- BRAVE PEOPLE LTD. (“BRAVE”) IS AN ADVERTISING PLATFORM THAT MONETIZE MOBILE APPLICATIONS AS WELL AS OTHER SERVICES OR PRODUCTS WHICH WE MAY MAKE AVAILABLE FROM TIME TO TIME (THE “SERVICES”).
- In this Policy, “BRAVE” shall include also any of its affiliates (meaning controlling entities, controlled entities and entities under common control).
- BRAVE takes your privacy very seriously and is committed to protecting your information in compliance with all applicable laws and regulations (collectively, “Laws”).
- This Policy has been created to inform you about how BRAVE collects and/or receives, stores, uses and shares and/or discloses the information you provide or that is being collected in connection with your use of any of the Services or your visit to our website (the “Website”). By accessing or using any of the Services or the Website, you are deemed to have accepted this Policy, including without limitations, to the collection and/or receipt, disclosure, storage and use of your information as outlined in this Policy. If you do not agree to any provision in this Policy, please stop using the Services or the Website.
- Brave may amend this Policy from time to time without providing to you any notice and you are encouraged to check this Policy frequently in order to make sure you are familiar with the most updated version. You continued use of the Services or the Website indicates your consent to the most updated version of this Policy.
- Please note that Brave will not share and/or disclose any of your personal information or other identifiable (by itself or together with additional information) information protected under applicable privacy Laws (including without limitations the GDPR and the CCPA/CPRA) (“PI”) with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by “opting in”.
- 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 PI) for certain uses of your PI and a data processor for other uses, as applicable.
How Brave Collects Your Personal Information
- BRAVE only collects PI to the extent it is necessary in order to fulfil one or more of the Services’ or the Website’s functions and activities and/or to maintain and improve the Services or the Website.
- As an example only, Brave may collect the following PI from you directly or from third parties: (i) your name; (ii) your IP and other browsing data including your device, browser, etc.; (iii) your e-mail and other contact details which you have provided or which we have collected in accordance with this Policy; (iv) your location data; (v) your gender; and (vi) your age and date of birth.
- Brave may also collect certain information about your activities on or through various third-party applications or services, through your use of the Services or the Website and/or from collecting and certain publicly available information.
- Brave may receive certain billing and payment information when you make payments to or receive payments from BRAVE. BRAVE will not store your financial information, however payment processors may share and/or disclose non-financial information with BRAVE.
- Finally, BRAVE may use various tracking technologies to collect certain technical information, including without limitations: (i) the type of the device you are using; (ii) the type of your operating system, version and platform type; (iii) your mobile device’s identifiers and other related information; (iv) your browser types, language, etc.; (v) referring/exit pages, URL, etc.; and (vi) pages viewed and other types of browsing information. In collecting such information from your devices (and in general under this Policy) Brave will act in full compliance with applicable Laws.
- Brave may collect the above information directly or through our third-party suppliers, subject to the applicable engagement terms with such third-party suppliers and subject to applicable Laws.
Transfer of Personal Information Internationally
- When you use the Services or the Website, your PI 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 PI about you on servers located in the EU, in the United States and/or in other countries and Brave may change the location of our servers (or severs or third-parties BRAVE is making use of, at its sole discretion) time to time.
- When BRAVE transfers your PI from one country to another country, it will take commercially reasonable steps to ensure that your PI is treated in the most secured and lawful way and in the manner and in accordance with the principles that are described in this Policy as well as 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 PI 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 PI is currently located.
- If you are a resident in a jurisdiction, where transfer of your PI to another jurisdiction requires your consent, then you hereby provide BRAVE with your express and unambiguous consent to such transfer in order for us to be able to provide you with the Services and the Website.
- 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 PI 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 our best understanding of the existing legal framework on these issues.
- A cookie is a small data file that is stored on your computer or on your mobile device. The Services may send cookies to a computer or a mobile device when you access the Information contained in a cookie may be linked to PI for purposes such as improving the quality of the Services or the Website, creating or improving recommendations to interests, and making the Services or the Website easier to use for you.
- Third party advertisers on the Services or the Website may also use, place or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies. You may disable the cookies at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting cookies from the websites you visit or limit the type of cookies you allow, however any such changes and actions might affect your ability to use certain aspects and features of the Services or the Website.
