Last modified: September 28, 2023
1. Introduction
This Privacy Notice describes how Brazen collects and uses Personal Data about you through the use of our Website, and through email, text, and other electronic communications between you and Brazen.
Brazen Technologies, Inc. (“Brazen” or “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this notice.
This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect from you or that you may provide when you visit the website www.brazen.com (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- on our Website; and
- in email, text, and other electronic messages between you and our Website.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Brazen or any third-party, including any information collected from a user of a customer of Brazen utilizing Brazen’s virtual career fair and career education services (collectively, the “Services”), or from a participant of an event, on behalf of a Brazen customer through the websites events.brazen.com, https://appl.brazenconnect.com or support@brazenconnect.com.
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates.
2. Children Under the Age of 13
Our Website is not intended for children under the age of 16 and children under the age of 16 are not permitted to use our Website. We will remove any information about a child under the age of 16 if we become aware of it.
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or provide any information on our or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 16, please contact us at privacy@brazen.com.
3. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
Generally
We collect several types of information from and about users of our Website (“Personal Data”):
- by which you may be personally identified, such as name, e-mail address, login information, or any other identifier by which you may be contacted online or offline;
- that is about you but individually does not identify you, such as company or university name, traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and/or
- about your internet connection, the equipment you use to access our Website and usage details.
- directly from you when you provide it to us;
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- information that you provide by filling in forms on our Website. This includes information provided at the time of requesting a demo or for more information about our services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Website;
- information that you provide to us during a live chat;
- information stored in your social media profile that you authorize us to access when you use your social media profile to execute features on our Website, such as the ability to log into the Website using your social media profile credentials;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes; and
- details of events such as job fairs that you set up through our Website.
- details of your visits to our Website as described above; and
- information about your computer and internet connection, i.e. your IP address, operating system, and browser type.
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
We collect this information:
Information You Provide to Us
The information we collect on or through our Website is:
- information that you provide by filling in forms on our Website. This includes information provided at the time of requesting a demo or for more information about our services. We may also ask you for information when you enter a contest or promotion sponsored by us and when you report a problem with our Website;
- information that you provide to us during a live chat;
- information stored in your social media profile that you authorize us to access when you use your social media profile to execute features on our Website, such as the ability to log into the Website using your social media profile credentials;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes; and
- details of events such as job fairs that you set up through our Website.
The Personal Data we collect from you may be required to enter into a contract with Brazen, for Brazen to perform under the contract, and to provide you with our Services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
- details of your visits to our Website as described above; and
- information about your computer and internet connection, i.e. your IP address, operating system, and browser type.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to our Website.
Details about the automated data collection technologies and the specific cookies that we use can be found by following the link entitled “Cookies” on our Website or by clicking on the “cookie” icon, and adjusting your preferences in the cookie consent manager, which you may access by selecting the links. The cookie consent manager enables you to control the settings of the cookies that we set on your device and whether we collect information from them.
4. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
- provide our Website to you;
- provide you with information you request from us;
- enforce our rights arising from contracts; and
- notify you about changes.
We use information that we collect about you or that you provide to us, including any Personal Data:
- 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;
- maintain a chat history between you and our representatives;
- to provide you with information, products, or services that you request from us;
- to notify you about changes to our Website or any services we offer or provide through them;
- 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.
- in any other way we may describe when you provide the information;
- for targeted advertising purposes through the use of cookies, web beacons, and other similar technologies from third-party partners such as Google for measurement services, enhanced targeting of advertisements, and for marketing purposes,
- to fulfill any other purpose for which you provide it; and
- for any other purpose with your consent.
We may also use your information to contact you about our own services that may be of interest to you. If you wish to stop receiving information about such services, you may send us an email stating your request at privacy@brazen.com or click an “Unsubscribe” link on one of the emails that we have sent to you. For more information, see Choices About How We Use and Disclose Your Information.
5. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. We disclose your Personal Data to a few third parties, including:
- our subsidiaries and our affiliates;
- our third-party service providers that we use to support our business;
- to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These entities provide IT, infrastructure support services, and marketing/sales support;
- to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Brazen’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Brazen about our Website’s users is among the assets transferred;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information;
- to third-party vendors for targeted advertisements, and with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce or apply our Terms of Use and other agreements; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brazen, our customers, or others.
6. Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Additionally, you may manage the cookies that can be set on your browser by using the cookie consent manager. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Offers from Brazen. We may use your contact information to promote our services to you. If you wish to opt-out of such use, you may do so at any time by sending us an email stating your request to privacy@brazen.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or by selecting an unsubscribe link in the promotional email.
7. Accessing, Correcting, and Deleting Your Information
You may contact us to request access to, correct, or delete any Personal Data that we have collected about you.
You may contact us at the Contact Information below to request access to, correct, or delete any Personal Data that we have collected about you. We may not accommodate a request to change your Personal Data if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
8. Jurisdiction-Specific Privacy Rights
The law in certain jurisdictions may provide their residents or individuals located in those jurisdictions with additional rights regarding our use of your Personal Data.
The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Website Privacy Notice.
For Individuals Located within the European Economic Area
If you are located in the European Economic Area, you have the additional rights described in our GDPR Privacy Addendum.
Your California Privacy Rights
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Services that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please send contact us through the contact information below.
Our California Privacy Notice is available for review here[1] .
9. Do Not Track Signals
We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.
