PRIVACY NOTICE
Last updated September 12, 2026
This privacy notice for CMO Success, LLC (doing business as Bright Growth) ("Bright Growth," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
• Visit our website at brightgrowth.io, or any website of ours that links to this privacy notice
• Create an account and use our AI CMO Operating System Platform at app.brightgrowth.io, where we deliver your marketing audit, plan, and execution engagement
• Request a complimentary Marketing Snapshot for your company, which we generate automatically from publicly available information
• Respond to an Alignment Survey that one of our customers asks us to send you
• Respond to a Team Onboarding Survey that one of our customers asks us to send you
• Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@brightgrowth.io.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also clickhereto go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, including creating an account on app.brightgrowth.io, we may process personal information depending on how you interact with Bright Growth and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not request or knowingly process sensitive personal information.
Do we receive any information from third parties? In most cases, no. The personal information we process about you is the information you provide to us directly. There are three exceptions. For our Investor Directory and Partner Directory features, we receive limited business contact information about investors, firm partners, and vendor representatives from third-party sources; this is not information about you as a visitor or customer, and it is not your data. If you are an executive at one of our customers, they may provide us with your name, title, and work email address so we can send you an Alignment Survey on their behalf. And if you are a member of one of our customers' marketing teams, that customer may give us your name, job title, and work email address so we can send you a Team Onboarding Survey on their behalf.
Do you use AI to process my information? Bright Growth may use AI-assisted tools, including large language models accessed through a commercial Anthropic (Claude) account, on or off the AI CMO Operating System Platform, to augment our Services, including analyzing the documents and information you provide (documents you upload may be sent to the AI provider for that analysis), researching your company's and named competitors' public web presence, and preparing your audit, plan, and execution deliverables. Documents the platform generates for an engagement are produced by AI-assisted software and show on their face whether a Bright Growth person has reviewed them yet. If you request a complimentary Marketing Snapshot, our tools research your company's public web presence and generate the Snapshot automatically, without any human review. Consistent with the commercial terms of the AI providers we use, that content is not used to train their models.
Do you make automated decisions about me? No. What we score is an organization: the publicly visible marketing of a company, or the working relationship between two of its teams. Neither evaluates, scores, or profiles you as an individual nor produces legal or similarly significant effects concerning you. Click here to learn more.
How do we process your information? We process your information to provide, improve, and administer our Service; communicate with you; protect against security risks and fraud; and comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties, including the service providers who help us operate brightgrowth.io and app.brightgrowth.io. Click here to learn more.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by emailing us at privacy@brightgrowth.io. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what Bright Growth does with any information we collect? Click here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you create an account or otherwise participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
• names
• email addresses
Information You Provide Through the AI CMO Operating System Platform. If you create an account on app.brightgrowth.io, we collect your work email address and a password (stored securely by our authentication provider; we never see it in plain text). The organization and role associated with your account come from the invitation you accepted, issued either by Bright Growth as part of setting up your engagement or by an administrator at your own organization, rather than being collected from you at signup. If your engagement involves uploading documents (brand guidelines, plans, decks, or other business data), those documents are stored in a private, organization-scoped storage area and are used only to deliver your engagement. We do not knowingly ingest your own customers' or prospects' contact-level records (names, emails, phone numbers) through this process. Documents you upload may contain personal information about your own personnel or third parties; we process that content solely to deliver your engagement and treat it as confidential, consistent with this notice.
Connected Business Systems and Communications Sources (optional platform features). Some engagements include connecting the platform, with your organization's explicit authorization, to business systems your organization already uses. Three options exist. The first two are read-only connections your organization can revoke at any time from within the platform; the third involves no connection to us at all:
• Business-system metrics. If your organization connects a system such as a CRM, marketing automation platform, or web analytics tool, automated processes read that system to compute aggregate marketing metrics (for example, lead volume, conversion rates, and pipeline coverage). Only the aggregate results are stored on the platform. Individual contact records in those systems are read in place solely to compute the aggregates and are never stored by us.
• Conversation intelligence. If your organization enables this optional feature and connects a communications source (for example, a meeting-notes tool, team messaging, or email), AI-assisted analysis reads those communications to extract structured marketing findings, such as commonly raised objections, competitor mentions, or how customers first heard of your organization. Only the findings, and short supporting excerpts that are screened to remove personal contact details before storage, are stored. Full conversations, recordings, and transcripts are never stored by us.
