- Acquired information
The information that we obtain in order to achieve the purposes of use in Section 4 (the “Acquired Information”) includes the following;
(1) Personal information as exemplified below (“Personal information” as defined in the Act on the Protection of Personal Information)
(i) Name, date of birth, gender, occupation (including job title), and other information that may identify a specific individual
(ii) Information such as address, telephone number, account information (i.e., e-mail address and password), nickname, etc., which is used in connection with specific Personal information
(iii) Credit card information, payment information such as crypto currency and blockchain wallet addresses
(iv) Hobbies, family structure, age, and other personal attribute information that is integrated with Personal information
(v) Information related to identity verification
(vi) Information about the Users obtained in connection with your use of the Services
(2) Information related to the use and browsing of the Services by the User, such as the content of the Services used by the User, the date, time and number of times used, and the User’s online behavior when using the Services (including information related to the User’s communications, such as cookie information, access logs and other information related to usage status, device information used, location information, IP address, browser information, browser language, etc.)
(3) Information regarding the payment status of the Users and the Partners in relation to the Services or business relationships.
(4) When the User has permitted linkage with external services such as social networking services when using the Services, the ID used by the User on such external services and information that the User has permitted to be disclosed to the linked party according to the privacy settings of such external services
- Method of collecting the Acquired Information
BraveEU will collect Acquired information through the following methods;
(1) The User input on the Services directly;
(2) The User provide the information to BraveEU in person, by e-mail, mail, in writing, or by telephone, etc. (When answering the phone with the User, BraveEU may record such call to improve the quality of the response, etc.);
(3) Methods to collect information when the User uses or browse the Services; or
(4) Indirect collection from business partners and third parties.
- Management of the Acquired Information
Those who are engaged in the management and use of the Acquired Information in BraveEU will strictly manage the Acquired Information and will take sufficient care in handling the Acquired Information to prevent unauthorized access, loss, leakage, or falsification of Personal information.
- Purpose of use of the Acquired Information
(1) For identity verification
(2) To communicate and provide information on various matters related to the Services
(3) To provide the Services
(4) To simplify the input of information required for the Users registration for the Services
(5) To link information between the Services that the Users has applied for
(6) To confirm applications for e-mail delivery services and to deliver e-mails
(7) To confirm and deliver purchases related to the Services
(8) To confirm billing and payment for the Services
(9) To send you rewards for your cooperation in surveys, etc.
(10) To send prizes for prize competitions, etc. to which you have applied.
(11) To survey and analyze the usage of the Services
(12) To improve and enhance the Services to better satisfy our customers or to develop new services.
(14) To customize the contents of the Services to suit the Users.
(15) To survey the level of satisfaction with the Services
(16) To aggregate and publish the results of the survey of the information which is statistically processed from the Acquired Information.
(17) To send information and notices about the Services, new services, and other various services
(18) To request cooperation for surveys and participation in various events, and to report the results of such surveys and events.
(19) To distribute or display advertisements of BraveEU or third parties
(20) To distribute or display product information within services provided by BraveEU or third parties
(21) To resolve problems in the operation of the Services and to comply with laws and regulations
< Personal information (name, affiliation, contact information, etc.) related to the Partners>
(1) To communicate, consult, place and receive orders, settle payments and execute and manage other transactions with BraveEU
(2) To manage customer information
(3) To prevent fraudulent activities that interfere with normal transactions
(4) To send information and notices regarding the Services, new services, and other various services
(5) To resolve problems related to transactions and to comply with laws and regulations
< Personal information regarding applicants who have applied for or participated in our recruitment activities>
(1) To provide information on recruitment and job openings, to conduct employment screening, and to confirm application histories.
(2) To communicate with applicants and respond to inquiries from applicants
(3) To provide information on recruitment-related events and seminars operated by BraveEU
(4) To prepare statistical data for use in the formulation of our future recruitment policy, etc.
(5) To resolve problems related to recruitment and to comply with laws and regulations
< Personal information concerning our directors, employees, retirees and their family members (hereinafter collectively referred to as the “Employees, etc.”)>
(1) To notify and communicate with the Employees, etc.
(2) To manage the employment of the Employees, etc. (payment of compensation, etc., performance of personnel and labor management, provision of benefits, etc.)
(3) To manage the health of the Employees, etc. and to ensure an appropriate working environment
(4) To provide benefit services to the Employees, etc. and to handle various insurance procedures, etc.
(5) To submit notifications and reports to government and other public offices concerning the Employees, etc.