Our Website may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers or operating systems permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Users may opt-out of Online Behavioral Advertising tracking but utilizing the Digital Advertising Alliance (DAA) WebChoices tool, available at https://optout.aboutads.info/.
10. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password used to access our services confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
11. Changes to Our Privacy Notice
We will post any changes to our Privacy Notice on our Websites. If we make material changes to our Privacy Notice, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Website’s home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.
12. Contact Information
If you wish to contact us, you may contact us through the contact information below.
If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below.
To Contact Brazen
Brazen
4075 Wilson BLVD
8th Floor
Arlington, VA 22203
United States
(703) 947-0787
privacy@brazen.com
Brazen GDPR and UK-GDPR Privacy Addendum
Last modified: September 28, 2023
1. Introduction
This GDPR Privacy Addendum supplements the information in the Brazen Privacy Notice and applies to Personal Data about individuals located in the European Economic Area.
This GDPR Privacy Addendum (the “GDPR Privacy Addendum”) supplements the information contained in the Brazen Privacy Notice and applies solely to all users of our Website who are located in the European Economic Area, the United Kingdom, or Switzerland. We adopt this GDPR Privacy Addendum to comply with the General Data Protection Regulation (2016/679) and any implementing acts of the foregoing by any of the member states of the European Economic Area, the United Kingdom (including the UK-GDPR), or Switzerland (collectively, the “GDPR”) and any terms defined in the GDPR or our Privacy Notice have the same meaning when used in this GDPR Privacy Addendum. When applicable to you, this GDPR Privacy Addendum takes precedence over anything contradictory in our Privacy Notice.
2. Data Controller, Data Protection Officer, and Representative
Brazen is the data controller of the Personal Data you provide on the Websites. Brazen has appointed a Data Protection Officer and a representative in the EU.
Brazen is the data controller of your Personal Data. Brazen has appointed a Data Protection Officer and representatives in the European Economic Area and the United Kingdom in compliance with the General Data Protection Regulation. Brazen, its Data Protection Officer, or its representatives may be contacted in any manner set forth below in the “Contact Information” Section of this GDPR Privacy Addendum
3. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
If you are in the European Economic Area or the United Kingdom, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):
- Consent. By using our Website, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Notice. If you do not consent to this Privacy Notice, please do not use the Website;
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between Brazen and you; detect and correct bugs and to improve our Website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; perform risk assessments; provide our live chat functionality; and provide information about our services to you;
- To Fulfill Our Obligations to You under our Terms of Use. We process your Personal Data in order to fulfill our obligations to you pursuant to our terms of use for our Website.
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
4. Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data.
Brazen does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you.
5. Automated Decisions Making
We generally do not use your Personal Data with any automated decision making processes.
Brazen does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.
6. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.
- Access and Update. You may notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide Brazen is processed based on your consent and that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We will only delete your Personal Data when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. If you reside in the United Kingdom you must lodge any complaint with the Information Commissioner’s Office. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law
7. Consent to Processing of Personal Data in the United States
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area or the United Kingdom, in order to provide our Website to you, we may send and store your Personal Data outside of the European Economic Area or the United Kingdom, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of your Personal Data outside the country where you reside or are located, including in the United States.
Your Personal Data is transferred by Brazen to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. To ensure your Personal Data is treated in accordance with this Privacy Notice, Brazen uses Data Protection Agreements between Brazen and all other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European Commission (the “Standard Contractual Clauses”). The European Commission has determined that the transfer of Personal Data pursuant to the Standard Contractual Clauses may provide for an adequate level of protection of your Personal Data, but may need to be supplemented with additional measures on a case-by-case basis. When we believe this to be appropriate and necessary, these Standard Contractual Clauses have been supplemented in this way. Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third party. You may request a copy of the Data Protection Agreement by contacting us through the Contact Information below.
8. Data Retention Periods
We retain your Personal Data for as long as reasonably needed to fulfill the purposes for which we collected or obtained it. We use reasonable business criteria to establish retention periods for your personal information. For example, if you provide your information for a demo, we will store your personal information for so long needed to fulfill your request, enforce any applicable terms that govern your use of our Website, and maintain appropriate records. In some instances, we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
Brazen may retain your Personal Data:[1] [RG2]
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely
9. Changes to this GDPR Privacy Addendum
We will post any changes to this GDPR Privacy Addendum on our Websites. If we make material changes to this GDPR Privacy Addendum, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
We reserve the right to amend this GDPR Privacy Addendum at our discretion and at any time and at any time and as further described in our Privacy Notice. When we make changes to this GDPR Privacy Addendum, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
10. Contact Information
You may contact us through the contact information below. If you wish to contact us, you may contact us through the contact information below.
If you have any questions, concerns, complaints or suggestions regarding this GDPR Privacy Addendum, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact us directly via the contact information in the Privacy Notice. If you wish to contact our Data Protection Officer or our representative in the European Union, you may do so at the contact information below.
To Contact Our European Union Representative
DataRep
The Cube, Monahan Raod, Cork, T12 H1XY
Republic of Ireland
To Contact Our United Kingdom Representative
DataRep
107-111 Fleet Street
London, EC4A 2AB
United Kingdom
To Contact Our Data Protection Officer
Brian Clark
4075 Wilson Blvd.
8th Floor
Arlington, Virginia 22203
United States
(703)879-8029
DPO@brazen.com
