Privacy Policy

Last modified: June 6, 2022

1. Introduction

This Privacy Notice describes how Brazen collects and uses Personal Data about you through the use of our Services, 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 policy.

This Privacy Notice for Services (our “Privacy Notice”) describes the types of information we may collect from you or that you may provide when you use our virtual career fair and career education services (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that. These Services are provided to you as the user of a Customer of Brazen utilizing our Services (a “Customer Organization”), or, if you a participant of an event, on behalf of a Customer Organization that uses our Services (an “Event Sponsoring Organization”) through the websites events.brazen.com, https://app.brazenconnect.com, support.brazenconnect.com and any other Services that we may offer (each, a “Website”). We provide this privacy notice as a service to our Customer Organization or Event Sponsoring Organization customers, however, the Customer Organization or Event Sponsoring Organization’s use of the Personal Data (defined below) that we collect on their behalf is subject to their own privacy practices. This privacy notice only governs our collection and use of your Personal Data while you use our Services and the features and functionality made available to you on or through our Websites, including to configure, setup, view, run, and participate in events. You should contact the applicable Customer Organization or Event Sponsoring Organization for more information about their privacy practices.

This policy applies to information we collect:

through our Services that we provide to you as a Customer Organization;
through our Services that we host and manage for our Event Sponsoring Organization customers; and
in email, text, and other electronic messages between you and our Services.

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 our affiliates and subsidiaries), including any information collected on our general information website at www.brazen.com that is not used in providing the Services, but which allows you to get more information about our Services;
information collected by the Event Sponsoring Organization;
us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website.

Please read this Privacy Notice 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 Services. By accessing or using our Services, 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 our Services 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

We collect information from children under the age of 13 only with the verified consent of a child’s parent or legal guardian or with the consent of an Event Sponsoring Organization who provides consent on behalf of a parent or legal guardian. If we learn we have collected or received Personal Data from a child under 13 without the required consent, we will delete that information.

We collect information from children under the age of 13 with verified consent of a child’s parent or legal guardian or consent that is obtained from Customer Organizations or Event Sponsoring Organizations that are educational institutions and that are permitted to provide consent on behalf of parents and legal guardians under applicable law. No one under age 13 may provide any personal information to or on the Services without such consent. You can find out more about how we process information for children under 13 in our Children’s Online Privacy Notice Addendum. If you are under 13 and do not have the required consent, do not register to use the Services or otherwise provide any information about yourself to us, 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 13 without the required consent, we will delete that information. If you believe we might have any information from a child under 13 without such consent, 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 Services (“Personal Data”):

by which you may be personally identified, such as your name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline;
that is about you and your background, such as your work history and other relevant experience (including information that may be included in contained in a resume, CV, or cover letter), grades in school, career plans, gender identity, race or ethnicity, age, citizenship, trade union membership, veteran or military status, educational information (including degrees awarded, transcripts, and other information provided by you as a potential employee), and current job title and company;
that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Services, error information, clickstream data, and other communication data and the resources that you access and use on the Services; and/or
about your internet connection, the equipment you use to access our Services and usage details.

We collect this information:

directly from you when you provide it to us; and
automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect on or through our Services are:

information that you provide by filling in forms on our Services. This includes information provided at the time of registering to use our Services or filling in forms for a potential employer. 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 Services;
information that you provide when you access your account;
pictures of you that you upload to our Services;
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 Services, such as the ability to log into the Services 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 interactions you carry out through our Services, including when you submit your information for us to send to a potential employer and when you interact with our chatbot.

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 Services, 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 Services 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 Services according to your individual interests;
speed up your searches; and
recognize you when you return to our Services.

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 Services 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.

Information We Collect From Third Parties

We may receive your registration information and/or additional information from third parties such as the Customer Organization or Event Sponsoring Organization or its service providers for the purposes of providing the Services. The additional information may include information, such as your status with the Customer Organization or Event Sponsoring Organization and identification information that may be assigned by the Customer Organization or Event Sponsoring Organization to verify your identity.

4. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

provide our Services to you;
provide you with information you request from us;
enforce our rights arising from contracts;
notify you about changes; and
provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

to present our Services and their contents to you;
to provide you with information and the services that you request from us;
to fulfill any other purpose for which you provide it;
to perform services on behalf of our clients, including providing a portal that enables you to provide information to the Customer Organization or Event Sponsoring Organization about you such as by enabling you to upload your employment and resume information to our Services;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
to allow you to participate in interactive features on our Website such as by using our chatbot or communicating with a potential employer or other presenters during an event;
to enable you to interact with other event participants;
to maintain a record of the events in which you participate, including chat history;
to transcribe and make available conversation history to the parties to a conversation;
to grant you access to your account;
to provide you with notices about your account;
for internal testing, research, analysis, and services development, including to develop and improve our Services;
to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activity;
to notify you about changes to our Services or any services we offer or provide though them;
to fulfill the purpose for which you provide it. For example, if you give us your employment history, we may provide that information to a potential employer, Customer Organization, or the Event Sponsoring Organization hosting the event for which you provided the information;
for Online Behavioral Advertising purposes (more details available here: https://www.ftc.gov/sites/default/files/documents/public_statements/online-behavioral-advertising-moving-discussion-forward-possible-self-regulatory-principles/p859900stmt.pdf and https://digitaladvertisingalliance.org/principles) by a third party vendor Demandbase (https://www.demandbase.com/); any other way we may describe when you provide the information; and
for any other purpose with your consent.

