisition, sale of assets, or similar transaction, or in the event of an insolvency or bankruptcy, provided that the recipient commits to a privacy policy with terms substantially consistent with this Policy.

5. Mobile Messaging / SMS Data Practices

5.1 No Sharing for Marketing. Mobile phone numbers and consent records collected for the SMS Program will not be sold, rented, or shared with third parties or affiliates for their marketing or promotional purposes. Information obtained as part of the SMS opt-in process — including your phone number, your consent, and the associated opt-in data described in Section 2.2 — will not be shared with third parties for their marketing purposes.

5.2 Limited Disclosure. We may share SMS-related data with service providers who assist in delivering messages (such as our messaging platform provider), subject to the same confidentiality and use restrictions described in Section 4.2.

5.3 Opt-Out. You may opt out of the SMS Program at any time as described in the Terms of Service. Upon opt-out, we will cease sending you messages. We will retain your consent record as described in Section 13.

6. Your Choices

6.1 Access, Correction, Deletion. You may access, update, correct, or delete your account information by contacting us at support@brightrhq.com. At your request, we will delete or block any reference to you in our database, subject to our right to retain information for backups, archiving, fraud prevention, analytics, legal obligations, or where we have a legitimate reason to do so. You may decline to share certain Personal Data, in which case we may not be able to provide certain features of the Service. This provision does not apply to Personal Data that is part of Client Data; requests for access, correction, or deletion of Client Data should be directed to the applicable Client.

6.2 SMS Opt-Out. You may opt out of the SMS Program at any time as described in Section 5 of the Terms of Service.

6.3 Commercial Communications. If you receive promotional emails from us, you may unsubscribe by following the instructions in the email or by emailing support@brightrhq.com. It may take up to ten (10) business days for us to process your request. Even after opting out of promotional communications, you will continue to receive administrative messages regarding the Service.

6.4 Navigation Information. You may opt out from the collection of navigation information by analytics providers by using their opt-out features where available.

6.5 Data Protection Rights. At any time, you may object to the processing of your Personal Data on legitimate grounds, except where otherwise permitted by applicable law. If you believe your privacy rights have been infringed, please contact us at matt@brightrhq.com. You also have the right to lodge a complaint with applicable data protection authorities.

7. Your California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"):

7.1 Right to Know. You have the right to request that we disclose the categories and specific pieces of Personal Data we have collected about you, the categories of sources from which the data was collected, the business or commercial purposes for collection, and the categories of third parties with whom we share your Personal Data.

7.2 Right to Delete. You have the right to request that we delete Personal Data we have collected from you, subject to certain exceptions permitted by law.

7.3 Right to Correct. You have the right to request that we correct inaccurate Personal Data we maintain about you.

7.4 Right to Opt Out of Sale or Sharing. We do not sell your Personal Data. If we share Personal Data for cross-context behavioral advertising, you have the right to opt out of such sharing.

7.5 Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA/CPRA rights.

7.6 How to Exercise Your Rights. To exercise any of the rights described above, please contact us at matt@brightrhq.com or by mail at Beacon Mobile, Inc., ATTN: Matt Mason, 41 University Drive, Suite 400, Newtown, PA 18940. We will verify your identity before processing your request and respond within the timeframes required by applicable law.

8. Cookies and Tracking Technologies

8.1 Types of Cookies. The following types of cookies are used on the Site: (i) strictly necessary cookies, which are essential to enable you to use the Site and its features; (ii) performance cookies, which collect aggregated, anonymous information about how visitors use the Site; (iii) functionality cookies, which allow the Site to remember your choices and provide enhanced features; and (iv) advertising cookies, which are used to deliver advertisements more relevant to you and your interests and to measure the effectiveness of advertising campaigns.

8.2 Third-Party Cookies. We allow third parties with which we have a separate agreement to use cookies and similar technologies to collect information about your use of the Site. These third parties include business partners and advertising networks. We do not share with these third parties information that would readily identify you (such as your email address), though they may have access to information about your device (such as IP or MAC address).

9. Interest-Based Advertising

We may work with third parties such as advertising networks, attribution partners, and business partners to understand the profiles of individuals who may be interested in our products or services and to measure the effectiveness of advertisements. We may use cookies, beacons, pixels, tags, mobile advertising IDs, and similar technologies for these purposes. You may opt out of receiving interest-based advertising by visiting www.aboutads.info/consumers and www.networkadvertising.org. These opt-out features will remove you from many, but not all, interest-based advertising activities.

