Skip to main content

FNF NV BRASADA, LLC | PRIVACY POLICY

Your privacy is very important to us. FNF NV Brasada, LLC created this Privacy Policy to let you know how we collect, use, share, and process your personal information, as well as your rights in determining what we do with the information that we collect and store about you when you access our website, https://www.brasada.com (collectively, the “Site”) or the features, content, or applications offered by FNF NV Brasada, LLC (collectively, the “Services”).

The Site and all related Services are provided by FNF NV Brasada, LLC. If you have any questions or comments about this Privacy Policy or about our use of your personal information, please contact us at 15 River Road Suite #15B, Wilton, CT 06897, or by email at info@NVHG.com


INFORMATION COLLECTED

When you visit our Site, we collect two types of information: personal information you give us and usage information automatically collected as you browse. The following are the specific types of information we collect from you.


INFORMATION YOU GIVE US:

We collect information you give us on our Sites and when you register for and use our Services. Examples include the following:

  • Registration and Profile Information: When you register to use our Services or update your profile, we collect various kinds of information about you, including, your name and email address; your title, company, and other profile information you provide; demographic information; information about your skills and preferences (if you are an influencer); and information you upload like photos, files, and documents.

  • Payment Information: If you choose to use a paid account or service, our payment processing vendor collects your credit card information and billing address.

  • Content Related Information: When uploading pictures, a name and an email address may be required. Generally, the information collected helps us to communicate with you regarding the content that you have submitted. For instance, we may use your email address to notify you of the status of the content you have submitted.


INFORMATION WE COLLECT AUTOMATICALLY:

While you visit or use our Sites or Services, certain information, including personal information, is collected about your use of the Sites and Services. Examples include the following:

  • Log and Usage Data. When you visit the Sites, our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. We use Log Data to monitor the use of the Site and Services and for the Site's technical administration. We use this information for internal system administration, to help diagnose problems with our server, and to administer the Site. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may link this information with your personal information.

Any or all of these activities with regard to Site usage information may be performed on FNF NV Brasada, LLC’s behalf by our service providers, including, for example, our analytics vendor(s) and our email management partner(s).

  • Cookies and Similar Tracking Technologies. Like many websites, we also use "cookie" and similar tracking technology to collect additional website usage data and to improve the Sites and Services. A cookie is a small data file that we transfer to your computer's hard disk. We do not use cookies to collect personally identifiable information, may use both session cookies and persistent cookies to better understand how you interact with the Sites and Services, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Sites and Services.


A session cookie enables certain features of the Site and our Services and is deleted from your computer when you disconnect from or leave the Site
. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.



Third parties on FNF NV Brasada, LLC’s Site may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes
. If you would prefer not to receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit:
- Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices)
- European Interactive Digital Advertising Alliance (EDAA)'s consumer opt-out page (http://youronlinechoices.eu)
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here http://www.networkadvertising.org/mobile-choices

Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.

You may sign-up to receive emails or other communications from us. If you would like to discontinue receiving this content, you may update your marketing preferences by using the “Unsubscribe” link found in the emails or toggling off the “Opt-in” button located in your privacy setting page.
We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com


PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

The purposes for which we process information about you are as follows:

  • To operate and improve our Sites and Services and to foster a positive user experience.

  • To enable secure use of the Sites and Services.

  • To enable secure use of the Sites and Services.

  • To obtain feedback, to conduct market analysis, and to analyze usage of the Sites and Services in order to develop, customize and improve the Sites and Services.

  • To publish comments that you make to our publicly accessible blogs.

  • To enable you to communicate, collaborate, and share files with users you designate.

  • To send you communications relating to your use of the Service, including, for example, welcoming and confirmation emails; responses to your emails, support inquiries, submissions, comments, requests or complaints, information on updates to services that better meet your needs; and notification if you win a contest.

  • With your consent, to send you surveys or newsletters, to contact you about services, products, activities, special events or offers from or our partners and for other marketing, informational, and promotional purposes.

  • To meet legal obligations.

  • To protect our rights and property.

  • For other purposes about which we notify you.

FNF NV Brasada, LLC’s legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the context in which we collect it. We collect personal information from you:

  • Where we need it to perform a contract with you;

  • Where the processing is in our legitimate interests (including the purposes described above);

  • Where we need it to comply with a legal obligation;

  • If we otherwise have your consent.


SHARING OF PERSONAL INFORMATION

We will not share, rent or sell personal information with any person or entity, except as set forth in this Privacy Policy below:

  • Third Party Service Providers/Vendors: We may use third party partners to help operate the Site and deliver our features and Services, and may share your information with service providers and other third parties that provide products or Services for or through this Site or for our business (such as Web site or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf).

