Privacy—yours and all of our Users’—is very important to us. This privacy notice explains how Personal Data is used and protected. This statement explains how we deal with Personal Data that is obtained via the Brave Buttons System (the “Buttons”), the Brave Sensors System (the "Sensors"), and The Brave App (the "App"). We respect the privacy of our Users and ensure that any Personal Data we receive or transmit will be protected and treated confidentially. Information requested or provided other than through the Buttons, the Sensors, or the App will contain separate privacy terms and conditions.
Brave’s CEO, Gordon Casey, is in charge of protecting Personal Data and, accordingly, also serves as our Privacy Officer. You can reach him in this capacity via firstname.lastname@example.org or over the phone at +1 (833) 833-2100.
Personal Data – any information relating to an identified or identifiable natural person.
Processing/Process (as a verb) – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
User – a natural person whose Personal Data is being Processed; also referred to in this notice as “you" (either capitalized or not). This includes, but is not limited to, App Callers and Supporters.
Client – an organization, whether incorporated or not, that has paid or contracted for any of Brave's technology services, including but not limited to the Brave App, Brave Buttons, and Brave Sensors.
We/us (either capitalized or not) – Brave Technology Co-Op.
Supporters - refer to Users of the App who volunteer to engage with our products to provide support (such as a conversation or a friendly ear) to other Users of the App.
Caller - refers to a User of the app who is not a Supporter.
You have legal rights under data protection laws in relation to your Personal Data.
You have the right to:
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information where we know we are dealing with the right individual.
We will not ask for a fee, unless we think your request is unfounded, repetitive, or excessive.
Where a fee is necessary, we will inform you before proceeding with your request.
You can locate more information about when and why we use Personal Data in other parts of this Privacy Notice, as well as the notices we provide when we collect information from you. If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use Personal Data you can contact us at any time.
If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it. If you show that your Personal Data is inaccurate or incomplete, we will make the necessary changes. If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedure, which is located below.
The App is designed and intended for use by Users in the United States, Canada and other countries. Personal Data provided for posting or making available on the App is stored in Canada. However, by using the App, you acknowledge and understand that the App is available, via the Internet, throughout the world; by using our products, you acknowledge that Personal Data you provide may be transferred across borders, including through the United States. Data protection laws vary among countries, with some providing more protection than others.
By submitting or providing Personal Data through our products, you understand that the applicable laws, regulations, and policies of these different jurisdictions may apply, including but not limited to, the European Union General Data Protection Regulation (“GDPR”).
If you are a resident of the European Union, please review our GDPR-specific privacy practices:
The Buttons registration process requires a Client to share location names (for example "The Rose Building"), Button names (for example "Room 312"), and contact information of the Client.
Buttons collect usage information. This usage information includes Button presses, response times, incident categories, and Button status.
The Sensors registration process requires a Client to share location names (for example "The Rose Building"), Sensor names (for example "4th Floor Bathroom"), and contact information of the Client.
Sensors collect usage information. This usage information includes Sensor alerts, response times, incident categories, and Sensor status.
The App does not require you to provide any Personal Data as a requirement to use it. You may, however, include Personal Data in your rescue plan and in communication with Supporters. Supporters using the App provide a username, contact information, and may include Personal Data in communication with other App Users, in which case, whenever a Supporter provides Personal Data, this Notice will be applicable to the Supporter as well.
As a Caller, if you choose to create a Rescue Plan in the App, and choose to share your contact information, we will only use the Personal Data provided in the Rescue Plan to allow potential rescuers to assist you. The Personal Data that you choose to provide in the App is stored only on the App and not on our server. In the creation of your Rescue Plan, you may be prompted to provide certain information, which may include your Personal Data, including address, emergency contact, and other preferences. You are never required to provide such information to use the App, but we can only activate help for you if this information is provided, either in a Rescue Plan or communicated verbally to the Supporter. Supporters are instructed to never retain your Personal Data, and if you have given Personal Data details verbally to a Supporter, Supporters are instructed to destroy these at the end of the call.
Anonymized App data may be used for training purposes.
