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Privacy policy

This privacy policy (“Privacy Policy”) explains how Brave group APAC (Thailand) Co., Ltd. (“Brave”, or “we” or “our”) will collect, use, disclose, and process in any manners a Personal Data (as defined herein) relating to users (hereinafter referred to simply as the “Users”) of services provided by Brave (the “Services”) and our business partner (hereinafter referred to simply as the “Partners”, collectively with Users as “you” or “your”) and other Personal Data which we will obtain as specified herein.

In addition to this Privacy Policy, Brave may stipulate other rules relating special handling of Personal Data about the Users (the “Individual Rules”) for Braves’ individual services. In such cases, the Individual Rules shall constitute a part of this Privacy Policy, and if there is any conflict between the two, the Individual Rules shall prevail.

As Brave may revise all or a part of this Privacy Policy as necessary, so please read all this Privacy Policy before using the Services.

Acquired Personal Data

The Personal Data that we obtain in order to achieve the purposes of use in Section 4 (the “Acquired Personal Data”) includes the following “Personal Data” as defined in the Personal Data Protection Act B.E. 2562, as amended, as well as any subordinate legislations thereunder (collectively, “PDPA”).

(1) Following information:

Name, date of birth, gender, occupation (including job title), and other information that may, directly or indirectly, identify any specific individual;
Information such as address, telephone number, account information (i.e., e-mail address and password), nickname, etc.
Credit card information, payment information such as crypto currency and blockchain wallet addresses;
Hobbies, family structure, age, and other personal attribute information that is integrated with Personal Data;
Information related to identity verification; and
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 (please see further details on how we process your cookie information via Cookie Policy), 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 Personal Data

Brave will collect the Acquired Personal Data through the following methods;

Users input on the Services directly;
Users provide the Acquired Personal Data to Brave in person, by e-mail, mail, in writing, or by telephone, etc. (When answering the phone with the User, Brave may record such call to improve the quality of the response, etc.);
Methods to collect information when the Users use or browse the Services; or
Indirect collection from Partners and third parties.

Management of the Acquired Personal Data

Those who are engaged in the management and use of the Acquired Personal Data in Brave will strictly manage the Acquired Personal Data and will take sufficient care in handling the Acquired Personal Data to prevent unauthorized access, loss, leakage, or falsification of Personal Data as well as to ensure that all the activities with respect to the collection, use, disclosure, or process of Personal Data shall strictly comply with this Privacy Policy and the PDPA..

Purpose of use of the Acquired Personal Data

Brave will use the Acquired Personal Data appropriately to the extent necessary to achieve (i) the purposes notified or announced at the time of acquisition or collection, (ii) the purposes stipulated in the Terms of Use, etc., or (iii) the following purposes. In addition, Brave may change the purpose of use to the extent that it is reasonably deemed to be related to the purpose of use before such change, and Brave will announce such change in a notice when it occurred on the Services or on the website operated by us, or in any other easily understandable manner.

(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;

(13) To prevent fraudulent activities that interfere with normal service provision (including detection of the Users violating the Terms of Use, etc. and notification to such users, and investigation, detection, prevention, and response to fraudulent activities such as fraud and unauthorized access that abuse the services, etc.);

(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 Brave or third parties;

(20) To distribute or display product information within services provided by Brave or third parties; and

(21) To resolve problems in the operation of the Services and to comply with laws and regulations.

< Personal Data (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 Brave;

(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; and

(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 Brave

(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

Applicable Legal Bases

Your Personal Data shall be collected, used, disclosed, and processed for the aforementioned purposes and by relying on the following legal bases under the PDPA:

The performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
The Processing is necessary for legitimate interests pursued by Brave as a data controller or interests of a third party other than you, except where your fundamental rights and freedoms regarding the protection of his or her Personal Data override these interests;
To comply with any legal obligations imposed upon Brave;
To prevent or suppress a danger to a person’s life, body, or health;
The performance of a task carried out in the public interest or in the exercise of official authority vested in Brave;
The achievement of purposes relating to the preparation of historical documents or archives for the public interest or for purposes relating to research or statistics in which suitable measures to safeguard the data subject’s rights and freedoms are taken; and/or
Processing based on your consent.