  • Business Partners: With your consent, FNF NV Brasada, LLC may share your information with business partners whose sites you have submitted content to, to allow them to provide you with offers, promotions, products, and services.

  • Legal Compliance and Protection of Rights and Interests: In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights or property, to defend against legal claims, to prevent abuse, to protect your safety or the safety of others, to investigate fraud, or to respond to a government request.

  • Affiliates: We disclose your personal information to affiliated companies related by common ownership or control to carry out regular business activities.

  • Corporate Transactions: If FNF NV Brasada, LLC is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transactions, we reserve the right to sell or transfer your information as part of the transaction. In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your personal information, and choices you may have regarding your personal information.


SECURING YOUR INFORMATION

FNF NV Brasada, LLC is very concerned about safeguarding the confidentiality of personal information. We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your personal information. Due to the inherent nature of the Internet as an open global communications vehicle, we make no guarantee as to the security of your information or that your information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.


DATA RETENTION

We process your personal information for the minimum period necessary for the purposes set out in this Privacy Notice unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your personal information, and after the retention period ends, we will delete or anonymize your personal information. When we cannot do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your personal information.


THIRD-PARTY LINKS

FNF NV Brasada, LLC Sites or Services may contain links to third party websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.


YOUR ACCESS AND OTHER DATA SUBJECT RIGHTS

We respect your control over your personal information. You may exercise any of the following rights by sending an email with details of your request to info@NVHG.com
Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

  • Request access to the personal information that we process about you;

  • Request that we correct inaccurate or incomplete personal information about you;

  • Request deletion of personal information about you;

  • Request restrictions, temporarily or permanently, on our processing of some or all personal information about you;

  • Request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated;

  • Opt-out or object to our use of personal information about you where our use is based on your consent or our legitimate interests.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal information. We encourage you to contact us at info@NVHG.com, so we can address your concerns directly before you do so.


CHILDREN’S PRIVACY

The Sites and Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children without parental consent.


INTERNATIONAL TRANSFER OF INFORMATION COLLECTED

Please be aware that personal information may be transferred, stored, and processed outside of your country, including in the USA. Although we take steps to provide adequate safeguards, the data protection laws in those countries might not be as comprehensive as those in your country.
FNF NV Brasada, LLC endeavors to apply suitable safeguards to protect the privacy and security of personal information wherever it is transferred, and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.


CHANGES TO PRIVACY STATEMENT

We may amend this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page and will indicate at the top of this page the Privacy Policy’s effective date. We therefore encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current Privacy Policy terms.


THIRD PARTY USE POLICIES

Use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.


CONTACTING THE COMPANY

For questions or comments regarding this Privacy Policy, please contact us at: info@NVHG.com 15 River Road Suite #15B, Wilton, CT 06897


CONTENT UPLOADER TERMS OF USE

FNF NV Brasada, LLC respects the intellectual property rights of third parties and responds to allegations that copyrighted material has been shared through our site (“Platform”), without authorization from the copyright holder, in accordance with the safe harbor set forth in the Digital Millennium Copyright Act (“DMCA”). We will also, in appropriate circumstances and at our discretion, disable and/or terminate the use of the Platform by users who may infringe or repeatedly infringe the copyrights of others in accordance with the DMCA.


A. NOTIFICATION OF ALLEGED COPYRIGHT INFRINGEMENT

If you believe that your work has been copied and made available in a way that constitutes copyright infringement, you may send a written document to info@NVHG.com that contains the following (a “Notice”):

  • A description of the copyrighted work that you claim has been infringed.

  • Identification of the URL or other specific location that contains the material that you claim infringes your copyright described in Item 1 above. You must provide us with reasonably sufficient information to locate the allegedly infringing material.

  • An electronic or physical signature of the owner of the copyright or of the person authorized to act on behalf of the owner of the copyright.

  • A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or applicable law.

  • A statement by you that the information contained in your Notice is accurate and that you attest under the penalty of perjury that you are the copyright owner or that you are authorized to act on the owner's behalf.

  • Your name, mailing address, telephone number, and email address.


Please note that you may be liable for damages, including court costs and attorneys fees, if you misrepresent that content uploaded by another Platform user is infringing your copyright.

Upon receiving a proper Notice, FNF NV Brasada, LLC will remove or disable access to the allegedly infringing material and notify the alleged infringer of your claim. We will also advise the alleged infringer of the DMCA Counter Notice Procedure described below in Section B by which the alleged infringer may respond to your claim and request that we restore this material.


