Privacy Policy
Last Updated: March 15, 2025
At Brighton Low, we take your privacy seriously. This policy explains how we collect, use, and protect your personal information when you visit our website or use our investment analysis services.
We're based in the Philippines and operate under the relevant data protection regulations including the Data Privacy Act of 2012 (Republic Act No. 10173). But honestly, beyond legal compliance, we simply believe in treating your data with respect.
Quick Contact: For any privacy concerns, reach us at contact@brightonlow.com or call +639957120094
What Information We Collect
We collect information that helps us provide better investment analysis services. Some of this you give us directly, and some we gather automatically when you use our website.
Information You Provide
When you sign up for our services or contact us, you might share:
- Basic details: Your name, email address, phone number, and mailing address
- Account information: Username, password, and security questions
- Financial data: Investment goals, risk tolerance, portfolio details (only what you choose to share)
- Payment information: Billing address and payment method details for subscription services
- Communication records: Messages you send us through contact forms or email
Information We Collect Automatically
Like most websites, ours gathers some technical information to function properly:
- Device data: IP address, browser type, operating system, device identifiers
- Usage patterns: Pages you visit, features you use, time spent on different sections
- Location data: General geographic location based on IP address (not precise GPS)
- Cookies and similar tech: Small files that help remember your preferences and analyze site performance
How We Use Your Information
We don't sell your data. Period. Here's what we actually do with it:
Primary Uses:
Your information helps us deliver and improve our investment analysis services, communicate with you about your account, and ensure platform security.
- Service delivery: Processing your requests, providing personalized investment insights, managing your account
- Communication: Sending important updates about your account, responding to inquiries, sharing educational content you've opted into
- Improvement: Analyzing how people use our platform to make it better and develop new features
- Security: Detecting fraud, preventing abuse, protecting against security threats
- Legal compliance: Meeting regulatory requirements in the Philippines financial services sector
- Marketing: Sending promotional materials about our services (only if you've agreed to receive them)
Data Storage and Security
We store your information on secure servers and implement multiple layers of protection. Our data centers use industry-standard security measures including encryption, firewalls, and access controls.
Security Measures
- Encryption: All sensitive data is encrypted both in transit (using SSL/TLS) and at rest
- Access controls: Only authorized personnel can access your data, and access is logged
- Regular audits: We conduct security reviews and vulnerability assessments quarterly
- Secure infrastructure: Our hosting providers meet international security standards
- Employee training: Our team receives regular privacy and security training
Important Note: While we implement robust security measures, no system is completely impenetrable. We continuously work to protect your data, but we can't guarantee absolute security. If we detect any breach affecting your information, we'll notify you promptly as required by Philippine law.
Data Retention
We keep your information for different periods depending on its purpose:
| Data Type | Retention Period | Reason |
|---|---|---|
| Account information | Duration of account plus 5 years | Legal and regulatory requirements |
| Financial transaction records | 7 years from transaction date | Tax and audit compliance |
| Communication logs | 3 years | Customer service and dispute resolution |
| Website analytics | 26 months | Performance analysis and improvement |
| Marketing consent records | Until consent withdrawn plus 1 year | Proof of consent for regulatory purposes |
Sharing Your Information
We share your data sparingly and only when necessary. Here's when and why we might share your information with others:
Service Providers
We work with trusted third parties who help us operate our platform. These include payment processors, email service providers, cloud hosting companies, and analytics tools. They can only use your data to provide services to us and are bound by confidentiality agreements.
Legal Requirements
We may disclose information when required by Philippine law, court orders, or regulatory authorities. This includes cooperating with the Securities and Exchange Commission (SEC), National Privacy Commission, or law enforcement when legally obligated.
Business Transfers
If Brighton Low is acquired, merges with another company, or sells assets, your information may be transferred as part of that transaction. You'd be notified beforehand and have options regarding your data.
What We Don't Do:
We never sell your personal information to data brokers, marketing companies, or other third parties. We don't share your investment details or financial information for advertising purposes.