• Your own AI, our findings (optional). Your organization may instead choose to run the analysis itself, inside its own AI provider account, against communications it holds. In that case only the finished finding and its short supporting excerpt are sent to Bright Growth: the conversation, recording, or transcript itself never reaches Bright Growth or Bright Growth's AI provider. Your organization's own AI provider is not one of our subprocessors; your organization chooses it, contracts with it, and instructs it, and we are not part of that relationship. If your organization chooses the same AI provider we happen to use, that provider is acting for your organization in this role, not for us, and the conversation still does not reach our account. Your organization is responsible for removing personal contact details before sending a finding; we apply an automated pattern check to what we receive, which refuses anything containing an email address or a phone number and does not detect names, as an additional safeguard rather than a substitute.
Findings derived from your organization's communications are used solely for your organization's engagement. They are never included in cross-customer benchmarks, never shared with any other customer, and not used to train AI models. Because business communications can involve your organization's own personnel, findings are aggregated at the team level by default; whether individual-level attribution is enabled is your organization's administrative choice, made in the platform and logged, and your organization is responsible for any notice to its own workforce required by applicable law. Your organization is likewise responsible for having any consents required to record or hold the communications it connects, or the communications it analyses in its own AI account; we read only what your organization already lawfully holds, and in the option described in the third bullet above we do not read the communication at all. Access to third-party systems (such as conversation-recording vendors) is procured by your organization under its own vendor agreements. Where your organization runs the analysis itself, the responsibility for notifying its own workforce, and for anything else its employment-law obligations require, sits with your organization in the same way.
Information About You If a Bright Growth Customer Invites You to an Alignment Survey. Some engagements include an Alignment Survey, a short questionnaire that measures how well a customer's marketing function and another part of their business, such as sales, product, or finance, are working together. If you receive one, you are almost certainly an executive at that customer's organization, and you reached us this way: someone there entered your name, job title, and work email address so we could send you a link. You do not create an account and you do not need one; the link in the email is yours.
What we collect from you, and who sees it. If you answer, we collect the ratings and selections you give, any comments you write, how confident you say you are, any file you choose to attach as evidence, and basic delivery information (whether and when the invitation was sent, opened, reminded, and completed, and how long you spent answering). Three points are stated here plainly:
• Your answers are attributed, not anonymous. Your name is attached to them. The marketing leader at the organization that sent the survey, and other people they authorize inside their workspace, can see what you said. This is stated on the form itself, before the first question.
• Nothing is visible until both sides have answered. The survey pairs you with a counterpart who answers the same questions on the other side, and neither set of answers can be read until both are submitted.
• It is not a decision about you. Your answers and your counterpart's are compared to grade the working relationship between two teams against a published scoring rubric. It is a fixed calculation rather than an AI judgement, someone at that organization reviews the result before it counts for anything, and nothing about your employment depends on it.
Our role, and where to take a question. The organization that sent you the survey decides whether to run it, who receives it, and what happens to the results; we send, collect, score, and store the responses per their instructions, as their service provider. So questions about why you were asked, or a request to see or delete your responses, are best directed to them. You can also email us at privacy@brightgrowth.io and we will pass your request on and help them act on it. Please do not include sensitive information, or personal information about other people beyond what the question asks, in a comment or an attached file.
Information About You If a Bright Growth Customer Invites You to a Team Onboarding Survey. Some engagements include a Team Onboarding Survey, sent to every member of a customer's marketing team at the start of a fractional-CMO engagement so the incoming leader has a real picture of how the team works before their first one-on-one conversations. If you receive one, you work on that customer's marketing team, and you reached us this way: someone there entered your name, job title, and work email address so we could send you a link. You do not create an account and you do not need one; the link in the email is yours.
What we collect from you, and who sees it. If you answer, we collect the ratings and selections you give, any comments you write, and basic delivery information (whether and when the invitation was sent, opened, reminded, and completed, and how long you spent answering). Three points are stated here plainly:
Your answers are attributed, not anonymous. Your name is attached to them. Only your engagement leader (the fractional CMO running your team's engagement) can see what you wrote. No other member of your organization, including your own colleagues, can see it in the platform. This is stated on the form itself, before the first question.
