Privacy—yours and all of our users’—is very important to us. This privacy policy explains how personal information is used and protected. Information requested or provided other than through the Brave Button System (the “Buttons”) will contain separate privacy terms and conditions. This statement explains how we deal with personal information that is obtained via the Buttons. We respect the privacy of our users and ensure that any personal information we receive or transmit will be protected and treated confidentially.
Brave’s CEO, Gordon Casey, is in charge of protecting personal information and, accordingly, also serves as our Privacy Officer. You can reach him in this capacity via dataprotection@brave.coop or over the phone at 1-833-833-2100.
Personal Data – any information relating to an identified or identifiable natural person.
Processing – 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.
We/us (either capitalized or not) – Brave Technology Co-Op.
We promise to follow the following data protection principles:
The User has the following rights (applies to EU citizens only):
The Button registration process may require individual users to share their location and phone numbers, sign waivers or acknowledgement of acceptance of terms and conditions. Users of the Buttons may also choose to provide additional identifying information at registration and through feedback, whether offered or solicited by Brave or an industry partner such as a health authority, housing provider or other body providing services to the User. In addition, Button users may opt to use other services offered by Brave, which will be subject to a similar Privacy Policy and additional terms of use.
When using the Site, you may also use the services offered by other parties. This privacy policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. Please check the privacy practices of these other companies or persons (if any) to understand how they treat the personally identifiable information that you provide to them and contact them if you have any concerns.
We use your Personal Data to provide our service to you. With your consent we use your Personal Data for the following purposes:
We may also Process your Personal Data in order to fulfill an obligation arising from law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized.
We might Process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. While we are reserving the right to use your data for additional purposes, we will ensure that those uses further our purpose of preventing accidental drug overdose deaths and offering services to people who reach out to us for this purpose. To do this, we will ensure that:
We will inform you of any further Processing and 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 anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. If we share personal information 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 that 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.
We may use cookies, web beacons, and similar technologies to help us verify your identity upon return to our technology, and improve your user experience with our services. No other parties will be able to collect your personally identifiable information while they are using the Buttons or using our services. Where applicable, we will not collect personally identifiable information about your activities over time and across third-party web sites or online services whether or not we receive a Do Not Track signal.
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. In the event that the Buttons use Cookies, only we will be able to access those cookies. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
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, you (a) consent to receive all communications from us, including any possible newsletters or messages about security incidents, in electronic form via your account in the Site or, if applicable, via the email address you submit when you 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 Button system links 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 information, please contact us and we would be glad to assist you (see Contact Information, below).
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Please contact us if you have any questions or comments about privacy, about 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
Email: dataprotection@brave.coop
Address: 308 - 877 E Hastings St, Vancouver, BC V6A 3Y1
It is your right to contact the Supervisory Authority should you have concerns, question, or need help enforcing your legal rights (EU citizens only).
Email: info@dataprotection.ie
Phone: +353 57 868 4800
Modifications to this Privacy Policy 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 ask you to consent to the new Privacy Policy before it applies to you.
This Privacy Policy is effective 3 February 2019.