Brave People Ltd. Privacy Policy (Jigsaw Puzzle – AI Puzzles)

Privacy Policy

General

Brave People Ltd. (“Brave”) takes its users’ privacy issues very seriously and is committed to protecting their Personal Date (as such term is defined below) in compliance with all applicable laws and regulations, including the specific laws mentioned in this Privacy Policy, as they may be amended from time to time.

By accessing or using any of Brave’s services or products, including the “Jigsaw Puzzle – AI Puzzles” application (the “App”) or any part thereof, you are deemed to have accepted this Privacy Policy and agree to its terms, including without limitations, to the collection and/or receipt, disclosure, storage and use of your Personal Data as well as other data as outlined in this Privacy Policy.

In this Privacy Policy, “Personal Data” means any information that is related to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirect, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In this Privacy Policy, the term Personal Data shall include all of the above information even if referred to otherwise under any privacy laws applicable to your jurisdiction (such as “Personal Information”).

“Sensitive Personal Data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic data, biometric data processed solely to identify a human being; health-related data; or data concerning a person’s sex life or sexual orientation.

If you do not agree to any of the provisions of this Privacy Policy, please stop using the App immediately.

 

Personal Data Shared by You With Brave

Brave may collect Personal Data from you when you voluntarily share it with Brave through using any of our services including the App. This may include the following Personal Data (as an example only):

User Content – When you upload or submit content to any of Brave’s websites or the App (“User Content”), Brave may use and publish your User Content to provide you and third parties with the Brave websites and App, to keep records of your communications or uploaded User Content on its services, to tailor content to your preferences, to defend against legal claims and for other legitimate uses.

Public Data – Brave may use any available public data to provide you with the services requested, with more relevant content, to tailor content to your preferences, to keep records of communications, to defend against legal claims and for other legitimate uses.

Communication – Brave may use your contact data and contacts information and other information to authenticate your account, to communicate with you, to connect you with friends or other users, to invite your friends to join Brave’s services including the App (at your request), to respond to communications, to keep records of our communication, or to pursue or defend against legal claims and for other legitimate uses. In addition, Brave may store and process your private communications and data related to them to scan for malicious content, to detect spam or prohibited images and other content, to identify violations of this Privacy Policy and Brave’s terms of use, to respond to legal process or law enforcement inquiries or for other legitimate uses.

Account Data – In order to open an account with Brave, you must provide Brave with some personal data so that Brave can provide you with the services that you have requested. This may include your username, password, email address, phone number, age, gender, contacts (such as when you invite your contacts from third party applications and/or social platforms) and your contact list.

 

Additional Personal Data Brave Receives From You

Brave may also collect Personal Data from you automatically when you use the Brave website or mobile applications. This may include the following Personal Data:

Location Data – Brave may collect data about your location by collecting and processing your IP address and device settings. Brave may use this data to provide location-based services, tailor our services to your geographic location, respond to law enforcement requests, or to provide you with content that is relevant to your geographic location.

Technical and Usage Data – Brave may collect technical data about your use of the Brave website or mobile applications, such as your IP address, your device IDs, mobile application’s bundle ID, the ad or creative ID, pages visited, referring web page, mobile carrier, search terms, cookie data, operating system, geolocation, and time zone, recordings or logs of user screens within the App or of the manner in which you interact with the App. Brave may use this data to better tailor its services or to understand how it can improve its graphical user interfaces, which may include our remote configuration of the user interface of our mobile application to improve its functionality. In addition, Brave may use this data to analyze your use of the App or other services, to detect fraud, to administer and secure the App, to manage, improve and support the App and the services and for other legitimate uses.

Marketing Data – Brave may collect your IP address, your application bundle ID, your advertising or creative ID, your Brave user ID, your device IDs, your geographical location, your phone numbers, pages visited, referring web page, mobile phone model, search terms, cookie data, Google Advertising IDs, and Apple Advertising IDs. Brave may use your data to provide advertisements to you, to determine the relevance of advertisements, to measure the effectiveness of advertisements, to detect fraud, and to help make those advertisements more relevant to your preferences. When providing you with advertisements, Brave may transmit your personal data off of your device to third party advertisers or other services providers or suppliers or business partners of Brave so that they may serve relevant advertisements to you.