You are also never required to provide third-party Personal Data to our App. If you choose to do so in order to fulfill your Rescue Plan (for example, by providing the name and phone number of a designated responder), you promise and agree that you have obtained all necessary and appropriate consent and authorization to share that information with us. The information you provide will also be subject to this Notice and how we handle Personal Data.
The App collects usage information. This usage information includes call duration, rescue operation status, anonymized app installation ID, connection information including network connection type and quality, device battery level, volume level and device operating system, rescue plan and operation status if a rescue is started. We collect app download statistics which are not traced back to a specific User or an identified person.
The App has the ability to record your geolocation only at the time of the creation of your Rescue Plan, but this setting is disabled by default. You may provide your location by enabling this setting but you are not required to do so. If you enable this setting, we may utilize location information in accordance with your Rescue Plan, if you created one; but the App does not continue to track your geolocation after the creation of your Rescue Plan, and it does not update or track your geolocation live. By enabling geolocation, you are agreeing that we can collect and use your location data under the Terms of this Notice, and also that you understand you can withdraw your consent at any time by contacting us.
We have no responsibility or liability for the functions of location settings within any device.
Finally, you understand that the information you provide via the App, by call, messaging, or in the Rescue Plan, may be accessible to Supporters. Supporters are volunteers (and not our employees or agents) that engage with our products to provide support (such as a conversation or a friendly ear) to Callers using the App. Supporters are instructed against sharing your Personal Data with third parties and outside of our internal systems. However, because anyone can volunteer as a Supporter, and we do not control the Supporters, you acknowledge and agree that by sharing any of your Personal Data with Supporters, we are not responsible for their use of your Personal Data. This is also true of Supporters who choose to share their Personal Data with the Callers that they are communicating with.
You agree to hold us (including our agents, our employees, directors, shareholders, and members), harmless against any claim in connection with the use of your Personal Data by Supporters, whether resulting from or caused by any negligent act, error, or omission, intentional misconduct, or breach of contract. If a court decides that we are responsible for such a claim, you agree that our liability is limited to any amounts that the owner of the Personal Data has paid us for our Services or products, and in any case, not more than one thousand Canadian dollars per occurrence. You also agree to hold us harmless against any claim in connection with the use of your Personal Data by the Clients of the Button, the Sensors, or the App, whether resulting from or caused by any negligent act, error, or omission, intentional misconduct, or breach of contract. If a court decides that we are responsible for such a claim, you agree that our liability is limited to a total of one thousand Canadian dollars.
We collect your Personal Data to understand your needs and offer you products and services that meet your changing needs.
We collect your Personal Data to determine your eligibility for our products and services.
We collect your Personal Data to operate and improve our products and services, to keep you informed about them, and to offer you new products and services.
We may collect and use your Personal Data for other purposes that further our business interests, but never at the expense of your privacy rights.We obtain consent to collect or use your Personal Data for a particular purpose where appropriate.
While using our services, you may also use services offered by other parties. The privacy notice does not apply to these third-party companies, so we recommend you check their privacy practices. You can contact us for an up-to-date list of companies that we contract for data Processing, if any.
We collect and Process your Personal Data to comply with legal, regulatory, or contractual requirements, and to ensure we Process data lawfully, fairly, and transparently, while ensuring respect for privacy and security of your data. We take reasonable steps to ensure that information is disposed of securely when we no longer require such data.
We also have a principled commitment not to keep or share any data that is not strictly necessary to the delivery of our services and will take all reasonable steps, at our discretion, to contest a mandate to disclose your Personal Data.
We may decide disclose limited Personal Data if doing so is necessary to (a) defend and bring legal actions; (b) if required by a government authority or legal process, but only after a final legal decision imposing such requirement on our company; (c) detect, prevent, or otherwise respond to fraud, security, or technical concerns; (d) support auditing and compliance functions; (e) when we believe disclosure is necessary or appropriate to prevent physical harm; or (f) in the good faith belief that disclosure is otherwise necessary.