Your Rights and Choices
Under Philippine data privacy law, you have several rights regarding your personal information. We're committed to helping you exercise these rights promptly.
Access Your Data
You can request a copy of the personal information we hold about you. We'll provide it in a readable format within 15 days of your request.
Correction Rights
If your information is inaccurate or incomplete, you can ask us to correct it. You can update most details directly through your account settings.
Deletion Requests
You can request deletion of your personal data, subject to legal retention requirements. Some information must be kept for regulatory compliance even after account closure.
Object to Processing
You can object to certain uses of your data, particularly for marketing purposes. We'll stop processing your data for those purposes unless we have compelling legitimate grounds.
Data Portability
You can request your data in a structured, commonly used format to transfer it to another service provider.
Withdraw Consent
Where we rely on your consent to process data, you can withdraw that consent anytime. This won't affect processing that occurred before withdrawal.
How to Exercise Your Rights
To exercise any of these rights, contact our Data Protection Officer at contact@brightonlow.com or write to us at:
Brighton Low Data Protection Office
2424, Taft Avenue, corner Gil Puyat Avenue
Barangay 49, Pasay City
1300 Metro Manila, Philippines
Include your full name, email address, and specific request. We'll verify your identity before processing requests to protect your security.
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance your experience and analyze site performance. You have control over most of these.
Types of Cookies We Use
- Essential cookies: Required for the website to function properly. These can't be disabled without breaking core features like login and security.
- Functional cookies: Remember your preferences and settings to personalize your experience.
- Analytics cookies: Help us understand how visitors use our site so we can improve it. We use these to track page views, session duration, and navigation patterns.
- Performance cookies: Monitor site speed and technical performance to identify and fix issues.
Managing Cookie Preferences
You can control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing ones. Keep in mind that blocking certain cookies may affect site functionality. For detailed instructions on managing cookies in different browsers, visit your browser's help section.
International Data Transfers
While we primarily operate within the Philippines, some of our service providers are located in other countries. When we transfer data internationally, we ensure appropriate safeguards are in place.
These safeguards include using service providers that comply with internationally recognized privacy frameworks, implementing standard contractual clauses, and ensuring equivalent levels of data protection. Any international transfers comply with the Philippine Data Privacy Act requirements.
If you're accessing our services from outside the Philippines, your information will be transferred to and processed in the Philippines, where our servers are located.
Children's Privacy
Our services are not intended for anyone under 18 years old. We don't knowingly collect personal information from minors. If you're a parent or guardian and believe your child has provided us with personal information, please contact us immediately so we can delete it.
Investment services and financial analysis require legal capacity to enter contracts, which is why we restrict our services to adults.
Third-Party Links
Our website may contain links to external sites, resources, or services. We're not responsible for the privacy practices of these third parties. When you click a link leaving our site, we encourage you to read that site's privacy policy.
This is particularly relevant for educational resources, market data sources, and partner platforms we may reference. Each operates under its own privacy terms.
Changes to This Policy
We update this privacy policy occasionally to reflect changes in our practices, services, or legal requirements. When we make significant changes, we'll notify you through email or a prominent notice on our website.
The "Last Updated" date at the top of this policy shows when it was most recently revised. We recommend reviewing this policy periodically to stay informed about how we protect your information.
Continued use of our services after policy changes indicates acceptance of the updated terms. If you disagree with changes, you can close your account by contacting us.
Regulatory Compliance
Brighton Low is committed to complying with the Philippine Data Privacy Act of 2012 and regulations issued by the National Privacy Commission. We're registered as a Personal Information Controller and maintain appropriate organizational and technical measures.
National Privacy Commission
If you believe we've violated your privacy rights or mishandled your personal data, you have the right to file a complaint with the National Privacy Commission. You can reach them at:
National Privacy Commission
5th Floor, Philippine International Convention Center (PICC)
Vicente Sotto Street, Pasay City, Metro Manila
Email: info@privacy.gov.ph
Hotline: (02) 8234-2228
We encourage you to contact us first so we can address your concerns directly, but you always have the option to escalate matters to the regulatory authority.