 

Cookies

Brave may also collect Personal Data from you through the use of cookies and other technologies used by Brave from time to time. This helps Brave understand how you use the App and Brave’s services, serve advertisements, and to understand any patterns that may be associated with your use of the above. This aids Brave in developing or improving our services in response to your needs or wants and in providing you with relevant offers from our advertisers.

Brave may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the App or Brave services and are automatically deleted when you resume such use. Persistent cookies are stored as a file on your computer or mobile device that remain on your computer or mobile device even after you resume your use. Brave may use persistent cookies when we utilize Google Analytics or other analytics providers, which are intended to track the origin and behavior of traffic to the Brave services and App. Brave may also, from time to time, receive Personal Data from third parties including analytics providers or advertising networks such as Google, Facebook, or Apple.

 

Marketing Communications

Brave may send you marketing communications if you have asked Brave for information concerning our products and services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask Brave to stop sending you marketing messages at any time by following the opt-out link in any marketing message sent to you by Brave.

In the event Brave sent you marketing text messages at your request, you may opt-out of receiving marketing text messages by texting STOP in response to any text message received from Brave.

 

Disclosure of Personal Data

Brave only shares or sells your Personal Data in limited circumstances.

Brave may share, sell, or disclose your Personal Data with your consent or at your direction.

We may also share or sell your Personal Data with certain third parties to aid Brave in operating the Brave website or mobile applications. For example, Brave may share your Personal Data with third parties, such as analytics providers, to utilize their software tools and measure the effectiveness of our advertisements. Brave may also share or sell your Personal Data, such as device IDs, with third party advertisers to help them determine whether they should serve an ad to you. The Personal Data that we share with or sell to these third parties does not include your email address, name, phone number, or username, but it may include your geographical location.

Brave may also share your Personal Data with our accountants, auditors, insurers, or attorneys where doing so is necessary to protect the interests of Brave, its employees, services providers and suppliers or contractors, or to comply with any law or regulation.

Brave may also share your Personal Data with government or law enforcement agencies when we are required to report our data processing activities, upon receipt of an exigent circumstances request, upon receipt of a duly authorized subpoena or court order, or where doing so is necessary to protect our users, our employees, our contractors, third parties, or property.

Finally, Brave may share your Personal Data to a third party if we sell, transfer, or merge any part of our business or assets. In the event that we share your personal data in the sale, transfer, or merger of any part of our business or assets, this Privacy Policy will continue to apply to your Personal Data when transferred to the new entity.

 

Third Party Links and Websites

Brave’s services may include links to third party websites and applications. Brave does not endorse or recommend such third party websites (or any service or product offered by them) and does not provide any representations with respect to such third party websites’ activity including any of the services or products sold or referred to by them.

By clicking on third party links, you may allow third parties to collect or share data about you in accordance with such websites’ own privacy policies, which you are encourage to review from time to time in order to ensure you are familiar with the most updated version.

You shall not have any claims against Brave or any of its representatives in connection with any damages incurred by you as a result of your information being used by any third party. In addition, Brave is not responsible for any business engagements between you and any such third parties.

 

Transfer of Personal Data Internationally

When you use the App, your Personal Data may be transferred between one county to another, including without limitations: (i) from the United States to other countries or from other countries into the United States, and/or (ii) from the EU to other countries or from other countries into the EU. Brave may store Personal Data on servers located in the EU, in the United States and/or in other countries and it may change the location of our servers (or severs or third-parties we are making use of, at its sole discretion) time to time.

When Brave transfers your Personal Data from one country to another country, it will take commercially reasonable steps to ensure that your Personal Data is treated in the most secured and lawful way and in the manner and in accordance with the principles that are described in this Privacy Policy as well as prevailing industry standards.

Please note that Laws vary from one jurisdiction to another, and so the privacy and data protection laws applicable to the places where your Personal Data is to be transferred to or to be stored, used or processed in, may be different from similar Laws in the place where you are resident or in which your Personal Data is currently located.

If you are a resident in a jurisdiction, where transfer of your Personal Data to another jurisdiction requires your consent, then you hereby provide Brave your express and unambiguous consent to such transfer in order for Brave to be able to provide you with its services.