B. COUNTER NOTICE PROCEDURE

If you believe your own copyrighted material has been removed from the Platform in error, you may submit a written Counter Notice to info@NVHG.com that includes the following:

  • Identification of the material that has been removed or disabled and the location at which the material appeared before it was removed or disabled.

  • A statement that you consent to the jurisdiction of the Federal District Court in which your address is located, or if your address is outside the United States, the Northern District of California or any other judicial district in which may be found.

  • A statement that you will accept service of process from the party that filed the Notice or the party's agent.

  • Your name, address and telephone number.

  • A statement under penalty of perjury that you have a good faith belief that the material in question was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.

  • Your physical or electronic signature.

If you send a valid, written Counter Notice meeting the requirements described above, FNF NV Brasada, LLC will restore your removed or disabled material within 10 to 14 business days from the date we receive your Counter Notification, unless we first receive notice from the party filing the original Notice informing us that such party has filed a court action to restrain you from engaging in infringing activity related to the material in question.

Please note that if you misrepresent that the disabled or removed content was removed by mistake or misidentification, you may be liable for damages, including costs and attorney's fees.


C. REPEAT INFRINGER POLICY

In accordance with the DMCA and other applicable laws, we will, at our discretion, disable and/or terminate access to the Platform by users who may infringe or repeatedly infringe the copyrights of others. This determination will be based on the number of “strikes” against the user. A “strike” is counted against a user each time there is an adjudication by a court, arbitrator or other tribunal of competent jurisdiction that the user has engaged in copyright infringement of any kind in relation to the Platform.

In accordance with the DMCA and other applicable laws, we will, at our discretion, disable and/or terminate access to the Platform by users who may infringe or repeatedly infringe the copyrights of others. This determination will be based on the number of “strikes” against the user. A “strike” is counted against a user each time there is an adjudication by a court, arbitrator or other tribunal of competent jurisdiction that the user has engaged in copyright infringement of any kind in relation to the Platform.

Each adjudication counts as a separate strike. If an adjudication pertains to multiple instances of copyright infringement, it can count as multiple strikes. has adopted a “three strikes and you’re out” policy under which a user who accumulates three strikes is considered a repeat infringer and may be subject to account termination.


D. REPRESENTATIONS AND WARRANTIES

You represent and warrant that any content you upload to the Platform does not violate the rights of any third party, including, without limitation, the intellectual property, privacy or publicity rights of any third party, and constitutes an original work of authorship by you.


E. USER CONTENT RESTRICTIONS

You may not upload, post, or transmit any images, video, text, audio, or other content or materials (collectively, “User Content”) that: (a) would violate or infringe our proprietary, privacy, publicity, or intellectual property rights, or those of any third party; (b) is obscene, defamatory, threatening, harassing, abusive, libelous, hateful, or harmful to any other person or entity; (c) violates any applicable law, statute, ordinance, or regulation; (d) puts in jeopardy the security of your account, us, the Platform, or any third party; or (e) promotes or displays any of the following content: (i) pornography; (ii) violence; (iii) racial intolerance or advocacy against any individual, group, or organization; (iv) profanity; or (v) illicit drugs and drug paraphernalia. We reserve the right, but have no obligation, to pre-screen, review, flag, filter, modify, refuse, and remove any and all User Content from this site. You understand and expressly acknowledge that by using the Platform you may be exposed to content that you find offensive, indecent, or objectionable and that we will not be liable to you or any other person or entity for your consumption of any content on the Platform.



DATA PROCESSING ADDENDUM

This Data Processing Addendum (DPA) amends our Terms of Service (also Agreement) and sets out the terms that apply when Personal Information is processed by under the Agreement. The purpose of the DPA is to ensure such processing is conducted in accordance with applicable laws and with due respect for the rights and freedoms of individuals whose Personal Information is processed. Other capitalized terms used but not defined in this DPA have the same meanings as set out in the Agreement.


1. DEFINITIONS

  • 1.1 For the purposes of this DPA:
    a) “EEA" means the European Economic Area, which constitutes the member states of the European Union, the United Kingdom, Norway, Iceland and Liechtenstein.
    b) “California Consumer Privacy Act of 2018” or “CCPA” means Assembly Bill 375 of the California House of Representatives, an act to add Title 1.81.5 (commencing with Section 1798.100) to Part 4 of Division 3 of the Civil Code, relating to privacy and approved by the California Governor on June 28, 2018;
    c) “EU Data Protection Legislation” means (i) prior to 25 May 2018, Directive 95/46/EC of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal information and on the free movement of such data, including any applicable national implementations of it; and (ii) on and after 25 May 2018, Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal information and on the free movement of such data, and repealing Directive 95/46/EC (as amended, replaced or superseded) ("GDPR");
    d) “Controller” shall mean the entity which, alone or jointly with others, determines the purposes and means of the processing of Personal Information;
    e) “Processor” shall mean an entity which processes Personal Information on behalf of the Controller; and
    f) “Personal Information” means any information relating to an identified or identifiable natural person.