10. Do Not Track

Some browsers include a Do Not Track feature that sends a signal to the websites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to them. You may opt out of interest-based advertising as described in Section 9. Choices you make may be browser- and device-specific.

11. Third-Party Services

The Service may contain features or links to websites and services provided by third parties. Information you provide on third-party sites or services is subject to those parties' own privacy policies. We are not responsible for the privacy and security practices of third-party sites or services. We encourage you to review their privacy policies before providing them with information.

12. Children's and Minors' Privacy

12.1 Under 13. Our Service is not directed to children under the age of thirteen (13), and we do not knowingly collect Personal Data from children under thirteen (13). If you are under thirteen (13) years of age, do not use or access the Service or provide any personal information through it. If we learn that Personal Data has been collected from a person under thirteen (13) without verifiable parental consent, we will take appropriate steps to delete that information. If you are a parent or guardian and discover that your child under thirteen (13) has provided us with Personal Data, please contact us at support@brightrhq.com.

12.2 Under 18 — SMS Program. You must be at least eighteen (18) years of age to opt in to the SMS Program. We do not knowingly collect mobile phone numbers through the SMS Program from individuals under eighteen (18). If we learn that a person under eighteen (18) has opted in to the SMS Program, we will promptly unenroll them and delete their SMS opt-in data. Individuals between thirteen (13) and seventeen (17) years of age may use the web-based features of the Service (such as the web concierge) but may not opt in to receive SMS messages.

13. Data Retention

We retain Personal Data collected from a User or Visitor for as long as the User's account is active or as long as we need it to fulfill the purposes for which it was collected, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13.1 SMS Consent Records. We retain SMS opt-in consent records (including your phone number, opt-in timestamp, the consent language displayed, event context, and source URL) for the duration of the messaging relationship and for four (4) years after opt-out or the end of the messaging relationship, whichever is later, in order to document compliance with applicable law.

13.2 Account Data. The contents of closed accounts are deleted within a reasonable period after closure. Backups are retained for a limited period. Billing and transaction information is retained as needed to comply with applicable legal, accounting, and tax obligations.

13.3 Deletion. When Personal Data is no longer required, we take reasonable steps to delete or de-identify it.

14. Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and after receipt. We maintain appropriate administrative, technical, and physical safeguards to protect Personal Data against accidental or unlawful destruction, loss, unauthorized alteration, disclosure, access, or misuse. This includes firewalls, password protection, access and authentication controls, and encryption of data during transmission using SSL/TLS technology. However, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the security of any information you transmit to us or store on the Service. If we learn of a security breach, we will inform you and the relevant authorities in accordance with applicable law.

15. International Users

The Service is directed to users in the United States and is hosted in the United States. If you access the Service from outside the United States, please be aware that your information may be transferred to, processed, and stored in the United States, which may not have the same data protection laws as your country of residence. By using the Service, you consent to the transfer of your information to the United States.

16. Data Controller and Data Processor

Beacon Mobile does not own, control, or direct the use of Client Data stored or processed by a Client or User through the Service. Only the Client or User is entitled to access, retrieve, and direct the use of such Client Data. Beacon Mobile does not directly access Client Data except as authorized by the Client or as necessary to provide the Service. Where Beacon Mobile processes Personal Data contained in Client Data on behalf of a Client, Beacon Mobile acts as a data processor, and the Client acts as the data controller. Beacon Mobile is not responsible for the content of Client Data or the manner in which the Client collects, handles, or processes such information.

17. Changes to This Policy

We may update this Policy from time to time. If we modify this Policy, we will post the revised version on the Site and update the "Last Updated" date above. Your continued use of the Service after the revised Policy becomes effective indicates that you have read, understood, and agreed to the current version.

18. How to Contact Us

For general questions, support, or to exercise your choices under this Policy: support@brightrhq.com

For legal notices, privacy rights requests, or data protection inquiries: matt@brightrhq.com

Beacon Mobile, Inc., ATTN: Matt Mason, 41 University Drive, Suite 400, Newtown, PA 18940