We promise to follow data protection principles that ensure our Processing activities are lawful, fair, and transparent, and that we always consider your rights before Processing Personal Data.
Our Processing activities are limited to the purposes described in this Privacy Notice, and we only gather and Process the minimum amount of Personal Data required.
We will not store your Personal Data for longer than needed and will ensure the accuracy, integrity, and confidentiality of your data.
We use your Personal Data to prevent drug overdose fatalities and to assist in the provision of or connection to emergency services or community support.
We may also use your Personal Data to fulfill legal obligations, but we will only use anonymized data outside the scope of this Privacy Notice. If we Process your data for additional purposes, we will ensure that it furthers our goal of preventing overdose deaths and offer appropriate safeguards for Processing. To do this, we will ensure that:
We will inform you of any further Processing and purposes.
We use your Personal Data to provide our service to you. With your consent we use your Personal Data for the following purposes:
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymization and pseudonymization where suitable. We monitor our systems for possible vulnerabilities and attacks. If we share Personal Data with others, we subject them to strict contractual and legal controls regarding the protection, use, and disclosure of the information. If we share anonymous or de-identified data with third parties, we will contractually require them to keep it in de-identified form and forbid them to make any attempt to re-identify the data or allow others to do so.
Even though we try our best, we cannot guarantee the security of information. There is always some risk of unauthorized, wrongful, or illegal access to your information; however, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret, as we accept no liability for the mishandling of your username and password by you or third-parties which are not obligated to us under a separate agreement.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
For contractual purposes, by using the Brave Buttons, the Sensors, and the App, you (a) consent to receive all communications from us, including any possible newsletters or messages about security incidents, in electronic form via the App or, if applicable, via the email address you submit when you register, or, if applicable, via the phone number(s) you submit when your register, and (b) agree that all Terms, agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications would satisfy if they were in writing. Emails we send to you will contain an easy automated unsubscribe link so that you can opt-out of the subscription. Simply follow the indications in the email.
You have choices in the collection, use, and sharing of your personal information.
If you do not want us to have your information, do not register to use the Buttons, the Sensors, or the App. The Buttons, Sensors, and App systems link to other technology and may in due course allow you to connect with other applications and websites or apps. Please read the privacy statements of any websites that you visit. Brave is not responsible for the privacy practices or the content of any connected technology. If you want to review and correct your Personal Data, please contact us and we would be glad to assist you (see Contact Us, below).
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
We restrict the download of the App through the Apple App Store and Google Play to users over the age of 11.
We do not intend to collect or knowingly collect information from children. We do not target children with our services. We also do not exclude children or work to prevent them from being able to access our services. By allowing your child to access our services and any and all tools covered under this Notice, you acknowledge that you are aware of its contents and agree to be bound by it, including by releasing us from any liability or claims arising from it that can be legally released or waived.
Please contact us if you have any questions, comments, or complaints about privacy or how any information you send us may be used, if you are an EU citizen seeking erasure or access to your Personal Data, or if you want to opt out of receiving communications from us, at:
Brave Technology Co-Op
Phone: +1 (833) 833-2100
Address: 308 - 877 E Hastings St, Vancouver, BC V6A 3Y1
If you are not happy with the way we are handling your information, you have a right to make a complaint with Brave directly or with your local data protection supervisory authority at any time.
We ask that you please attempt to resolve any issues with us using the information in the Contact Us section above, before contacting the local privacy authority. We will make every effort to take appropriate action, including changing our policies and practices, as necessary.
If our efforts become insufficient to address your request, you may escalate it by connecting with the appropriate authorities. The Canadian data protection supervisory authority is the Privacy Commissioner's Office. In the EU, the data protection supervisory authority is contactable by email at email@example.com or by phone at +353 57 868 4800.
Modifications to this Privacy Notice that are editorial in nature or reflect changes in the services we offer will not require new consent. If we ever make material changes that would permit us to share your information more broadly than we have previously described, we will post public notices of the changes in the App and platforms, and we will default the settings to not share your information until we obtain your consent.
This Privacy Notice is effective 21 September 2023.