2. APPLICATIONS OF DPA

  • 2.1 Applicability. This DPA will apply only to the extent that processes Personal Information from the EEA on behalf of “You” the Customer.

  • 2.2 GDPR. This DPA inclusive of Exhibits A and B will apply only on and after 25 May 2018. Where the GDPR materially or adversely impacts our continued provision of the Services (including its costs in providing the Services) and / or Customer's receipt of the Services, the Parties shall discuss in good faith and acting reasonably, what changes may be necessary and operationally, technically and commercially feasible to the Agreement and/or the DPA and/or the Services (including, without limitation, the fees payable by Customer to for the Services) in order to enable to continue providing the Services. No such changes shall be effective unless agreed between the Parties pursuant to this Clause.


3. ROLES AND RESPONSIBILITIES

  • 3.1 Parties' Roles. To the extent that FNF NV Brasada, LLC processes Personal Information in the course of providing the Services, it will do so only as a Processor acting on behalf of Customer (as Controller) and in accordance with the requirements of the Agreement.

  • 3.2 Purpose Limitation. FNF NV Brasada, LLC will process the Personal Information only for the purpose of providing the Services and in accordance with Controller’s lawful instructions.

  • 3.3 Compliance. Customer, as Controller, shall be responsible for ensuring that:
    a) It has complied, and will continue to comply, with all applicable laws relating to privacy and data protection, including EU Data Protection Legislation; and
    b) It has, and will continue to have, the right to transfer, or provide access to, the Personal Information to for processing in accordance with the terms of the Agreement and this DPA
    c) FNF NV Brasada, LLC providing an accurate and up to date Data Security Contact name, and contact information available during both business and non-business hours.


4. SECURITY

  • 4.1 Security. FNF NV Brasada, LLC will have in place and maintain throughout the term of this Agreement appropriate technical and organizational measures to protect the Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing (a “Security Incident”).

  • 4.2 Security Incident. In the event of a Security Incident, FNF NV Brasada, LLC will notify Customer via Customer’s designated Data Security Contact and provide reasonable assistance in order to remedy or mitigate the effects of the Security Incident.


5. TERM AND TERMINATION

  • 5.1 Subprocessing. Customer authorizes FNF NV Brasada, LLC to subcontract processing of Personal Information under the Agreement to a third party provided that flows down Section 3.2 and Section 4.1 to any subcontractor it appoints.


6. INTERNATIONAL TRANSFERS

  • 6.1 Adequacy. FNF NV Brasada, LLC will provide an adequate level of protection for Personal Information that it processes on behalf of Customer in accordance with the requirements of EU Data Protection Legislation.


7. SERVICE DATA

  • Notwithstanding anything in this DPA, FNF NV Brasada, LLC will have the right to collect, extract, compile, synthesize and analyze non‐personally identifiable data or information resulting from Customer's use or operation of the Services (“Service Data”) including, by way of example and without limitation, information relating to volumes, frequencies, recipients, bounce rates, or any other information regarding the communications FNF NV Brasada, LLC Customer, its end users or recipients generate and send using the Services. To the extent any Service Data is collected or generated by us, such data will be solely owned by and may be used by for any lawful business purpose without a duty of accounting to FNF NV Brasada, LLC Customer or its recipients, provided that such data is used only in an aggregated form, without directly identifying any person. For the avoidance of doubt, this DPA will not apply to Service Data.


8. MISCELLANEOUS

  • 8.1 Except as amended by this DPA, the Agreement will remain in full force and effect.

  • 8.2 If there is a conflict between the Agreement and this DPA, the terms of this DPA will control.

  • 8.3 Any claims brought under this DPA shall be subject to the terms and conditions, including but not limited to, the exclusions and limitations set forth in the Terms of Service.