With your consent, we may also use your information to contact you about our own and third-parties’ services that may be of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which we collect your data. If you wish to change your choice, you may do so at any time by logging into the Services and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes, selecting the unsubscribe link that is provided in one of our emails, or by sending us an email stating your request at privacy@Brazen.com. 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 employers and potential employers who provide us with requests for potential employee hires;
to the Customer Organization or Event Sponsoring Organization hosting the event for which you provided your information;
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.
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 example, if you upload your employment history or resume to our Services, we may provide that to a potential employer that is seeking an employee;
to enforce our rights arising from any contracts entered into between you and us;
to third parties such as Demandbase (https://www.demandbase.com) that collect data and use your data for Online Behavioral Advertising purposes;
for any other purpose disclosed by us when you provide the information; 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 and our advertising to you.

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. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

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.

If you are an end user, you may review and change their Personal Data by logging into the Services and visiting your account profile page when that option is made available to you.

You may also contact the Customer Organization or Event Sponsoring Organization to request access to, correct, or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not be able to accommodate a request to change information if either of us 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 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 within this Privacy Policy.

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 Services 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.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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 Services. 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
4040 Fairfax Drive
7th Floor, Suite D
Arlington, VA 22203
United States
(703) 947-0787
privacy@brazen.com

Brazen GDPR and UK-GDPR Privacy Addendum

Last modified: June 6, 2022

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 Services 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. Children Under the Age of 16

We collect information from children under the age of 16 with the required consent. 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.

We collect information from children under the age of 16 only with consent of the parent or legal guardian, or their agent, as required by applicable law. No one under age 16 may provide any personal information to or through the Services without such consent. If you are under the age of 16 and do not have the required consent, do not use or provide any information on our Services or on or through any of its features/register to use the Services, make any purchases through the Services, use any of the interactive features of our Services or provide any information about yourself to us, 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 the required consent, we will delete that information. If you believe we might have any information from a child under 16 without such consent, please contact us at privacy@brazen.com.

3. Data Controller, Data Protection Officer, and Representative

Brazen is the data processor of the Personal Data you provide on or as a result of the use of our Services. Brazen has appointed a Data Protection Officer and a representative in the EU.

Except for cookies that we use on our Services, the Customer Organization or Event Sponsoring Organization is the data controller of your Personal Data and Brazen is generally the data processor of your Personal Data. You can learn more about their privacy practices concerning your Personal Data by reviewing the Customer Organization or Event Sponsoring Organization’s privacy notice related to events. Brazen is, however, the controller solely for the use of cookies in providing our Services and solely to the extent these cookies contain your Personal Data. Please see our cookie consent manager for more information about our use of cookies and the rights you may have regarding these cookies. Brazen has appointed a Data Protection Officer and representatives in the European Union and the United Kingdom in compliance with the General Data Protection Regulation. Brazen, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this GDPR Privacy Addendum.

4. 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, as required by law, and with your consent.

If you are in the European Union, 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 Services, you consent to our collection, use, and sharing of your Personal Data as described in our Privacy Notice and this GDPR Privacy Addendum. If you do not consent this collection, use, and sharing, please do not use the Services.
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: provide our Services for a virtual career fair; provide potential employers with your information so they can consider you for potential employment with them; enable you to communicate with potential employers; to fulfill our obligations to the Customer Organization or Event Sponsoring Organization; to provide you with information about educational programs; detect and correct bugs and to improve our Services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; and perform risk assessments.
For Our Performance Under Our Terms of Use. We process your Personal Data as necessary for our performance and to exercise our rights under the Terms of Use for our Services.
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.

5. Special Categories of Information

We may process some Personal Data considered sensitive when necessary to carry out our obligations under the law or to protect our legitimate interests.

Some Personal Data processed by Brazen may be considered sensitive, including Personal Data that reveals your age, skin color, race, national origin, citizenship, religious/philosophical beliefs, gender, biometric data, trade union membership, and veteran or military status. By submitting this information, you hereby consent to our use of this information as described in our Privacy Notice. Brazen processes this information only to the extent necessary to assist the Customer Organization or Event Sponsoring Organization’s with their obligations in the field of employment (so far as authorized by the law in your country) or as otherwise provided by law.

6. 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.

7. 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 can review and change your Personal Data by logging into the Services and visiting your “Edit Profile” page. You may contact the Customer Organization or Event Sponsoring Organization to request access to, correct or delete any personal information that you have provided to us to ensure that it is complete, accurate, and as current as possible. We may 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 request the Customer Organization or Event Sponsoring Organization to restrict our processing of your Personal Data under certain circumstances. In particular, you can make this request 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 the Customer Organization or Event Sponsoring Organization 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 the Customer Organization or Event Sponsoring Organization 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 the Customer Organization or Event Sponsoring Organization. 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 the Customer Organization or Event Sponsoring Organization to instruct us to delete your Personal Data. We cannot delete your Personal Data except by also deleting your user account (if you have one), and we will only delete your account 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 or the Customer Organization or Event Sponsoring Organization 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 notice. 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 or the Customer Organization or Event Sponsoring Organization 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 the Customer Organization or Event Sponsoring Organization who runs the event through which we collect your information. If you contact us to exercise any of the foregoing rights, we will direct you to make your request with the Customer Organization or Event Sponsoring Organization as the controller of your Personal Data. We are not able to comply with requests made directly to us unless otherwise authorized by the Customer Organization or Event Sponsoring Organization.

8. 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 (“EEA”) or the United Kingdom, in order to provide our Services to you, we may send and store your Personal Data outside of the EEA, 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 Services, 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.

9. Data Retention Periods

We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example 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 will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:

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.

10. 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.

Brazen reserves 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 Services following the posting of changes constitutes your acceptance of such changes.

11. 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
4040 Fairfax Drive
7th Floor, Suite D
Arlington, Virginia 22203
United States
(703)879-8029
DPO@brazen.com

(List of all other Data Reps POC)