1. Purpose of This Privacy Policy

This Website Privacy Policy describes what personal data is collected when you visit our website, www.brightscope.io (our “Website”), and how Folyo GmbH, Edelhofgasse 21, 1180 Vienna, Austria (“Brightscope”, “we”, “us”, or “our”), as the data controller, processes such data. This Privacy Policy is addressed to every visitor of our Website (“data subject” or “you”). We process your personal data in accordance with the EU General Data Protection Regulation (“GDPR”) and applicable national data protection laws. Unless otherwise defined in this Privacy Policy, terms used herein shall have the same meaning as under the GDPR.

2. What Personal Data We Collect and How We Use It

When you use our Website, we may process personal data that you voluntarily provide to us (e.g., through our contact forms). However, you may also visit our Website without actively submitting information about yourself. In such cases, we only collect certain information transmitted by your browser to our web server (i.e., log files) and information collected through cookies or similar technologies.

The following sections explain how we collect personal data and the lawful purposes for which we may use it.

Personal Data You Actively Provide
When you communicate with us through our Website, we process the personal data you voluntarily provide.

Contact Form and Chatbox
If you choose to contact us through the contact form or chatbox available on our Website, we process the personal data you provide (e.g., name, email address, postal address) in order to answer your questions, fulfill your request, or otherwise communicate with you. Legal basis: Article 6(1)(b) GDPR – performance of pre-contractual or contractual obligations.

Job Applications
If you apply for a position advertised on our Website, we process the personal data you provide (e.g., name, contact details, cover letter, CV, photograph, certificates, references, etc.) for the purpose of evaluating your application and considering you during the recruitment process. Legal basis: Article 6(1)(b) GDPR – performance of pre-contractual obligations.

Newsletter
If you subscribe to our newsletter, we process the personal data you provide (e.g., name, email address, product preferences) to send you the requested newsletter containing personalized information about our products and available promotions. You may unsubscribe at any time by clicking the unsubscribe link included in each newsletter or by contacting us via email. Legal basis: Article 6(1)(a) GDPR – consent.

Demo Requests
If you submit a demo request via our Website, we process the personal data you provide (e.g., name, email address, job title, company name, telephone number) to arrange a demonstration of our products. One of our representatives will contact you to schedule a suitable appointment. Legal basis: Article 6(1)(b) GDPR – performance of pre-contractual obligations.

Downloading Resources
If you provide personal data (e.g., name, email address, company name) when downloading one or more of our resources, we may process this information:

– To send you our newsletter and product-related communications (Article 6(1)(a) GDPR – consent);
– To arrange a product demonstration (Article 6(1)(b) GDPR – performance of pre-contractual obligations);
– For direct marketing and promotional purposes (Article 6(1)(f) GDPR – legitimate interest of Folyo GmbH).

Some information fields may be mandatory. If you do not provide the required information, we may be unable to process your request or provide the requested services.

Log Files
You may visit our Website without actively providing information. In such cases, our servers automatically collect and store information transmitted by your browser.

Log files may include:
– Date and time of access
– Browser type, version, and settings
– Operating system
– Internet service provider
– Requested pages and files
– Referring website
– IP address

We process these log files to ensure the functionality, stability, and security of our Website. They may also be used for forensic investigations in the event of security incidents and for generating usage statistics. For statistical purposes, IP addresses are only used in anonymized form. Legal basis: Article 6(1)(f) GDPR – legitimate interest in maintaining Website functionality, stability, and security.

Cookies
Our Website uses cookies and similar technologies. Cookies are small text files stored on your device during your visit and used to store certain information.

We use two categories of cookies:

Necessary Cookies
Necessary cookies are required for the proper functioning of our Website. These cookies may be used without your consent. Legal basis: Article 6(1)(f) GDPR – legitimate interest.

Optional Cookies
Optional cookies help us improve our Website, analyze user behavior, personalize content, and conduct marketing activities. These may include third-party cookies. Optional cookies are only used with your consent, which can be provided through our cookie banner. Consent can be withdrawn at any time with future effect. Legal basis: Article 6(1)(a) GDPR – consent.

Google Analytics
If you consent to the use of cookies (including those from U.S.-based partners), this Website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies to analyze your use of the Website. Information generated by these cookies, including your IP address and visited URLs, may be transferred to and stored on Google servers in the United States. This Website uses IP anonymization, meaning your IP address is shortened by Google before processing. Google uses this information on our behalf to evaluate Website usage, compile reports, and provide related services. This Website also uses Google Analytics User-ID functionality to track interactions across multiple devices. The User-ID is anonymized and encrypted. You may withdraw your consent at any time or prevent the use of cookies through your browser settings. You may also install Google's opt-out browser add-on: https://tools.google.com/dlpage/gaoptout

For more information, please visit: https://policies.google.com/technologies/partner-sites

3. Recipients of Your Personal Data

For the purposes described above, we may disclose your personal data to:

– Employees who require access to provide services;
– IT service providers responsible for hosting, maintenance, and security;
– Advertising and analytics partners (e.g., Google LLC);
– Customer relationship management providers, including HubSpot Inc.;
– Social media partners such as LinkedIn Ireland Unlimited Company;
– Public authorities, courts, regulators, legal advisors, and forensic experts where legally required.

Some recipients may be located outside the European Union or European Economic Area. Where required, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, or obtain your explicit consent before transferring personal data internationally.

4. Data Retention

Log files are generally retained for three months. Beyond this period, they are only retained where necessary for investigating irregularities or security incidents. Personal data is generally stored only for as long as necessary to fulfill the purposes for which it was collected. We may also retain data to comply with legal retention obligations or to establish, exercise, or defend legal claims. Once there is no longer a legitimate reason to retain personal data, it will either be deleted or anonymized.

5. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or business developments. When we make changes, we will take appropriate steps to inform you. The date of the latest revision can be found at the beginning of this Privacy Policy.

6. Links to Third-Party Websites

Our Website may contain links to third-party websites. We have no control over the content or privacy practices of these websites. Please review their privacy policies before providing any personal information.

7. Contact Information

If you have any questions or concerns regarding the processing of your personal data, please contact us at: welcome@brightscope.io

Version: January 2026