- BRAVE and its third party service providers and/or partners may also employ other similar technologies including, without limitations: (i) web beacons, allowing us to know if a certain page was visited or whether a specific e-mail was opened; or (ii) pixels, allowing us or our advertising or other partners to advertise more efficiently by excluding you from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites.
How BRAVE Uses and Shares and/or Discloses Your Personal Information
- BRAVE may collect and/or receive and store your PI for the following reasons: (i) enable our Services or the Website; (ii) improve, optimize and personalize the Services or the Website; (iii) provide technical support; (iv) protect your safety and your legal rights; (v) enforce this Policy; (vi) prevent fraud or illegal activities; (vii) manage and deliver contextual and behavioral advertising; (viii) notify you of new products or services or any updates; or (ix) comply with legal obligations and resolve disputes.
- For fulfilling the above purposes BRAVE may share your information with third parties such as services provider and suppliers, subject to making sure that such third parties are in full compliance with their legal obligations with respect to the protection of your information.
Advertising by a Third-Party
- BRAVE does not actively share and/or disclose PI with third-party advertisers for their direct marketing purposes unless you have provided your consent.
- When advertisers place ads in the Services or the Website, they may collect or Brave may share certain performance data, aggregated and/or de-identified information about you. BRAVE may use your email and other contact details you provided with for approaching you with direct marketing offers, including new products or services by BRAVE or its business partners. You may opt out of such marketing services by replying accordingly to messages or by contacting us at: email@example.com
- The information collected as set forth above may be used in order to measure the effectiveness of ads, offer targeted advertising and/or perform web analytics.
How We Share Your Information – Additional Cases
- BRAVE may share your information: (i) in response to lawful requests by governmental authorities, including to meet national security or law enforcement requirements, or legal process; (ii) to satisfy any Laws; (iii) where we believe that the Services or the Website is being used in committing a crime or other illegal act or omission , including to report such illegal activity and/or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions; (iv) when BRAVE believes that there is an emergency that poses a threat to your health or safety and/or of any other person; and (v) to protect the rights or property of BRAVE, yours or and other third party, including to enforce this Policy.
Managing Your Information
- Please note that, under applicable data protection Laws, you have the following rights, which you can exercise in accordance with the instructions below:
- access your personal data and receive a copy thereof;
- amend your personal data, i.e. request to amend inaccurate personal data;
- delete your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under applicable Laws exist – for example Brave may have the right not to agree to a request to delete information if applicable Laws obligate us to retain information for AML/KYC purposes);
- restrict the processing of your personal data, provided that one of relevant grounds for such actions apply (and that there are no exclusions under applicable Laws);
- complain to a supervising authority; and
- withdraw your consent in accordance with and subject to applicable Laws.
You may request to exercise your rights in relation to your personal data by contacting us at: firstname.lastname@example.org
How BRAVE Protects Your Personal Information
- BRAVE has made reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access. While we take reasonable precautions against possible security breaches of our Services or the Website, no website or Internet transmission is completely secure, and BRAVE cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
How Long BRAVE Retains Your Personal Information
- How long BRAVE retains your PI depends on why such PI was collected and how such PI is being used. BRAVE will not retain your PI for longer than is necessary for its business purposes or for legal requirements.
- BRAVE is determining the retention period by assessing the time required to fulfill its business purposes, and mainly to provide its various products and services, maintaining relevant transaction and other business records, improving and monitoring the performance and the quality of its services and any other requirements under applicable laws and regulations, as they may be from time to time.
- For instance, BRAVE may retain all or part of your PI for a few years after you have decided to stop using the Services or the Website (including in case you have requested to have deleted your information) if this is necessary to meet its legal obligations or to exercise legal rights (including without limitations any AML/KYC obligations).
Representative for data subjects in the EU and UK
- We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
- Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website:
CCPA Obligations Applying to your Personal Information
- This part of this Policy contains 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 “PI” that is subject to the CCPA and the CPRA and only to California residents. In this 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.
- For the purpose of the CCPA and the CPRA, “PI” does not include: (i) publicly available information from government records; (ii) de-identified and/or aggregated information; or (iii) information specifically excluded from the scope of the CCPA/CPRA, such as health information or medical information or PI covered by certain sector specific privacy laws and regulations.