(6) To resolve problems related to the Employees, etc., and to comply with laws and regulations
- Joint use
BraveEU may jointly use the Acquired Information as follows;
(1) Scope of joint use
Our group companies (for details, please click here)
(2) Purpose of use
・ To be used by our group companies for the same purposes as described in section4.
・ To communicate and hand over information to company in charge in the event of an inquiry, application for use, or other request regarding the products or services provided by BraveEU or our group companies.
・ For management and internal administration of our group companies.
(3) Items of Personal information to be jointly used
Name, date of birth, address, gender, telephone number, account information, nicknames and other information, SNS account information, transaction details (including information on service usage, purchase history, payment information such as credit card information or wallet address, payment status, etc.), etc.
(4) Responsible for the management of Personal information used jointly
Brave group Europe Inc. (for details, please click here)
- Provision of the Acquired Information to third parties
BraveEU will provide the Acquired Information to third parties within the scope permitted by law in the following cases;
(1) Providing information on the Services in order to provide the Services.
(2) When providing information to delivery companies, settlement agents, subcontractors, or other third parties for the purpose of product delivery, payment settlement, response to inquiries from the Users, inquiries from BraveEU to the Users, provision of related after-sales services, etc.
(3) When requested by a court, administrative agency, supervisory authority, or other public agency to provide the Acquired Information in accordance with laws and regulations.
(4) When BraveEU deems it necessary to provide information in order to resolve disputes with third parties or to protect the rights or interests of the Users or third parties
(5) When providing information to a third party to whom BraveEU outsource such research and analysis in order to research and analyze the usage of the Services
(6) When the information is provided to a third party for the purpose of distributing or displaying advertisements of BraveEU or a third party
(7) When BraveEU deems it necessary to provide the Acquired Information and has obtained the User’s consent
(8) Other cases in which the provision of information to a third party is permitted by law.
- Outsourcing of handling of the Acquired Information to third parties
To the extent necessary to achieve the purpose of use stipulated in Section 4, BraveEU may outsource all or part of the handling of the Acquired Information to subcontractors. In such cases, BraveEU will thoroughly screen such subcontractors to ensure that they meet our standards for selecting subcontractors, and ensure that the Acquired Information is properly managed in making the contract.
- Personally relevant information
For the purpose of maintaining and protecting the convenience improvement sessions such as automatic input of e-mail addresses when logging in to the Services, for security protection, and for researching and analyzing the usage of the Services and the effectiveness of advertisements related to the Services, BraveEU may acquire cookies, device type, device identifier, browser type, referrer, IP address, and other advertising identifiers (collectively, the “Personally Relevant Information”) by incorporating information collection modules selected by us, such as Google Analytics.
Google Analytics Terms of Service
Google Analytics Opt-out Add-on:
- Retention of Personal Information
BravEUe will retain the Acquired Information to the extent necessary for the purposes stated in “Purpose of use of the Acquired Information”
The criteria for determining the retention period includes, but is not limited to: (i) the duration of the contractual relationship between you and BraveEU; (ii) the legal obligations assumed by BraveEU; and (iii) a need to perform an agreement to which you are a party.
- Information of minor users
- Procedures for Disclosure, Correction, Suspension of Use, etc. of Personal information
BraveEU will accept requests for disclosure, correction, deletion, or suspension of use (the “Disclosure, etc.”) of Personal information (including records of provision of Personal information to third parties) on the Services only from the person himself/herself or his/her representative in accordance with the prescribed procedures separately stipulated by BraveEU. However, BraveEU may not be able to perform these procedures if BraveEU is not obligated to do so under the Act on the Protection of Personal Information or other laws and regulations, if the same request is repeated many times without justifiable reason, or if excessive technical work is required.
In addition, when requesting disclosure of personal information, you may be required to submit identification documents and pay a disclosure fee in accordance with our separate regulations.
- Contact for inquiries
If you have any opinions, questions, complaints, or other inquiries regarding our handling of acquired information, please contact us at the following address.
3.25 East London Works, 75 Whitechapel Road, London E1 1DU
Brave group Europe Inc. Personal information contact
Supplementary Provisions for Processing of Personal Information of EEA and UK Residents
The following supplementary provisions apply to the processing of personal information (meaning information relating to an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person) of residents in the European Economic Area (the “EEA”) and the United Kingdom in accordance with the General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (the “UK GDPR”).
- Legal Basis for Processing Personal Information
(1) Such processing is necessary for the performance of a contract to which you are a party or in order to respond to your request prior to entering into a contract; or
(2) Such processing is necessary for the purposes of the legitimate interests pursued by BraveEU or any third party (including, without limitation, interests such as those pertaining to the provision of services by BraveEU).
