Privacy Notice for California Residents

Last modified: September 28, 2023

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in Brazen Technologies Inc. (“we,” “our” or “us”) Website Privacy Policy: https://www.brazen.com/website-privacy-policy, and applies solely to all visitors, users, and others who reside in the State of California (“Consumers,” “your” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

This Privacy Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (collectively, “Work-Related Entities.” Please see Brazen Technologies Inc.’s separate Privacy Notice for Work-Related Entities.

Other California Privacy Rights

Generally, California’s “Shine the Light” law (Cal. Civil Code Section § 1798.83) permits California residents that have a direct business relationship with Brazen Technologies Inc. to request certain information regarding our disclosure of Consumer Personal Information to third parties for their own direct marketing purposes over the preceding year unless we meet certain exceptions. This Privacy Notice and our Website qualify for the exceptions and provide how consumers may opt-out of any such disclosure and use. If you are a California resident and have a direct business relationship with us and have questions regarding our policies under the Shine the Light Act, please send an email to privacy@brazen.com or write us at: Brazen, 4075 Wilson Blvd., 8^th Floor, Arlington, VA 22203. You must state “Shine the Light Act Request” in the subject matter of the email, or add “Attn: Shine the Light Act Request” to the postal mail envelope. We do not accept inquiries by telephone or via any other means.

Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA),clinical trial data, or other qualifying research data
• Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To maintain a chat history between you and your representatives;
• To provide you with information, products, or service that you request from us;
• To notify you about changes to our Website or any services we offer to provide through them;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users and customers is among the assets transferred.
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling 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 (also called a data portability request).
• If we disclosed your Personal Information for a business purpose, we will identify the types of Personal Information that each category of recipient obtained.
• 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• 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.
• 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:
  • Email Address Verification
• Identity Verification by providing last event attended.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

In particular, we have collected the following categories of Personal Information from

Consumers within the last twelve (12) months. The broad list of examples below does not necessarily apply to each individual Consumer:

We obtain the categories of Personal Information listed above from the following categories of sources:

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information

We may disclose your Personal Information to a third party for a legitimate business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep the Personal Information confidential, and not use it for any purpose except performing the contract. Our Service Providers also meet the other contractual requirements under the CCPA and its implementing regulations. In the preceding twelve (12) months, Brazen has disclosed Personal Information to the categories of third parties indicated in the chart below.

Your Rights and Choices

The CCPA provides Consumers 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 our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights in this Privacy Notice, and the associated section in our Privacy Policy), we will disclose to you:

We do not provide these access and data portability rights for Work-Force Related Entities.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers, vendors and data aggregators to delete) your Personal Information from our records, unless an exception applies or there are legitimate business reasons for retaining such information.

We will deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

We do not provide these deletion rights for Work Related Entities. Please see Privacy Notice for Work Related Entities for details.

Exercising Access, Data Portability, and Deletion Rights

To exercise the Consumer access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:

Website: [https://www.brazen.com/contact]

Postal Address:

Brazen Technologies Inc.
Attn: Privacy Department at Brazen Technologies Inc.
4075 Wilson Blvd.
8 Floor
Arlington, VA, 22203

Email: privacy@brazen.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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.

Response Timing and Format

We endeavor to substantively respond to a verifiable consumer request within forty-five (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 that account. If you do not have an account with us, we will deliver our written response by postal 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 will not provide a substantive response to an excessive, repetitive, or manifestly unfounded request. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request, otherwise we will not charge a fee to process or respond to a verifiable consumer request.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell or share your Personal Information at any time (the "right to opt-out"). We do not sell or share the Personal Information of Consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old.

Consumers who opt-in to the sale of Personal Information may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by clicking on the button below:

Once you request that we not sell or share your Personal Information, we will wait at least twelve (12) months before asking you to reauthorize the sale or sharing of Personal Information. However, you may change your mind and opt back into Personal Information sales or sharing at any time.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the Website and update the effective date. Your continued use of our Website following the posting of changes to the Privacy Notice will constitute your acceptance of such changes, unless additional steps are required by applicable law.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which Brazen Technologies Inc. collects and uses your information described here and in Brazen’s Website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: [https://www.brazen.com/contact]

Postal Address:

Brazen Technologies Inc.
Attn: Privacy Department at Brazen Technologies Inc.
4075 Wilson Blvd.
8th Floor
Arlington, VA, 22203

Email: privacy@brazen.com

If you need to access this Privacy Notice or our Website Privacy Policy in an alternative format, please contact privacy@brazen.com or 703-947-0787.