Collection, Disclosure or Sale of PI
- In the last 12 months, BRAVE collected the categories of PI about California residents as described in this Policy including in this CCPA Privacy Notice. BRAVE’s use of such PI may qualify as a “Sale” under the CCPA, since the data we provide to third parties, including to our clients/users and partners might help us to generate valuable consideration. Even if our own use of PI does not constitute a “Sale” under the CCPA, our clients/users and partners may use our technology to buy or sell PI as defined by the CCPA. If you wish to opt out of the use of your PI for interest-based advertising purposes, please contact us at: email@example.com
Categories of PI BRAVE Collects
- Personal and online identifiers (such as name, emails, unique online identifiers like cookies, mobile advertising IDs, etc.). Please note that BRAVE will not, however, sell any personal identifiers such as names and emails and they will be used only for BRAVE’s internal purposes as described in greater depth in other parts of this Policy.
- Internet or other electronic network activity information (such as browsing history, interactions with a website or advertisement).
- Geolocation information.
- Inferences drawn from the above information about your predicted characteristics and preferences.
- Other information linked to the PI above.
Such PI was Used as follows
- Categories of Sources: BRAVE collects this PI from the following categories of sources: visitors of our Website, business partners and automated means
- Why We Collect, Use, and Share such PI: BRAVE uses the PI collected for its commercial and business purposes, as described in this Policy. These commercial and business purposes include, without limitation: (i) Providing the Services or the Website, (ii) Other business purposes as identified in the CCPA, which include: advertising or marketing services, legal compliance, detecting and protecting against security incidents, fraud and other illegal activity and analytics, internal research for technological improvement, internal operations, activities to maintain and improve the Services or the Website and other certain one-time uses.
- Recipients of California PI: To the extent our use of PI constitutes a “Sale” under the CCPA, we “sell” PI to our partners. BRAVE discloses the categories of PI designated above to the following categories of third parties, for the above commercial and business purposes: Services providers (as defined by the CCPA), government entities (upon request and to the extent we are obligated to do so), Services providers such as fraud protection vendors and data analytics companies.
- BRAVE does not sell, transfer, trade, or otherwise give any right in to any third party for its own business or personal use any PI unless it has secured your Accordingly, there has been no sale of your PI by BRAVE to any third party for its own business or personal use in the past twelve (12) month period.
Your Rights Regarding PI
- If you are a California resident, you may exercise the following rights, subject to certain exceptions as they shall be from time to time in accordance with and subject to applicable Laws:
(i) the right to know categories and specific PI BRAVE collects, use, disclose, and sell about you over the past twelve (12) months, categories of sources from which BRAVE collects your PI, its purposes for collecting or selling your PI, the categories of your PI that BRAVE has either sold or disclosed for a business purpose, and the categories of third parties with which BRAVE has share PI,
(ii) the right to request that BRAVE delete the PI it has collected from you or maintain about you – subject to certain exceptions,
Once BRAVE receives and confirms a verifiable consumer request (as more fully explained below), Brave will delete (and direct any relevant service providers to delete) the relevant PI from our records, unless any of the exceptions provided under law applies.
BRAVE may deny any deletion request made by you if retaining the information is necessary for BRAVE or for any of its service providers to:
- Comply with the provisions of the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Complete the transaction other purpose for which BRAVE has collected the relevant PI, provide a product or a service that was requested by the relevant consumer, take actions which are reasonably anticipated within the context of BRAVE’s ongoing business relationship with the consumer, or otherwise perform its contract with the consumer.
- Detect and solve security incidents, protect its business (including its software) against any malicious, deceptive, fraud, or other illegal activity, or exercise its rights vis-à-vis those who are responsible for the same.
- For maintenance purposes including repairing errors and malfunctions which impair existing functionality.
- Exercise the right for free speech or ensure the rights of its customers to do so or to exercise any another rights provided for by applicable law.
- Enable internal uses reasonably aligned with the consumer’s expectations based on BRAVE’s relationship with the consumer, or
- Comply with any of its legal obligations (g. KYC duties).