A few questions ask about people you work with. If a written answer names a colleague or a former manager, that is expected, since a small number of questions ask about your working relationships directly, and we process that content solely to deliver your engagement leader's briefing.
It is not a performance review. Your answers shape a private briefing document and the agenda for your first one-on-one conversation with your engagement leader. Nothing about your employment depends on how you answer.
Retention and what happens when the engagement ends. We keep your recipient details and your responses for two (2) years from the date of the survey by default; the customer that sent it may instruct us to keep them for a shorter or longer period. When the engagement ends, that customer chooses to have your responses kept as they are, to have your name and other identifying details removed while your answers to rating questions are kept in aggregate, or to have your responses deleted entirely; we do not choose this, and neither do you. We delete them sooner if that organization asks us to, or if you ask us to: email privacy@brightgrowth.io.
Our role, and where to take a question. The organization that sent you the survey decided to run it, chose who would receive it, and controls what happens with the results, including the choice described above; we send, collect, and store the responses on their instruction, as their service provider. So questions about why you were asked, or a request to see or delete your responses, are best directed to them. You can also email us at privacy@brightgrowth.io and we will pass your request on and help them act on it. Please do not include sensitive information, or personal information about people other than the colleagues or managers a question specifically asks about, in a comment or an attached file.
Information You Provide When You Request a Complimentary Marketing Snapshot. Anyone can request a complimentary Marketing Snapshot for their company from app.brightgrowth.iowithout an existing engagement. To do that, we collect your company's website address, optionally the names and website addresses of up to three competitors, and your work email address. As soon as you enter a website address, our software runs a brief automated preview scan of that company's public web presence, using the same AI tools described in Section 4, to suggest details for you to confirm; that preview runs before you give us an email address and is the only thing that runs before you do. We use your email address to verify the request, to create a private workspace for your company, and to tell you when your Snapshot is ready. We do not generate the Snapshot itself, or create a workspace, until you confirm your email address. To prevent abuse of this public form, we also record the network address (IP address) each request comes from and the company domain requested, and limit how many requests either can make in an hour.
How the Snapshot is produced, and what it is. Once you confirm, automated processes using large language models (see Section 4) read your company's publicly available web presence (your website, and public sources such as search results, review sites, public social profiles, and news coverage about your company and any competitors you named) and produce a maturity assessment of that company's marketing, scored against our standard evaluation framework, together with the reasoning behind each score. Three points are stated here plainly:
• It is generated automatically. No Bright Growth person writes or reviews your Snapshot before you receive it. It can be incomplete or wrong, and it is our opinion based on what is publicly visible, and not a statement of fact about your business, and not professional advice. Our Terms of Service at brightgrowth.io/terms say more about this.
• It uses only public information. We do not access your internal systems, documents, or private data to produce a Snapshot. Where public evidence does not support an assessment, we leave that item ungraded rather than guessing.
• It is about a company, not a person. The assessment evaluates an organization's marketing. It does not evaluate, score, or profile you or any other individual, and we do not use it to make automated decisions producing legal or similarly significant effects about any individual.
Your Snapshot is private to your company's workspace. We do not publish it, and we do not share it with the competitors you name or with any other customer. If you believe your Snapshot is inaccurate, or you want it and the associated workspace deleted, email privacy@brightgrowth.io, and we will correct or delete it.
Sensitive Information. We do not request or knowingly process sensitive information, and we ask that you not include sensitive information (such as health information, government identifiers, or financial account numbers) in documents you upload or messages you send us.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services, including app.brightgrowth.io. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). On signed-in pages of app.brightgrowth.io, if the page encounters a software error, an error report (the technical details of the error, the page address, and your browser and device type) is sent to our error-monitoring provider (Sentry, described in Section 4) so we can fix it. We do not configure that report to include your name, email address, or account identifier.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect approximate location data derived from your IP address. We do not collect precise (GPS) location data.
A note on website analytics. We use Google Analytics (via Google Tag Manager) on brightgrowth.io to understand how visitors use our site. Google Analytics collects device information and approximate (IP-based) geolocation on a per-visit basis; we review this information in aggregated reports. Because the underlying collection is individual-level, we disclose it as personal information in Section 11 below. We do not use Google Analytics or any other analytics or advertising trackers on app.brightgrowth.io.
