Updated May 25, 2018
Brazen Technologies, Inc. (“Brazen,” “we” or “our”) is committed to protecting and respecting your privacy. Brazen’s chat-based event platform (the “Service”) helps the world’s leading companies, universities and member organizations enable valuable, scalable conversations for their constituents, connecting recruiters to job candidates, current students to successful alumni, and organizational members on one continent to another in chat-based events.
The Information We Collect
Information You Voluntarily Provide Us: We may obtain information about you that you submit voluntarily, including when you call or email us or communicate with us through social media, submit a website form requesting information about Brazen or our Service, or when you participate in an Event. An “Event” is an online gathering that includes registration before the event begins, activities between the event’s start and end time, and after the event’s end time. This information is “Personal Information” since it identifies you. Our legal basis for processing this information is your consent.
The types of this information we may obtain include:
- Information that identifies you, such as your name, password, email address, address, phone number(s), and photographic image.
- Demographic Information, such as zip code, country, years of work experience, skills, industry, certifications, degrees, etc. We do this to help you connect with other event participants.
- Preference Information, such as preferred time zone or whether to show a dialog on your next visit. We do this to personalize your experience on the Sites.
- If you are accessing the Service on behalf of a Customer, you may provide certain information when you register, for example, your organization’s name, email address, and password.
- Information collected from Customers in order to manage billing, including credit card numbers and associated billing information. We refer to this information as “Billing Information”.
- Information stored in your social media profile that you authorize us to access when you use your social media profile to execute features on the Service, such as the ability to log into the Service using your social media profile credentials.
Automatically-Collected Information: Whether you are a Visitor visiting our Website or acting on behalf of a Customer as part of the registration process, or a participant in an Event or other Constituent of a Customer using the Service, we may collect certain information by automated means. The information we may collect by automated means includes:
- Information about the devices you use to access the Service or our Website (such as the IP address and the device, browser and operating system type).
- Pages and URLs that refer visitors to our Website or the Service, also pages and URLs that visitors exit to once they leave the Service or our Website.
- Dates and times of visits to the Service or our Website.
- Information on actions taken on the Service or our Website (such as page views, site navigation patterns or application activity).
- A general geographic location (such as country and city) from which a visitor accesses our Website.
- Search terms that visitors use to reach our Website.
- Anonymous information, such as pages visited, and time on the Service or our Website.
- Cookies and web beacons, as described more fully below under “About Cookies, Web Beacons, Tracking Choices and Third Party Service Providers”.
Our legal basis for processing this information is your consent and our legitimate interests, namely monitoring and improving our Website and the Service.
How We Use the Information We Collect
We may use the information we obtain about you to:
- Create, manage and maintain your account on the Service.
- Provide you with services that you request.
- Manage your participation in Events hosted on the Service, where you have signed up for such Events.
- Maintain a record of the Events in which you participate, including chat history.
- Transcribe and make available conversation history to both parties involved in a conversation.
- Enable you to interact with other Event participants.
- Provide administrative notices or communications applicable to your use of the Service and the Website (which are not subject to opt out).
- Respond to your questions and comments and provide customer support.
- Operate, evaluate and improve our business and the products and services we offer.
- From time-to-time, to market to you our products and services and those of our affiliates, partners and third parties.
- Analyze and enhance our marketing communications and strategies (including by identifying when emails we have sent to you have been received and read).
- Analyze trends and statistics regarding visitors’ use of the Service and the Website, mobile applications and social media assets, and the jobs viewed or applied to on our Service.
- Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users.
- Comply with applicable legal requirements and industry standards and our policies.
Aggregated / Anonymous information. We may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service. Information that is in “aggregate / anonymous” form refers to non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly.
About Cookies, Web Beacons, Tracking Choices and Third Party Service Providers
A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon” is also called a Web bug or a pixel tag or a clear GIF. Used in combination with cookies, a web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, that is placed on a Web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail.
The companies that provide third-party tools and services such as commenting operate under their own privacy policies and Brazen encourages you to be aware of the privacy policies of such companies. Brazen does not have control over or access to any information contained in the cookies that are set on your computer by third party tool providers.
There are many resources on the Internet that can provide you guidance regarding how to see what cookies have been set and how to manage and delete them, including https://en.wikipedia.org/wiki/HTTP_cookie, www.allaboutcookies.org, or www.aboutcookies.org.
(Disclosing Personal Information to Third Parties)
We will offer you the opportunity to choose whether your Personal Information is to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you.
We do not request or knowingly receive or collect Sensitive Personal Information. Nonetheless, if at any point in the future we receive or collect Sensitive Personal Information you, we will not process such information about you for purposes other than those for which the information was originally obtained or subsequently authorized by you unless you explicitly consent to the processing, or as required or permitted, or where not prohibited by law or regulation. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, biometric data where processed to uniquely identify a person, any information that concerns medical or health conditions or sex life, or information relating to the commission of a criminal offense.