Last, certain aspect of privacy and data protection Laws might be subject to interpretation, including with respect to the sufficient protection which should be applied when transferring your Personal Data from the EU to other countries. The exact manner in which Brave should apply security measures such as various standard contractual clauses, available protection shields, as well as other legal and contractual protection is being done to Brave’s best understanding of the existing legal framework on these issues.

 

Use of the App and Services by Minors

Our services are not directed to, or open to, children under the age of 13. In using our services, you warrant that you are over the age of thirteen (13). If you are younger than 13, please do not use the Brave website or mobile applications and please do not provide personal data to Brave.

 

Management, Protection, and Retention of Your Personal Data

 

Citizens of Brazil

If you have registered an account with Brave and are a Brazilian citizen, we provide you with account settings that let you modify, correct, or delete the Personal Data that you have provided to Brave that is associated with your account. Whether you are located outside the Brazilian territory or elsewhere, to stop our collection and use of your personal data, you need only to delete your account.

If you have not registered an account with Brave, we only collect technical data from you. To stop our collection and use of your technical data, you need only cease using the Brave website and uninstall the Brave mobile applications.

Brave is located in the European Union. Brave may transfer your Personal Data to countries outside of the European Union and outside the Brazilian territory, which may not offer the same level of protection. Many of our third-party service providers are located within the United States and their processing of Personal Data will involve an international transfer to several countries. We do our best to ensure a similar degree of security by transferring your Personal Data outside the Brazilian territory, complying with the requirements of the Law nº 13.709/2018 -Brazilian Data Protection Law (“Lei Geral de Proteção de Dados Pessoais” or “LGPD”).

Brave also put data security measures into place to protect your Personal Data. We allow access to your Personal Data only by employees and service providers who have a need to know or access your Personal Data on our instructions. Brave will notify you and any regulatory body of any breach of your Personal Data or our security measures if and when we are legally required to do so.

Brave will only retain your Personal Data or Sensitive Personal Data for so long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

Article 18 of the LGPD provides the following rights: (i) confirmation of the existence of processing; (ii) access to data; (iii) correction of incomplete, inaccurate or out-of -date data; (iv) anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the Law; (v) portability of the data to another service provider or product provider; (vi) deletion of personal data processed with the consent of the data subject; (vii) information about public and private entities with which Brave has shared data; (vii) information about the possibility of denying consent and the consequences of such denial; (viii) revocation of consent. To submit a request please email Brave at support@thebrave.io

Brave will apply our best efforts to briefly respond you in accordance with the deadlines established by LGPD. To confirm your request, Brave may request specific information as a security measure to ensure that Personal Data is not disclosed to an unauthorized third party.

 

California Privacy Rights

This part of this Privacy Policy contains disclosures and provisions required by the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act of 2020 (the “CPRA”) and applies only to “Personal Data” that is subject to the CCPA and the CPRA and only to California residents. In this Privacy Policy, any reference to the “CCPA” shall mean such Act as amended by the CPRA and/or by any other regulations or other legislative actions from time to time.

California residents have a right to request that we disclose what Personal Data or Sensitive Personal Data we collect from you and whether, and how, we disclose, share, or sell that Personal Data or Sensitive Personal Data. California residents may also request that we correct or delete any Personal Data or Sensitive Personal Data collected or maintained by Brave from you.

California residents may also have the right to opt out of the sharing or sale of their Personal Data or Sensitive Personal Data upon request. Brave will only retain your Personal Data or Sensitive Personal Data for so long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

California residents may opt out of the sharing or sale of their Personal Data by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information,” “Do Not Share My Personal Information,” or any other similar designation. By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sharing or sale of your Personal Data as set forth in the California Consumer Privacy Act.

However, even though you may have opted out, you may still see interest-based advertisements. If you opt-out of the sharing or sale of your Personal Data but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on Personal Data that was not shared or sold by Brave, Personal Data that was shared or sold to downstream participants at least 90 days before you opted out, or Personal Data that was shared or sold by other sources from which you have not opted out.

California residents may opt out of having their Sensitive Personal Data used or disclosed for advertising or marketing. Sensitive Personal Data includes your precise geolocation and the contents of mail, email or text messages, unless the business is the intended recipient.