A note on content delivery networks. Pages on app.brightgrowth.io, including the public sign-in, Snapshot-request, and survey pages, load open-source script libraries and fonts from third-party content delivery networks (currently jsDelivr, Google Fonts, and, on signed-in pages, Sentry's script CDN). Like any web request, those networks receive your IP address and standard technical request data in order to serve the files; we do not send them any other information about you.
Customer case studies and testimonials
In Short: With your separate consent, we may photograph, record, or interview you for use in marketing materials.
Some of our work with customers includes producing case studies or video testimonials. If you agree to participate, we may photograph you, or record audio or video of you, and use that content, along with your name, title, and company, in case studies, testimonials, or other marketing materials. We will always ask for your specific consent (typically a signed release) before recording for this purpose and before publishing the resulting content, and will tell you at that time how it will be used.
Information we receive about investors, partners, and vendors from other sources
In Short: Separately from the information described above about you, we maintain directories of investors, firm partners, and vendors that include business contact information we did not collect from those individuals directly.
As part of the Services, we maintain an Investor Directory and a Partner (Vendor) Directory, which we use to help identify potential investors, business partners, and vendors relevant to a customer's engagement. These directories include business contact information (such as names, firm or fund affiliation, titles, and professional contact details) about investors, firm partners, and vendor representatives. We compile this information from licensed third-party data sets, publicly available sources (such as firm websites and public filings), and, where applicable, enrichments contributed by Bright Growth customers through the platform. This is distinct from, and unrelated to, the information you provide us about your own business; it does not include your organization's confidential engagement data, and your organization's information is not added to these directories or made available to other customers. If you are an investor, partner, or vendor representative included in one of these directories and would like to review, correct, or be removed from it, contact privacy@brightgrowth.io.
We also draw on industry benchmark data (aggregate statistics such as budget and headcount ranges, channel-mix percentiles, and similar market data) from third-party research and industry sources to inform our audits and recommendations. This benchmark data is aggregate market data, not personal information about any identifiable individual.
Information a third-party specialist consultant contributes to your engagement. If your engagement involves a third-party specialist consultant as described in Section 4, that consultant's findings and recommendations become part of your organization's workspace and may reference your own personnel by name (for example, notes from an interview with a member of your team). We process that content the same way we process any other document in your workspace, solely to deliver your engagement. If your organization's administrator gives a consultant access to your workspace, we also process that consultant's own account details (name and work email address) as a platform user, and we record when their access is revoked.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To facilitate account creation and authentication, and otherwise manage user accounts. We may process your information so you can create and log in to your account on app.brightgrowth.io, as well as keep your account in working order.
• To deliver and improve the Services you request. We process the information and documents you provide us to prepare your marketing audit, plan, and execution deliverables. This may involve Bright Growth personnel and our service providers using AI-assisted tools, including large language models, to help analyze what you've shared, research your organization's and named competitors' public web presence, and draft your deliverables. See Section 4 for how we handle that.
• To produce and deliver a complimentary Marketing Snapshot you request. We process the company website address, competitor names, and work email address you submit in order to verify your request, research your company's publicly available marketing, generate the automated assessment described in Section 1, create your private workspace, and notify you when each part is ready. We use your work email address only to verify the request, deliver the Snapshot, and respond to you about it; we do not add Snapshot requesters to any marketing list.
• To run an Alignment Survey for one of our customers. Where a customer's engagement includes an Alignment Survey, we process the recipient details that customer gives us in order to send the invitation and reminders, collect and score the responses, and present the results in that customer's workspace. We do this on that customer's instruction and for their engagement only; we do not use survey responses for any other purpose, share them with any other customer, or use them to train AI models.
• To run a Team Onboarding Survey for one of our customers. Where a fractional-CMO engagement includes a Team Onboarding Survey, we process the recipient details that customer gives us in order to send the invitation and reminders, collect the responses, and present them, attributed, to that customer's engagement leader. We do this on that customer's instruction and for their engagement only; we do not use survey responses for any other purpose, share them with any other customer, or use them to train AI models.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information, including account confirmations, password resets, and invitations.