The Information We Share
When you create an account on the Service, Brazen will collect and retain information about you, some of which is Personal Information.
Information you provide when registering for an Event hosted on the Service is collected by Brazen, and is shared with the company(ies) participating in the Event. This information includes Personal Information such as your name, email address, resume and other questions you answer during the registration process. This information also includes the conversation history from conversations with any other participants and organizations. If providing information for an Event, this information may become subject to the policies of the respective company(ies) participating in the Event after it has been shared, and Brazen is not responsible for these policies. Providing additional information beyond what is required at registration is entirely optional, but enables you to better identify yourself.
We may share your information with third party contractors or service providers to provide you with the services that we offer you through our Sites; to provide technical support; or to provide specific services in accordance with your instructions. We require that these third parties not use your information other than to provide the services requested by Brazen.
We may also disclose specific user information when we determine, in good faith, that such disclosure is necessary to comply with applicable law, to cooperate with or seek assistance from law enforcement, to prevent a crime or protect national security, or to protect the interests or safety of Brazen, our Customers and/or other users of the Services.
You should be aware that any information you submit on the Service may be read, collected, or used by other users of Brazen, and could be used to send you unsolicited messages. In addition, any information you submit in an Event can be read, collected, or used by participating companies, and could be used to send you unsolicited messages. We are not responsible for the information you choose to submit on the Service or the Website.
Aggregated / Anonymous information. We may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service.
Opting Out of Marketing Communications
If you receive marketing or promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact Us” section.
HOW WE PROTECT PERSONAL INFORMATION
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the Personal Information we process, Brazen maintains appropriate administrative, technical and physical safeguards to protect Personal Information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Information.
Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail, or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect, that your Personal Information will always remain private. As a user of the Website and the Service, you understand and agree that you assume all responsibility and risk for your use of the Website and the Service, the internet generally, and the documents you post or access and for your conduct on and off the Website and the Service. If you believe your Personal Information has been compromised, please contact us as set forth in the “Contact Us” section.
To further protect yourself, you should safeguard your Brazen Connect account username and password and not share that information with anyone. You should also log off from Brazen Connect and close your browser window when you have finished your visit to our Service. Please note that we will never ask for your Brazen Connect account password via email.
We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
ACCOUNTABILITY FOR ONWARD TRANSFER
We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of Personal Information from the European Economic Area (“EEA”) and Switzerland.
DATA INTEGRITY AND PURPOSE LIMITATION
We endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. We will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by us for as long as we retain possession of such information. Our personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. When acting as a provider of our Service to our Customers, we endeavor only to process Personal Information that is relevant to our Service, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.
ACCESSING AND CONTROLLING YOUR INFORMATION
EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant controller, since the controller has primary responsibility for your Personal Information.
(For Constituents of our Customers who register for Events through our Service) When acting as a provider of our Service to our Customers, we will process your Personal Information to help administer Events on behalf of our Customers, and we are not responsible for the continued accuracy any Personal Information provided. Any questions that you may have relating to your Personal Information and your rights under data protection law should therefore be directed to the relevant Customer (the controller) who has organized the Event, not to Brazen. We will assist our Customers in fulfilling their obligations under applicable law to respond to such requests by individuals to correct or update their Personal Information.
Notwithstanding the foregoing, Constituents of our Customers who register for Events through our Service may access, update and amend certain Personal Information included in your online account at any time prior to the conclusion of an Event by logging into your account and making the necessary changes. You can decide what information to make available to other participants when you register for an Event, participate in a chat, or post or reply to comments. You may choose to deactivate your account at anytime. When you deactivate your account, you will be logged out of Brazen Connect and you will no longer be able to log into Brazen Connect to view Events you attended or the chats you had with other participants. Furthermore, we will only delete registrations you have started or completed for upcoming Events. We will not delete information you provided when registering for or participating in a concluded Event as this information has already been shared with other participants that you engaged with in a chat or message board conversation.
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
RECOURSE, ENFORCEMENT AND LIABILITY
Disputes and Choice of Law and Location for Resolving Disputes
The laws of Virginia govern this contract and any claim or dispute that you may have against us, without regard to Virginia’s conflict of laws rules, and that the United Nations Convention on Contracts for the International Sale of Goods shall have no applicability. Any disputes or claims that you may have with or against us will be resolved exclusively by a court located in Arlington County, Virginia, and you agree and submit to the exercise of personal and subject matter jurisdiction of the federal and state courts located in Arlington County, Virginia for the purpose of litigating any such claim or action.
We do not intentionally gather information about users who are under the age of 13. If you are under the age of 13, you are not authorized to use the Service.
Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.