Last Updated: October 12, 2022
Collection and Use of Information
Personal information is information about you that identifies you as an individual. Information, including personal information, we collect depends on how you interact with our Services. We collect information, including personal information, directly from you through our Site, and/or our App, when you contact our customer service, and from third-party sources. This information includes:
Account Information. If you create a Member Account, we’ll collect certain information that can be used to identify you, such as your name, email address, telephone number, and profile picture. If you create a Member Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and email address and other information that your privacy settings on the SNS Account permit us to access. If you create a Member Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information associated with your SNS Accounts, such as current position, job title, employer, duration or time period of employment, and employment location.
Your Contacts. Bravado has a variety of ways for you to store or share your contacts within our Services. If you allow, we collect contacts associated with your email and/or customer relationship management (“CRM”) accounts or through LinkedIn, Facebook, Google and other integrations we offer to recommend you people with whom you can connect inside the Services. You may also provide information about individuals when you submit or reply to Opportunity Listings, provided on and through the Services. This contact information will identify others, and you are responsible for giving any required notice to those individuals and, where required by law, obtaining their consent before sharing their contact information with us.
Information You Directly Provide Through User Content. You control what information, including personal information, you share when you provide User Content. For example, when you are creating your profile or professional portfolio, if you share any personal information in such materials, we will collect such information. Please use discretion when providing any User Content.
Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features provided on and through the Services (e.g., Opportunity Listings, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.
Publicly Available Information About You. We may also collect any publicly available information, including personal information, about you such as, information available on your LinkedIn and Google accounts.
Information Provided by Reviewers. We will collect the information about our Members that their Reviewers post. However, as a Member you will always have the option of deleting any Reviewer’s Review about you at any time.
Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be used for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Site, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
For more information about Cookies and similar technologies, please see our separate Cookie Notice.
Advertising or Targeting. We may use first-party or third-party Cookies and Web Beacons to deliver Content, including ads relevant to your interests, on our sites or on third-party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
Information Related to Use of the Services. Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”). Log Data may include information such as Internet Protocol (IP) address, browser type, operating system, the web page visited before accessing our Services, the pages or features of our Services browsed, and the time spent on those pages or features, search terms, the links on our Services clicked on, and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
Information Sent by Your Device. We collect certain information that your device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
Location Information. When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your device.
Use of Information Collected
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Member Account, if you are a Member), and to enable you to enjoy and easily navigate our Services. We will use your personal information to:
provide the Services, communicate with you and provide customer support in relation to the Services.
process payments for transactions carried out via the Services.
pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention.
use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
resolve disputes and troubleshoot problems.
customize your experience and otherwise measure and improve our Services, including to develop new products and services.
prevent potentially prohibited or illegal activities on or through the Services.
send you relevant emails and communications (including keeping you informed about our offerings and any promotional offers) that might be of interest to you. If we use your personal information to market to you, you will be able to opt-out of such uses.
comply with our legal obligations.
enforce our agreements, terms, conditions, and policies, and send you notices and alerts.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
Information that We Share with Third-Parties
We may share any personal information that we have collected from or regarding you as described below:
Information Shared with Our Service Providers.
We may engage third-party service providers to work with us to administer and provide the Services. These third-party service providers have access to your personal information only for the purpose of performing services on our behalf. Our Legal and Privacy Center includes a list of current Third-Party Subprocessors.
Information Shared with other Users.
We may share some of the information you make available via the Services with other Users. For example, we may share some of your information, including personal information, with the Reviewers that you have selected to review your work so they can identify you and provide their Reviews. We will share with the Reviewer only the information that is relevant for the purpose of providing you the Services.
Information Shared with Third-Parties.
We may share de-identified and/or aggregated information with third parties for industry research and analysis, demographic profiling and other similar purposes.
Information Shared for Interest-Based Advertising and Third-Party Marketing.
Through our Services, we may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected personal information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Bravado related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” Please see our separate Cookie Notice for more information about Cookies and similar technologies. If you prefer that we do not share your personal information with third-party advertising partners, you may opt-out of such sharing at no cost by following the instructions in the ”Cookies and Interest-Based Advertising” section below.
Information Disclosed in Connection with Business Transactions.
Information that we collect from our Users may be considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your personal information, may be disclosed or transferred to a third-party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third-party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We offer you choices regarding the collection, use and sharing of personal information and we’ll respect the choices you make. Please note that if you decide not to provide us with the personal information that we request, you may not be able to access all of the features of the Services.
Your Privacy Rights.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us at firstname.lastname@example.org or as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
You can access and modify the personal information associated with your Member Account through the Settings on your Profile. If you want us to delete personal information (that identifies you or others in connection with you, such as your email and/or CRM contacts) and/or your Member Account, please contact us at email@example.com with your request. We’ll take steps to delete the information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Cookies and Interest-Based Advertising.
You may stop or restrict the placement of Cookies, Web Beacons, and other technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note, you must separately opt out in each browser and on each device. Please see our separate Cookie Notice for more information about Cookies and similar technologies.
Responding to Do Not Track Signals
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including personal information) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. As a matter of security, we do not disclose the specific details regarding our security posture as this information could be used by criminals and other bad actors. For more information on our security practices, please contact us at firstname.lastname@example.org.