• To respond to user inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To protect and maintain our Services. We may process your information as part of our efforts to keep our Services safe, secure, and working, including fraud and abuse prevention (such as rate-limiting the public Snapshot-request form) and diagnosing software errors on app.brightgrowth.io.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To comply with our legal obligations. We may process your information to comply with applicable law or respond to valid legal process.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing app.brightgrowth.io and delivering your engagement, or to take steps at your request prior to entering into such a contract.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, such as operating, securing, and improving our Services, and communicating with you about your engagement, and where those interests are not overridden by your data protection interests.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, for example for investigations and fraud detection and prevention, for business transactions provided certain conditions are met, or where disclosure is required to comply with a subpoena, warrant, or court order.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Third-Party Specialist Consultants: Audit Phase. Some engagements call for functional experts outside our core team, for example independent consultants with deep expertise in a specific discipline such as demand generation, sales enablement, or category strategy. These consultants contract directly with you. Where a consultant participates in your engagement, we may share documents and information relevant to their portion of the work with them, and the consultant may work with you directly (for example, through interviews or additional document requests) to conduct a deeper-level audit. Your organization's administrator may also give the consultant access to your workspace on app.brightgrowth.io: that access is read-only, is limited to the document categories and assessment areas your administrator selects, expires automatically after at most ninety days unless renewed, and can be revoked by your administrator at any time; Bright Growth does not select, approve, or supervise the consultants you invite, and a consultant you give access to acts as your organization's authorized user. The consultant's findings and recommendations are then added to your organization's workspace, where they become part of your engagement records. Because your relationship with the consultant is direct, the consultant's confidentiality and data-handling obligations are established by your agreement with them; Bright Growth makes no representations or warranties about a consultant's confidentiality or data practices.
• Third-Party Specialist Consultants: Plan and Execution Phase. If you agree to move forward with plan or execution services from that consultant, what happens next depends on how the work is delivered: if it continues to flow through app.brightgrowth.io, this notice keeps applying to that information. If the consultant delivers those services to you directly, outside app.brightgrowth.io (for example, by email or their own tools), that portion of the engagement is between you and the consultant, and their handling of your information is governed by their own privacy practices, not this notice.
• Investor, Partner, and Vendor Recommendations. As part of delivering your engagement, we may share relevant entries from our Investor Directory or Partner (Vendor) Directory with you, for example, a shortlist of investors or vendors that match your needs. This directory information originates from the third-party sources described in Section 1, not from you, and sharing it with you as part of your deliverables does not involve any of your own information.
• Vendors, Consultants, and Other Service Providers. We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us and require access to your information to do that work. Each is bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. The categories of service providers we use, and what they do, are:
Squarespace: hosts and serves brightgrowth.io. Data involved: site visit data, cookies.
Google (Tag Manager / Analytics): website analytics. Data involved: device information and approximate (IP-based) geolocation, aggregated in the reports we view.
Supabase: authentication, database, and private file storage for app.brightgrowth.io workspaces. Data involved: account data, uploaded documents.
Resend: delivers account and service emails (confirmations, password resets, invitations), Alignment Survey and Team Onboarding Survey invitations and reminders to the recipients a customer names, and internal notifications to Bright Growth when a new account is created. Data involved: email address, recipient name (for survey invitations), and, for signup notifications, the time of signup.
Netlify: hosts and serves app.brightgrowth.io, and checks that each request carries a valid sign-in session before any page or data is served. Data involved: site/app traffic data, session token (verified, not stored).
Sentry (Functional Software, Inc.): error monitoring for signed-in pages of app.brightgrowth.io. Data involved: when a page encounters a software error, the technical error details, the page address, browser and device information, and, as with any web request, your IP address. We do not configure Sentry to attach your name, email address, or account identifier, and we have set Sentry not to store your IP address with the report. Not loaded on the public sign-in, Snapshot-request, or survey pages.
jsDelivr, Google Fonts, and Sentry's script CDN (content delivery networks): serve open-source script libraries and fonts for app.brightgrowth.io, including its public pages. Data involved: IP address and standard technical request data.
GitHub (a Microsoft company): private source-code repository where Bright Growth stores its engagement working files, including audit, plan, and execution deliverables prepared for customers outside the platform. Data involved: engagement documents and deliverables, which may incidentally name a customer's personnel.