Where provision of your personal information is mandatory and you choose not to provide the same, then BraveEU will not be able to provide you with the relevant services.
You may withdraw your consent via the contact point for inquiries provided above; provided, however, that the consent which you have provided for BraveEU’s collection, use and provision of your personal information will remain valid until such time as this consent is withdrawn by you.
- International Transfer of Personal Information
BraveEU may transfer your personal information to countries other than your country of residence, including, without limitation, Japan and the United States, for storage or other processing. Please note that the laws and regulations of such countries or regions may provide a lower level of data protection than those in your country of residence. In such cases, BraveEU will take the appropriate measures to protect your personal information in compliance with our legal obligations.
As required under the GDPR or the UK GDPR, BraveEU protects your personal information by entering into Standard Contractual Clauses (Article 46(2) of the GDPR) regarding the transfer of your personal information outside the EEA or the UK. If you would like to review the Standard Contractual Clauses, please contact us as described via the contact point for inquiries.
- Your Rights Under the GDPR or the UK GDPR
You have the right to request BraveEU: (i) for a copy of your personal information; (ii) to revise, delete or restrict the processing (suspend the use) of your personal information; and (iii) to provide you with the personal information you have provided to BraveEU for a contract or based on your consent, in a structured, machine-readable format.
In addition, you may object to the processing of your personal information in certain circumstances (in particular, where BraveEU is processing the information for direct marketing purposes).
However, these rights may be limited, for example if fulfilling your request would reveal personal information of a third party or would infringe upon the rights of a third party (including BraveEU’s rights), or if BraveEU is required by law to retain or has legitimate interests in retaining your personal information. Relevant exemptions are included in applicable laws on privacy. BraveEU will inform you of the relevant exemptions which BraveEU relies upon when responding to any request you make.
If you wish to exercise any of these rights, please contact BraveEU via the contact point for inquiries. If you have any unresolved concerns, you may lodge a complaint with an EU or UK data protection authority having jurisdiction over the area in which you live or work, or where you believe a breach may have occurred.
Supplementary Provisions for Processing of Personal Information of U.S. California Residents
The following supplementary provisions apply to the processing of personal information (any 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; the same shall apply to these supplementary provisions hereinafter) of U.S. California residents in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA; collectively, the “California Privacy Laws”).
- Information Collected by BraveEU
BraveEU has collected in the last twelve (12) months and will continue to collect the following categories of personal information from you for the purposes stated in “Purpose of use of the Acquired Information.”
Identifiers Name, date of birth, gender, occupation (including job title), address, telephone number, account information (i.e., e-mail address and password), nickname, hobbies, family structure, age
Commercial information Credit card information, payment information such as crypto currency and blockchain wallet addresses, payment information for the Services or our transactions
Internet or other electronic network activity information Information related to the use and browsing of the Services by the User, such as the content of the Services used by the User, the date, time and number of times used, and the User’s online behavior when using the Services (including information related to the User’s communications, such as cookie information, access logs and other information related to usage status, device information used, location information, IP address, browser information, browser language, etc.)
Professional or employment-related information Information regarding the department in or company by which you are employed (company name, address, telephone number)
Sensitive personal information Credit card number, ID and password
- Disclosure of Personal Information
BraveEU may disclose your personal information (including sensitive personal information; the same shall apply to these supplementary provisions hereinafter) to third parties for business purposes. When disclosing personal information to a service provider or contractor for such purpose, BraveEU executes an agreement that indicates such purposes and requires that the service providers or contractors keep such personal information confidential and not use personal information for any purpose except performing such agreement.
BraveEU has shared or disclosed personal information to the following categories of third parties for business purposes during the last twelve (12) months:
(1) Our group companies (for details, please click here); and
[Purposes of sharing and disclosure]
・ To be used by our group companies for the same purposes as described in “Purpose of use of the Acquired Information.”
・ To communicate and hand over information to a company in charge in the event of an inquiry, application for use, or other request regarding the products or services provided by BraveEU or our group companies.
・ For management and internal administration of our group companies.
(2) Delivery companies, settlement agents, subcontractors, or other third parties.
[Purposes of sharing and disclosure]
・ For the purpose of product delivery, payment settlement, response to inquiries from the Users, inquiries from BraveEU to the Users, provision of related after-sales services.
・ To research and analyze the usage of the Services
- Sale or Sharing of Personal Information
BraveEU has not sold any personal information in the preceding twelve (12) months.