Links to Other Sites
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your personal information to us, we may transfer your personal information to the United States and process it there. We endeavor to safeguard your information consistent with the requirements of applicable laws.
Retention of Your Personal Data
We retain your personal information as follows:
The period during which we store your personal information varies depending on the purpose for the processing:
For the provision of our Services, for so long as you are a visitor or User of the Services.
For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.
Children's Privacy Statement
Our Service is not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information of a child under 13 we will take steps to delete such information from our files as soon as possible.
Supplemental Privacy Notice for California Residents
Bravado values the privacy of our visitors and Members and we take measures to implement reasonable security controls for the protection of their information. California law and more specifically CCPA define ‘personal information’ very broadly as information that relates to,
describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. It could include identifiers such as IP addresses or device identifiers, in addition to names and addresses. This Supplemental Privacy Notice for California Residents provides additional information regarding Bravado’s practices and your rights if you are a resident of California.
The CCPA provides California residents with the right to know what categories of personal information that we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
Additional Privacy Rights for California Residents
“Sales” of personal information under the CCPA. For purposes of the CCPA, Bravado participates in various affiliate ad networks as described in the “Information Shared for Interest-Based Advertising” section above. While not a traditional “sale” for money, this participation does constitute a “sale” of personal information under the CCPA. As such, you may opt-out of such a “sale” by using the mechanisms described in the “Cookies and Interest-Based Advertising subsection of the “Your Choices” Section Above. You may also exercise your rights as described below.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in the Questions section below.
Verification. When you make a request to know or delete personal information, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about what personal information we collect, use, disclose and sell. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we have collected about you in the last 12 months, why we have collected it, and whether we have disclosed that information for a business purpose.
The categories of sources from which we collect personal information.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you.
Deletion Rights Requests. You have the right to request that we delete your personal information we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal
Code § 1546 seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
If you are a California resident and wish to exercise any of your rights under the CCPA, please submit your request by sending us an email at email@example.com with “California Privacy Rights” in the subject line or by writing to us at 268 Bush Street, #2734, San Francisco, CA 94104.
Only you or a person that you authorize to submit a request to know your personal information or to delete your personal information on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an Account with us, we will deliver our written response to the registered email associated with the Account. If you do not have an Account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Correction of Information Collected From You Online
CalOPPA provides you with the right to correct the information that we collected about you online. If you entered information online and later need to correct that information, please contact us by e-mail at firstname.lastname@example.org. Please note that if we cannot associate the information to you, we may not be able to correct it.
Supplemental Privacy Notice for EEA and UK Residents
Bravado only collects, uses, or retains personal data for the purposes specified in this EEA Privacy Notice. When the purpose is no longer valid, or if we no longer have a legal basis for retaining your personal data after the original purpose has been fulfilled, we will delete such personal data. We may retain personal data beyond the original purpose for collection where we have a legitimate need for the personal data to comply with a legal obligation to which we are subject or to exercise or defend legal claims.
The Legal Basis on Which We Process Your Personal Data
It is necessary for the performance of Services we provide to you; such as the delivery
of our Services under our Terms of Service;
It is necessary for us to comply with our legal and/or contractual obligations, such as replying to a governmental request or a subpoena or other legal process;
When we’re pursuing legitimate interests for ourselves or those of third parties which are items that you would reasonably expect us to use your personal data for provided safeguards apply to your personal data that protect your privacy, such as:
to develop new products and features or improve our Services for the benefit
of our Users;
performing research to improve our Services to our Users and helps the public;
communications, marketing and intelligence including sending you direct
fraud detection and crime prevention;
monitor, detect and protect our computer systems, network, infrastructure, computers, information, intellectual property and other rights including your data security;
protecting against harm to the rights, property and safety of you, our Users, us, and the public;
general corporate operations and due diligence; and for the establishment, enforcement or defense of legal claims.
Bravado is located in the United States, and as such, all personal data will be stored there, and will be transferred there should you live in another country; however, it may be accessed from other countries where Bravado does business. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal data outside the EEA or the UK are adequately protected. Unless a jurisdiction is deemed to have adequate safeguards, the safeguards we typically put in place are the Standard Contractual Clauses in accordance with the General Data Protection Regulation and the UK General Data Protection Regulation.
How We Handle Your Individual Rights in the EEA and UK
If you are located in the EEA or the UK, you have the following individual rights with respect to the processing of your personal data:
to be informed about the collection and use of your personal data;
to access and receive a copy of your personal data, and other supplementary information;
to have your inaccurate personal data rectified, or completed if it is incomplete;
to have your personal data erased;
to request the restriction or suppression of your personal data;
to data portability which allows you to obtain and reuse your personal data for your own purposes across different services;
to object to the processing of your personal data in certain circumstances;
to restrictions on automated individual decision-making (making a decision solely by automated means without any human involvement); and
to restrictions on profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
If you object to our processing of your personal data, it may impact our ability to deliver all of our Services to you. If applicable law provides you any of the individual rights above, you may request action with respect to such rights by emailing us at: email@example.com.
If you have contacted us and we have tried to resolve your complaint, but you feel that your complaint has not been successfully resolved, and you are a resident of the EEA or UK, Bravado will cooperate with the EEA Data Protection Authorities or UK’s ICO, and/or their representatives (DPAs), as appropriate, for investigation and resolution of the complaint.