Anthropic (and other large language model providers we may use from time to time): AI-assisted analysis and drafting via a commercial Anthropic (Claude) account, used by Bright Growth on or off the platform to augment our Services, including audit, plan, and execution deliverables (including documents the platform generates for an engagement, which display whether a person has reviewed them yet); automated research of your organization's and named competitors' public web presence for briefs, diagnostics, and ongoing monitoring; the automated Marketing Snapshot described in Section 1; and, where your organization enables it, the conversation-intelligence analysis described in Section 1. Data involved: content of documents and information you provide or that your organization connects, where applicable to your engagement; documents you upload to the platform may be transmitted to the provider for analysis; and, for a Marketing Snapshot, the company and competitor website addresses you submit. Automated research involves web searches for publicly available information about the company being assessed; those searches are run through the AI provider's own web-search tool and the search providers named on its published subprocessor list, and disclose only the search terms, never your email address or any other information about you. Where a customer organization chooses to run the conversation analysis in its own AI provider account, as described in Section 1, that account is that organization's own relationship with its provider, including where it is the same provider we use, and the communications processed inside it do not reach us, our account, or this subprocessor relationship.
We do not sell your personal information. Consistent with the standard commercial terms of the AI providers listed above, the content you submit is not used to train their models or products absent your separate opt-in.
• Case Studies and Testimonials. With your specific consent as described in Section 1, we may publish content from a case study or testimonial, which may include your name, title, company, photo, or video, on brightgrowth.ioor in other marketing materials. We only do this with your consent, and you can ask us to take down published content at any time by emailing privacy@brightgrowth.io.
• Cross-Border Transfers. We are based in the United States, and the service providers above may process information in the United States or other countries. Where required by applicable law (such as the GDPR), we take steps to ensure any such transfer is subject to appropriate safeguards, such as standard contractual clauses or an equivalent mechanism.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We use cookies and similar technologies (including browser local storage) in two ways:
• Essential. Cookies and local storage that keep you signed in to app.brightgrowth.io and maintain the security of your session. The platform does not work without these.
• Analytics. Cookies set by Google Analytics (via Google Tag Manager) on brightgrowth.io, which help us understand how visitors use our marketing site, as described in Section 1. These are not used on app.brightgrowth.io.
We do not use advertising or cross-site tracking cookies anywhere on our Services. You can refuse or delete cookies through your browser settings; refusing essential cookies will prevent you from signing in to app.brightgrowth.io, while refusing analytics cookies does not affect your use of either site.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
For app.brightgrowth.io specifically, we retain your account and workspace data for as long as your engagement with Bright Growth is active. Aggregate metrics and conversation-derived findings (including their supporting excerpts) created through connected sources are part of your workspace data and are retained and deleted on the same basis; a supporting excerpt is never retained longer than the finding it supports. If you'd like your data deleted after an engagement ends, email privacy@brightgrowth.io, and we will remove it, subject to any data we are required to retain for legal or accounting reasons.
If you requested a complimentary Marketing Snapshot and did not become a customer, we keep your Snapshot, its workspace, and the email address you provided for up to twenty-four (24) months, so the Snapshot remains available to you. We delete them sooner on request: email privacy@brightgrowth.io. If you never confirm your email address, we delete the request (including the preview scan) within thirty (30) days, and no Snapshot is ever generated. The network-address log kept to rate-limit the request form is retained for the same twenty-four-month period.
Error reports from app.brightgrowth.io are retained by our error-monitoring provider for up to thirty (30) days.
If you responded to an Alignment Survey, we retain your recipient details and responses for three (3) years from the date of the survey so the organization that sent it can see how alignment changes over time, after which we delete them. We delete them sooner if that organization asks us to, or if you ask us to, by emailing privacy@brightgrowth.io.
If you responded to a Team Onboarding Survey, we keep your recipient details and your responses for two (2) years from the date of that survey by default, unless the organization that sent it instructs us to keep them for a shorter or longer period. When that organization's engagement ends, it chooses to have your responses kept as they are, to have your name and other identifying details removed while the rating answers are kept in aggregate, or to have your responses deleted entirely; we act on that choice, and delete them sooner if that organization asks us to or if you ask us to: email privacy@brightgrowth.io. Neither retention period is enforced by an automated deletion process; each is a commitment we act on.
