(Last Updated August 6th, 2019)
For the purpose of processing personal data, Brave may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Brave. In such cases, Brave shall take necessary measures to ensure that such data is processed in accordance with the instructions of Brave and applicable legislation. Brave shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, Brave shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
Information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
Information you provide to us
We collect information about you when you input it into the Services, website forms or otherwise provide it directly to us.
Account and Profile Information
We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make registrations through the website. For example, you provide your contact information when you make contact through the website. You also have the option of adding a job title, and other details to your information to be displayed in our demo registration and contact form submission.
Content you provide through our products
We collect and store content that you post, send, receive and share through our website and service demo/s. This content includes any information about you that you may choose to include. Examples of content we collect, and store include: the summary and description added to a support issues and the messages you send via a contact form. Content also includes the files and links you upload to our Products or Services.
Content you provide through our websites
We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels
Information we collect automatically when you use the website
We collect information about you when you use our website, including:
Your use of the website
We keep track of certain information about you when you visit and interact with our website. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the website; frequently used search terms etc.
Device and Connection Information
We collect information about your computer, phone, tablet, or other devices you use to access the website. This device information includes your connection type, browser type, phone type etc. We also collect information through your device about URLs of referring/exit pages, device identifiers, and crash data where required. We use your IP address and/or country preference in order to approximate your location to provide you with a better website experience. How much of this information we collect depends on the type and settings of the device you use to access the website.
Cookies and Other Tracking Technologies
Cookies and other technologies
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen will tell you how to do this. We also give you information about disabling cookies. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Platform and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use. To read more about our cookies policy please visit our cookies policy page.
How we use your information
You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed on our Cookies Policy page.
We use information held about you in the following ways
Information you give to us:
We will use this information to: Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- administering your account with us;
- notifying you about changes to our service.
Provide you with information about our products we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.
Ensure in our legitimate interests that:
- content from our Platforms is presented in the most effective manner for you and for your computer.
- we provide you with the information, products and services that you request from us.
Information we collect about you from your use of our Platforms
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our Platforms safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve our Platforms to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service, when you choose to do so.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products.
You can object to further marketing at any time by checking and updating your contact details within your account or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you.
We may give your information to
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
Our selected third parties may include
Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual).
Business partners who jointly with us provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.
Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.
We will disclose your personal information to third parties:
If Brave or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Brave, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
The storing of your information
Information storage and security
We use industry standard technical and organisational measures to secure the information we store.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If you use our website or Brave Products, responsibility for securing storage and access to the information you put into these platforms’ rests with you and not Brave. We strongly recommend that server or data center users configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage points used.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the account and its services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Platforms. Where we retain information for Platform improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.
Information you share on the Services
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Platform. For example, we continue to display messages you sent to the users that received them and continue to display content you provided.
If the Platforms are made available to you through an organisation (e.g., your employer), we retain your information as long as required by the administrator of your account if this is applicable.
If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Brave account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Platform and using settings available within the Service or your account. Where the Platforms are administered for you by an administrator, you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information
Our Platforms and related documentation give you the ability to access and update certain information about you from within the Service. You can update some information within your Platform settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate your account
If you no longer wish to use our Platform, you or your administrator may be able to deactivate your account. If you can deactivate your own account, that setting is available to you in your account settings. Otherwise, please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact Brave support. For more information on how to delete your information, contact our support team.
Request that we stop using your information
In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe an account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
Opt out of communications
You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your account settings, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.
Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Platform. You can opt out of some notification messages by contacting our support team.
Notice to End Users
Many of our products are intended for use by organisations. Where the Platforms are made available to you through an organisation (e.g. your employer), that organisation is the administrator of the Service and is responsible for the accounts and/or sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Service is subject to that organisation’s policies. We are not responsible for the privacy or security practices of an administrator’s organisation, which may be different than this policy.
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Even if the Services are not currently administered to you by an organisation, if you use an email address provided by an organisation (such as your work email address) to access the Platform, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Service at a later date. You will be notified if this happens.
If you do not want an administrator to be able to assert control over your account or use of the Platform, use your personal email address to register for or access the Service. Once an administrator asserts control over your account or use of the Platform, you will no longer be able to change the email address associated with your account without administrator approval.
Please contact your organisation or refer to your administrator’s organisational policies for more information.
Our policy towards children
The Platform is not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for up to six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section);
- to request that your provided personal data be moved to a third party.
Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us firstname.lastname@example.org. You can also change your marketing preferences at any time as described in ‘Our promotional updates and communications’ section.
You can also exercise the rights listed above at any time by contacting us at email@example.com
If you have any queries regarding our data collection and protection practices, or your rights, please do not hesitate to contact our corporate office at firstname.lastname@example.org