To submit a request for a list of the categories of personal information collected from you or to request that Brave correct or delete your personal information or sensitive personal information, please email Brave at support@thebrave.io

To verify your request, Brave may request certain information from you to confirm that you are a Brave user, such as your phone number, username, email address or geographic location. You may designate an authorized agent to make a request to Brave to disclose or delete your Personal Data. To do so, you must provide Brave with proof that such agent has been appointed by you, such by providing a a signed power of attorney form and provide accurate responses to any information requested by Brave that may be necessary to confirm that you are a Brave user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Brave for their exercise of these rights conferred under California law.

Brave collected the following categories of PII as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Notice:

– Identifiers – Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers – As long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

– Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) – Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information – As long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

– Commercial    Records of products purchased – As long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

– Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement – As long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

– Geolocation data – As long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements.

 

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, or if your personal information is not accurate or complete, please contact our Data Protection Officer at: zachi@thebrave.io

 

Other US States Privacy Laws

Please note that the residents of other US states (such as Colorado, Connecticut, and Virginia) may have a right to request that Brave disclose what Personal Data or Sensitive Personal Data it collects from them and whether, and how, Brave discloses, shares, or sells that Personal Data or Sensitive Personal Data. Such residents may also have the right to request that Brave correct or delete any Personal Data or Sensitive Personal Data collected or maintained by Brave from them.

To the extent any such residents apply to Brave in order to access such rights (or other rights which they may have under applicable laws), Brave will enable such residents to exercise their rights in accordance with such laws and subject to any conditions or limitations included in such laws from time to time, as well as subject to Brave’s own policies.

 

European Union (GDPR)

We are a member of and participate in the IAB Europe Transparency & Consent Framework and complies with its Policies and Specifications. We use our own private Consent Management Platform (CMP) registered with IAB Europe.

For the purposes of the GDPR, Brave might be a data controller (i.e., the company that is responsible for, and controls the processing of your Personal Data) for certain uses of your Personal Data and a data processor for other uses, as applicable.

To the extent that Brave transfers or stores the Personal Data or Personal Sensitive Data of European citizens outside of the European Union, Brave adheres to the EU-U.S. Data Privacy Framework (“DPF”) Principles, including the DPF’s Supplemental Principles, and comply with the Principles in handling all data from EU-citizens.

Brave may be subject to the enforcement powers of the United States Federal Trade Commission (“FTC”) in relation to our handling of user data.

If you are a European citizen, you are entitled to certain rights regarding the protection of your Personal Data and Sensitive Personal Data, which are subject to limitations set forth in the EU GDPR and its applicable case law. These rights are:

  • The right to access and correct the information that we processes about you;
  • The right to transfer all or a part of the information collected about you to another data controller, where it is technically feasible;
  • The right to the erasure of data concerning you, subject to our right of retention under the law;
  • The right to object to the processing of Personal Data and Sensitive Personal Data where you dispute the accuracy of the data, the processing is not lawful, we no longer need the information for the purposes of processing, or you have raised an objection for personal reasons;
  • The right to revoke your consent to data processing;
  • The right to object to the processing of your Personal Data Sensitive Personal Data for marketing purposes;
  • The right to object to the processing of Personal Data and Sensitive Personal Data for direct marketing or for personal reasons that arise from your particular situation; and
  • The right to file a complaint with a data protection authority.

To exercise these rights, contact Brave at: support@thebrave.io

Brave reserves the right to charge a reasonable fee if your request is unreasonable or excessive or for other reasons from time to time at Brave’s discretion and subject to applicable laws.

To confirm your request, Brave may request specific information from you such as a security measure to ensure that personal data is not disclosed to an unauthorized third party. Brave will attempt to respond to all legitimate requests within thirty (30) days.

 

Changes in the Privacy Policy

Brave reserves the right to modify this Privacy Notice without notice to you in order to reflect technological developments, legislative and regulatory changes and good business practices as well as changes in Brave’s activities including in the App.

In the event that Brave changes this Privacy Notice, the updated version of the Privacy Policy posted in the App and/or on Brave’s website(s) will reflect those changes and the updated version shall be marked by the updated effective date at the top of the Privacy Policy. You are expected to review this Privacy Policy frequently in order to ensure that you are familiar with the most updated version.

 

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, or if your Personal Data is not accurate or complete, please contact Brave at: support@thebrave.io