We retain published case study and testimonial content, and the consent records behind it, for as long as we continue to use that content in our marketing, and will remove it on request as described in Section 4.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including: encrypting data in transit (HTTPS/TLS) across our websites and application; enforcing database-level access rules on every table of app.brightgrowth.io so that each customer organization's workspace is isolated from every other customer's, and only members of your organization and authorized Bright Growth personnel can access it; verifying every request's sign-in session at the network edge before any page or data is served; running Bright Growth's own staff access through individually named accounts rather than shared logins; and limiting internal access to personal information to what's needed to operate the Services and deliver your engagement.
Despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. If you have questions about our current security practices or certifications, contact privacy@brightgrowth.io.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@brightgrowth.io.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. If your request relates to app.brightgrowth.io, you can also reach us directly at privacy@brightgrowth.io, including to request an export of documents you've uploaded.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. We do not serve interest-based advertising on our Services.
If you have questions or comments about your privacy rights, you may email us at privacy@brightgrowth.io.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category A: Identifiers. Examples: contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. Collected: YES.
Category B: Personal information categories listed in the California Customer Records statute. Examples: name and contact information you provide when you create an account, express interest in our Services, or contact us. Collected: YES.
Category C: Protected classification characteristics under California or federal law. Examples: gender and date of birth. Collected: NO.
Category D: Commercial information. Examples: transaction information, purchase history, financial details, and payment information. Collected: NO.
Category E: Biometric information. Examples: fingerprints and voiceprints. Collected: NO.
Category F: Internet or other similar network activity. Examples: browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. Collected: YES.
Category G: Geolocation data. Examples: approximate, IP-based device location, collected via website analytics. Collected: YES.
Category H: Audio, electronic, visual, thermal, olfactory, or similar information. Examples: with your consent, photos, audio, or video for case studies and testimonials. Collected: YES.
Category I: Professional or employment-related information. Examples: business contact details in order to provide you our Services at a business level, or job title, work history, and professional qualifications if you apply for a job with us. Collected: YES.
Category J: Education information. Examples: student records and directory information. Collected: NO.
Category K: Inferences drawn from other personal information. Examples: inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics. Collected: NO.
Category L: Sensitive personal information.Collected: NO.
We will use and retain the collected personal information as needed to provide the Services or for:
• Category A - As long as the user has an account with us
• Category B - As long as the user has an account with us, or as long as needed to respond to your inquiry
• Category F - As long as necessary for security, troubleshooting, and analytics purposes described in Section 1
• Category G - As long as necessary for the analytics purposes described in Section 1, in aggregated/reported form
• Category H - As long as we use the content in our marketing (case studies and testimonials, with your consent)
• Category I - As long as the user has an account with us, or as long as needed to evaluate a job application
• Categories A, B, and I, where collected as Alignment Survey recipient details and responses - three years from the date of the survey, as described in Section 6
• Categories A, B, and I, which are collected as Team Onboarding Survey recipient details and responses - two years from the date of the survey by default, or the period the sending organization instructs, as described in Section 6
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests;
• Documents and business information you upload to app.brightgrowth.io, information processed through business systems or communications sources your organization connects, and answers you give in an Alignment Survey, for your or that customer's engagement, all of which we treat as confidential and process only to deliver that engagement; and
• Facilitation in the delivery of our Services and responding to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by visiting brightgrowth.io/contact, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We use your personal information only for the business purposes described in Section 2. This is not considered to be "selling" of your personal information.
CMO Success, LLC has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. CMO Success, LLC will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data: Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed: Request to know
Depending on the circumstances, you have a right to know:
• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by visiting brightgrowth.io/contact, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with CMO Success, LLC and our Services. To find out more, please visit the following links:
• Personal data we collect
• How we use your personal data
• When and with whom we share your personal data
Your rights with respect to your personal data
• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
CMO Success, LLC has not sold any personal data to third parties for business or commercial purposes. CMO Success, LLC will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at privacy@brightgrowth.io, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at privacy@brightgrowth.io. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint (https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint).
Residents of other US states. If you reside in another US state with a comprehensive consumer privacy law (such as Colorado, Connecticut, or Utah), you may have similar rights to access, correct, delete, and obtain a copy of your personal data. You can exercise those rights by emailing privacy@brightgrowth.io, and we will honor them in accordance with the law that applies to you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at privacy@brightgrowth.io (or, for general inquiries, info@brightgrowth.io) or by post to:
CMO Success, LLC
946 Teresita BLVD
San Francisco, CA 94127
United States
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, email privacy@brightgrowth.io.