Last Updated: October 8, 2020
Collection and Use of Information
Account Information. If you create an Account, we’ll collect certain information that can be used to identify you, such as your name, email address, and profile picture. If you create an 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 an Account through the Site or one of your SNS Accounts, we may also collect your gender, date of birth and other information associated with your SNS Accounts.
Your Contacts. Bravado has a variety of ways for you to store or share your contacts within our Service. 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 platform. You may also provide information about individuals when you submit or reply to Opportunity Listings. 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 the contact information with us.
Information you Provide. You control what information, including personal information, you share with us. 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. So please use discretion when providing us with any User Content.
Interactive Features. We and others who use our Service may collect personal information that you submit or make available through our interactive features (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 included on our Service for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Service, to monitor how many visitors view our Service, 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).
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 Service. Our servers automatically record certain information about how a person uses our Service (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Service, the pages or features of our Service to which a User browsed and the time spent on those pages or features, search terms, the links on our Service that a User clicked on and other statistics. We use Log Data to administer the Service and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Service 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 Service is used.
Information Sent by Your Device. We collect certain information that your device sends when you use our Service, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Service.
Location Information. When you use our Service, 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 Service 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 Service, to administer your use of the Service (including your Account, if you are a Member), and to enable you to enjoy and easily navigate our Service. We will use your personal information to:
- provide the Service, communicate with you and provide customer support in relation to the Service.
- process payments for transactions carried out via the Service.
- 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 Service, including to develop new products and services.
- prevent potentially prohibited or illegal activities.
- send you relevant emails and communications (including keeping you informed about our products, 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 Service, 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 Service. These third-party service providers have access to your personal information only for the purpose of performing services on our behalf.
Information Shared with other Users. We may share some of the information you make available via the Service 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 Service.
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 Service, 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.” 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, including personal information, is 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 Service.
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 email@example.com or as set forth in the Questions section 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.
Modifying Information. You can access and modify the personal information associated with your 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 Account, please contact us at firstname.lastname@example.org 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 Service may not work properly. Please note that cookie-based opt-outs are not 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.
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. When you enter sensitive information on our Service, we encrypt this data using SSL or other technologies. 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.
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.
Our Policy Toward Children
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 Notice for California Residents
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). 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”, this participation does constitute a “sale” of personal information. 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, 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, which may include your name, email address, username, or password.
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.
Supplemental Notice for EEA Residents
Bravado processes your personal information based on our legitimate interest in running our business, as necessary to enter into or fulfill contractual obligations to you, or as necessary to exercise or defend legal claims. While there may be times we also process personal data through your consent, we will request such consent when we collect the personal information for specific processing purposes which we use consent as the legal basis for processing.
Bravado only collects, uses, or retains personal information for the purposes specified in this Policy. When the purpose is no longer valid, or if we no longer have a legal basis for retaining data after the original purpose has been fulfilled, we will delete such personal information. We may retain personal information beyond the original purpose for collection where we have a legitimate need for the personal information to comply with a legal obligation to which we are subject or to exercise or defend legal claims.
Questions or Complaints
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 European Economic Area, Bravado will cooperate with the EEA Data Protection Authorities and/or their representatives (DPAs), as appropriate, for investigation and resolution of the complaint.