(iii) the right to correct inaccurate PI. California consumers have the right to request that any business that maintains any inaccurate PI about them correct that inaccurate PI, considering the nature of the PI maintained by such business and the purposes of the processing or other use of the applicable PI. A business must also use commercially reasonable efforts to correct any inaccurate PI as directed by the consumer in a verifiable consumer request,
(iv) the right for portability. California consumers are entitled to obtain a copy of their PI which the requesting consumer has previously provided to a business, in a portable and, if technically feasible, readily usable format which allows the consumer to transfer the such PI to another business without hinderance,
(v) the right to limit the use and disclosure of sensitive PI. California consumers have the right to limit BRAVE’s use and/or disclosure of any sensitive PI to the minimum which is necessary in order to provide them with requested services or products. California consumers should be provided with a link titled “Limit the Use of Sensitive Personal Information” which link should lead to a landing page enabling them to select to limit the use of any sensitive PI as described above. Sensitive PI includes any of the following information: (i) social security number, driver license number, passport number, etc.; (ii) bank account details, credit card or debit card number; (iii) user account login information including passwords; (iv) contact details such as a personal email, personal address or phone number when the recipient (the consumer) is not the business accessing the information; (v) accurate geolocation; (vi) race, religious belief or union membership; (vii) health related information; (viii) genetic data; or (ix) information related to consumers’ sex life or orientation. Please note however that under the CCPA/CPRA, publicly available information will not be considered as sensitive PI,
(vi) the right to opt out of any “sale” of your PI. A business must provide a “Do Not Sell My Personal Information” link in a reasonable location on such business’ website and such link should lead to a landing page enabling consumers to opt out of the selling or sharing of their PI. California consumers may also opt-out of cross-behavioral advertising and profiling based on decisions which can produce a legal or other significant effect about them, and
(vii) the right not to be discriminated against for exercising any of your rights under the CCPA. A business is not entitled to discriminate against any consumers who have exercised any of their rights under the CCPA/CPRA. Anything to the contrary above notwithstanding, a business is entitled to charge fees or provide a different quality of services if the difference is reasonably related to the relative value of the applicable customers’ data and, in addition, a business may offer its customers financial incentives for the right to collect or sell any PI, based on prior opt in.
- To exercise any of the above rights or for any questions you may have, please contact us at: firstname.lastname@example.org.
Minors under 18
- We do not sell the PI of consumers that we know to be under 18 years of age. BRAVE is taking complying with applicable Laws regarding minors very seriously, including without limitations, the United States’ Children’s Online Privacy Protection Act.
- If you are a parent or guardian and you have discovered that your minor has submitted PI to us, BRAVE will make reasonable efforts to delete the information from its database at your request. To request the deletion of your minor’s information, please send an email to:email@example.com
Making a CCPA/CPRA Consumer Rights Request.
- A consumer who wishes to exercise any of its CCPA/CPRA rights above, can do so in one of the following ways: (i) Clicking on this link to submit a form; or (ii) by calling us at +972-544451052.
- Upon BRAVE receiving a verifiable request from a consumer, Brave will confirm the receipt of the request within ten (10) days and provide the consumer with information about how BRAVE handles the request, and by when the consumer should expect to receive a response from us. Please note however that a verifiable consumer request to receive information about your PI or to access your PI under the CCPA/CPRA can be made not more than two (2) times within any twelve (12) month period.
- A verifiable request submitted to BRAVE by a consumer must include sufficient information in order to allow BRAVE to reasonably verify that the submitting consumer is actually the person about whom BRAVE collected the relevant PI or an authorized representative of such person and, in addition, to describe the consumer’s request with sufficient details in order to enable BRAVE to properly evaluate the request and respond to it.
- BRAVE may (but is not obligated) to request reasonable proof that anyone approaching BRAVE with a request and seeking to act on the behalf of a consumer is authorized by the consumer to do the same. It is permissible for a consumer to make a verifiable consumer request on behalf of its minor children.
- BRAVE will make reasonable efforts to respond to any verifiable consumer request within forty-five (45) days of the date of receipt of the If BRAVE shall require additional time to respond to the request, Brave will inform you about of the reason and additional period need (but in any event not more than 90 days more) in writing.
- Any response BRAVE provides only covers the twelve (12) month period preceding the date on which the verifiable consumer request was actually received by BRAVE.
- BRAVE may (but is not obligated to) charge a fee to process or to respond to any verifiable consumer request if such request is excessive, repetitive, unfounded or for other justifiable reasons.
Changing BRAVE’s Policy
- BRAVE may decide to change this Policy from time to time at its sole discretion. If BRAVE decides to make material changes to this Policy, it will inform you by placing a notice on its website or by sending a notice to the e-mail address it has on file prior to the applicable change becoming effective – to the extent practical to do so. Otherwise, BRAVE may post an updated version of this Policy without any additional or prior notice.
- For any questions about this Policy, please contact us at: firstname.lastname@example.org