In the preceding twelve (12) months, BraveEU has distributed cross-text behavioral advertisements by sharing online identifiers, etc. collected from you with advertising companies, etc. If you do not wish for cross-context behavioral advertisements to be distributed, please perform the procedures described in “Do Not Share My Personal Information.”
In these supplementary provisions, the term “sale” means disclosing, etc. your personal information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your personal information to a third party for cross-text behavioral advertisements, regardless of monetary or other valuable consideration.
- Your Rights and Choices Under the California Privacy Laws
The California Privacy Laws grant rights regarding personal information to consumers who are residents of California. The following describes your rights and how to exercise those rights under the California Privacy Laws.
(1) Right to Access Specific Information
You have the right to request that BraveEU disclose certain information to you in relation to the collection, sharing, disclosure, or use of your personal information by BraveEU. Upon receipt and confirmation of your verifiable consumer request, BraveEU will disclose to you any or all of the following information:
(i) The categories of your personal information that BraveEU has collected;
(ii) The categories of sources of your personal information from which BraveEU has collected;
(iii) The business or commercial purpose of BraveEU for the collection, sale, or sharing of such personal information;
(iv) The categories of third parties BraveEU discloses, sells, or shares such personal information;
(v) The categories of your personal information that BraveEU has disclosed, sold, or shared to each; and
(vi) The specific pieces of your personal information that BraveEU has collected.
(2) Right to Request Deletion
You have the right to request that BraveEU delete any of your personal information that BraveEU has collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, BraveEU will delete your personal information from our records and will notify any service providers and contractors, as well as third parties to which BraveEU has sold or with which BraveEU has shared personal information, that they must delete such personal information from their records, unless an exception applies.
BraveEU may deny your request to delete your personal information if it is necessary for BraveEU or BraveEU’s service providers or contractors to retain your personal information in order to:
(i) Complete the transaction for which BraveEU collected the personal information, fulfill requirements for a product recall conducted in accordance with a written warranty or federal law, provide a good or service that you requested, enable you to take measures reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform an agreement between BraveEU and you;
(ii) Provide support to ensure the security and integrity of your personal information to the extent reasonably and proportionally necessary for the purpose of use;
(iii) Debug products to identify and repair errors that impair existing intended functionality;
(iv) Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law;
(v) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres or adapts to all other applicable ethics and privacy laws, where BraveEU’s deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent;
(vii) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with BraveEU and compatible with the context in which you provided the information; or
(viii) Comply with legal obligations.
(3) Right to Request Correction of Inaccurate Personal Information
You have the right to request that BraveEU correct any inaccuracies in your personal information that BraveEU retains in view of the nature of the personal information and the purpose of processing the personal information. Upon receipt and confirmation of your verifiable consumer request, BraveEU will use commercially reasonable efforts to correct inaccurate personal information as you instruct in accordance with laws and regulations.
(4) Right to Opt Out
BraveEU has not and will not sell any personal information collected from you.
In the preceding twelve (12) months, we have distributed cross-context behavioral advertisements by sharing online identifiers, etc. collected from you with our advertising companies, etc. If you do not wish for cross-context behavioral advertisements to be distributed, please perform the procedures described in “Do Not Share My Personal Information.”
(5) Right to Request Restriction of Use
BraveEU will not use or disclose sensitive personal information collected from you for purposes other than the following:
(i) To provide products and services that are reasonably expected by average consumers;
(ii) To provide support for ensuring security and integrity;
(iii) For short-term temporary use (except for any use involving profiling or modification to future consumer experiences);
(iv) To provide services on behalf of BraveEU; and
(v) To maintain or improve the quality and safety of BraveEU’s services and devices.
(6) Right of Non-Discrimination
BraveEU shall not discriminate against California residents for exercising any of their rights under the California Privacy Laws. Moreover, unless permitted by the California Privacy Laws, BraveEU will not engage in any of the following acts:
(i) Deny goods or services to you;
(ii) Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
(iii) Provide you with a different level or quality of goods or services; or
(iv) Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
(7) Exercising Your Rights
To exercise your rights under the California Privacy Laws, please submit a verifiable consumer request to BraveEU by contacting us via the contact point for inquiries.
Only you, a natural person authorized by you, a person registered with the California Secretary of State, a person entrusted by you, or your conservator may submit a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
A “verifiable consumer request” must:
• Provide sufficient information that allows BraveEU to reasonably verify that you are the person whose personal information BraveEU has collected or an authorized representative thereof; and
• Describe your request with sufficient detail that allows BraveEU to properly understand, evaluate, and respond thereto.
- Processing of Personal Information of Children