Privacy Policy

This Privacy Policy explains how Bracket handles Personal Data. “Personal Data” is defined as information submitted to and/or collected by Bracket via our company website. Such information can be collected when an individual submits his or her name and/or address. Bracket can also collect information about visits to the Bracket website without an individual actively submitting information through various automated digital means, such as cookies and internet tags. Although the information collected by such automated digital means does not directly identify specific individuals, internet web browsers automatically transmit information to the Bracket website regarding the software a user’s computer is operating, such as IP address and browser version. Information collected by these technologies cannot be used to identify individuals without additional identifiable information.

In order to perform collection and/or transfer of Personal Data, Bracket unconditionally relies on our clients to obtain from each data subject their express, freely given, specific, informed and unambiguous written consent to the collection and/or transfer services.

Any identifiable information individual users provide will be used only by Bracket employees for the purposes of fulfilling a specific customer request. Bracket will not share this information with any third party without the consent of an individual user. Bracket will not disclose any Personal Data it gathers from an individual user, except as set forth in this Privacy Policy or as specifically agreed to by such individual user. Bracket may release Personal Data to third parties without user consent: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat, to protect property or defend or assert legal rights. In the event that Bracket is legally compelled to disclose Personal Data to a third party, Bracket will attempt to notify the involved user unless doing so would violate the law or court order. In addition, bracket may disclose Personal Data as further described below.

Bracket operations and maintenance contractors sometimes have limited access to Personal Data in the course of providing products or services to Bracket. Access to an individual user’s Personal Data by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for Bracket. Bracket requires its operations and maintenance contractors to: (1) protect the privacy of any individual user’s Personal Data consistent with this Privacy Policy, and (2) not use or disclose Personal Data for any purpose other than providing Bracket with products and services, as required by law.

An individual may opt out of any future contacts with us at any time. You can do the following at any time by contacting us via the email address or phone number given on our website (
• See what data we have about you, if any
• Change/correct any data we have about you
• Have us delete any data we have about you
• Express any concern you have about our use of your data

Please note that, in the event you contact us for one of the above purposes, Bracket may need to contact the sponsor of the study in which you are participating, if applicable.

Bracket recognizes potential liability in cases of onward transfer to third parties. Bracket will not transfer any Personal Data to a third-party without first ensuring that the third-party adheres to the Privacy Shield principles. Bracket does not transfer a client’s Personal Data to unrelated third parties, unless lawfully directed by that client, or in certain limited or exceptional circumstances in accordance with the EU-U.S. Privacy Shield Framework. For example, such circumstances would include disclosures of a client’s Personal Data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety.

In the event that Bracket is requested to transfer a client’s Personal Data to an unrelated third party, Bracket will ensure that such party is either subject to the EU-U.S. Privacy Shield Agreement, or subject to similar laws providing an adequate and equivalent level of privacy protection. If neither condition is applicable to the unrelated third party, Bracket will enter into a written agreement with the third party requiring them to provide protections consistent with the EU-U.S. Privacy Shield Framework and Bracket’s Privacy Shield Policy. Should Bracket learn that an unrelated third party which received Personal Data from Bracket is using or disclosing Personal Data in a manner contrary to this Policy, Bracket will take reasonable steps to prevent or stop the use or disclosure.

Bracket complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union to the United States. Bracket has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

Bracket is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Bracket also assures compliance with this EU-U.S. Privacy Policy and the EU-U.S. Privacy Shield Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of Personal Data in violation of this Privacy Policy.

In compliance with the Privacy Shield Principles, Bracket commits to resolve complaints about our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding our Private Shield policy should first contact Bracket at:

Jason Cabrera
International Liaison
American Arbitration Association
International Centre for Dispute Resolution
120 Broadway, 21st Floor
New York, NY 10271

Bracket has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association/International Centre for Dispute Resolution, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit for more information or to file a complaint. The services of the American Arbitration Association/International Centre for Dispute Resolution are provided at no cost to you.

This Privacy Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this EU-U.S. Privacy Policy and to note recent updates. Neither this EU-U.S. Privacy Policy nor updates to it will affect or modify any contracts we have with our clients.