Exhibit A – GDPR Addendum

  • The following terms in this Exhibit A shall apply to the Agreement and the DPA only on and after 25 May 2018.
    1. Scope. The subject‐matter of the data processing is the provision of the Services and the processing will be carried out for the duration of the Subscription Term. Exhibit B sets out the nature and purpose of the processing, the types of Personal Information processes and the categories of data subjects whose Personal Information is processed.
    2. Instructions. The Terms of Service and this DPA set out FNF NV Brasada, LLC Customer's complete documented instructions in relation to the processing of the Personal Information and any processing required outside of the scope of these instructions will require prior written agreement between the parties.
    3. Purpose Limitation. If FNF NV Brasada, LLC is required to process the Personal Information for any other purpose by European Union or national law to which FNF NV Brasada, LLC is subject, shall inform the Customer of this requirement before the processing, except where otherwise required by such law.
    4. Data Protection Impact Assessments. FNF NV Brasada, LLC shall, to the extent required by EU Data Protection Legislation, provide Customer with reasonable assistance at Customer's cost and expense with data protection impact assessments or prior consultations with data protection authorities that Customer is required to carry out under EU Data Protection Legislation or the CCPA.
    5. Sub‐processing.
    5.1 Customer agrees that FNF NV Brasada, LLC may engage affiliates and third party sub‐processors (collectively, "Sub‐processors") to process the Personal Information on our behalf.
    5.2 FNF NV Brasada, LLC shall impose on such Sub‐processors data protection obligations that protect the Personal Information to the same or substantially similar standard provided for by this DPA and shall remain liable for any breach of the DPA caused by a Sub‐processor.
    6. Security
    6.1 FNF NV Brasada, LLC will ensure that any person that it authorizes to process the Personal Information (including its staff, agents and subcontractors) shall be subject to a duty of confidentiality) whether a contractual or a statutory duty).
    6.2 Upon becoming aware of a Security Incident, FNF NV Brasada, LLC shall notify Customer via Customer’s provided Data Security Contact, without undue delay and shall provide such timely information as Customer may reasonably require, including to enable Customer to fulfil any data breach reporting obligations under EU Data Protection Legislation or the CCPA. FNF NV Brasada, LLC shall promptly take appropriate steps to remedy or mitigate any damage arising from such a Security Incident.
    7. Audit. While it is the parties' intention ordinarily to rely on the provision of the documentation to verify our compliance with this DPA, FNF NV Brasada, LLC shall permit the Customer (or its appointed third party auditors) to carry out an audit of processing of Personal Information under the Agreement following a Security Incident suffered by us, or upon the instruction of a data protection authority. Customer must give reasonable prior notice of such intention to audit, conduct its audit during normal business hours, and take all reasonable measures to prevent unnecessary disruption to our operations. Any such audit shall be subject to our security and confidentiality terms and guidelines.
    8. Data subjects' rights. FNF NV Brasada, LLC shall, taking into account the nature of the processing, provide reasonable assistance to Customer insofar as this is possible and at Customer's cost and expense, to enable Customer to respond to requests from a data subject seeking to exercise their rights under EU Data Protection Legislation. In the event that such a request is made directly to us, we shall promptly inform Customer of the same.
    9. Deletion / return of Personal Information. Upon termination or expiry of the Subscription Term, we shall, at Customer's election, delete all relevant Personal Information (including copies) in our possession, save to the extent that is required by any applicable law to retain some or all of the Personal Information.
    10. If there is a conflict between the DPA and this Exhibit, the terms of this Exhibit will control.

Exhibit B – Data Processing Appendix

Data subjects
The Personal Information transferred concern the following categories of data subjects (please specify): End users – individuals who interact with the Customer by way of the communication platform.

Categories of data
The Personal Information transferred concern the following categories of data: IP Address, Device info (Operating system, Browser), Cookie dropped anonymous ID, Email, Full Name, location data, Facebook Username, Instagram Username, Facebook Avatar, Instagram Bio, Unique social Id for Instagram/Facebook/ Twitter, and interactions with end users via the communication platform.

Special categories of data (if appropriate)
The Personal Information transferred concern the following special categories of data: None.

Processing operations
The personal information transferred will be subject to the following basic processing activities (please specify):

  • Personal Information will be transferred from the Customer to for to provide a communication platform to facilitate interaction and engagement between the Customer and the end user.

  • This service will consist of providing a communication platform for the Customer to use in order to onboard and retain end users as well as analyze their use of the Customer's product and / or services.

  • Full details about our products and services can be found at https://www.nvhg.com

Exhibit C – California Consumer Privacy Act of 2018

  • 1. FNF NV Brasada, LLC is a “Service Provider” as defined in CCPA Section 1798.140(v).
    2. Customer discloses Personal Information to solely for: (i) a valid business purpose; and (ii) to perform the Services.
    3. FNF NV Brasada, LLC is prohibited from: (i) selling Personal Information; (ii) retaining, using, or disclosing Personal Information for a commercial purpose other than providing the Services; and (iii) retaining, using, or disclosing the Personal Information outside of the Agreement between and Customer.
    4. FNF NV Brasada, LLC understands the prohibitions outlined in Section 4.