Joint use

Brave may jointly use the Acquired Information as follows;

Scope of joint use

Our group companies (for details, please click here)

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 Brave or our group companies.
For management and internal administration of our group companies.
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.

Responsible for the management of Personal information used jointly

Brave group Inc. (for details, please click here)

Transfer/Disclosure of the Acquired Personal Data to third parties

In certain circumstances, and for the purposes of this Privacy Policy, Brave may transfer or disclose some or all of the Acquired Personal Data to the following third parties, within the scope permitted by law:

Our group companies, subsidiaries, affiliates, and any related companies to the extent necessary in providing the Services. For more details of our group companies, please click;
Third-party service providers, including but not limited 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 Brave to the Users, provision of related after-sales services, and provision of other services, in order to achieve the performance of Services to the Users;
Third-party service providers, including but not limited to warehouse service providers, printing house, IT service provider, auditors, lawyers, tax and legal advisers and any consultants, to the extent necessary of carry out the ordinary course of business;
Court, administrative agency, supervisory authority, or other public agency as required by applicable laws and regulations;
Third-party marketing agencies, analysts, researchers, and/or advertisement service providers for the purpose of market planning, market research, data and business analysis, advertisement, etc.
Other third parties as per your consent or contractual requirements or legal requirements, as the case may be.

Transfer of Personal Data Outside Thailand

Brave may provide the Acquired Personal Data to third parties which are located/resided outside Thailand (e.g., to Japan, etc.), to process and achieve the purposes of collection, use and disclosure specified herein. In such case, Brave shall comply with the requirements under the PDPA for the purpose of the transfer hereunder, including to ensure that the country of destination has an adequate data protection standard. However, please be aware that certain countries may not currently offer the same level of standard on data protection as in Thailand, in that regard, we will put in place any reasonable measures to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy.

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, Brave 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.

These information collection modules collect the Personally relevant information without including personally identifiable information, and the collected information is managed in accordance with the privacy policy and other rules stipulated by each information collection module provider and Brave may use cookies and the Personally relevant information obtained from information collection module providers in conjunction with Personal information that Brave already has.

If you do not want your data to be collected by Google Analytics or other information collection modules, please reject the use of your data in the manner prescribed by Google Inc. or other information collection modules. However, if you prohibit the use of cookies and other personally identifiable information, you may not be able to use the Services properly, or you may not be able to reflect advertising settings that require Personally relevant information.

For an explanation of the Google Analytics Terms of Service and Privacy Policy, please visit the following site;

Google Analytics Terms of Service

https://www.google.com/analytics/terms/jp.html

Google Privacy Policy

http://www.google.com/intl/ja/policies/privacy/

Google Analytics Opt-out Add-on:

https://tools.google.com/dlpage/gaoptout?hl=ja

Retention of Personal Information

Brave will retain the Acquired Personal Data to the extent necessary for the purposes stated in “Purpose of use of the Acquired Information” in this Privacy Policy and will promptly delete the same in the case that such data is no longer necessary.

The criteria for determining the retention period includes but is not limited to: (i) the duration of the contractual relationship between you and Brave; (ii) the legal obligations assumed by Brave; and (iii) a need to perform an agreement to which you are a party.

Information of minor users

If the Users are minor, the Users’ parent(s), guardian(s) or custodian(s) must agree to the contents of the Privacy Policy and Terms of Use, etc., and comprehensively agree to the Users’ use of the Services in accordance with the Privacy Policy and Terms of Use.

Improvement and update of the Privacy Policy

Brave will review the status of our operations regarding the handling of the Users’ Personal Data, etc., as appropriate, and change or amend this Privacy Policy from time to time in response to changes in laws and regulations, business needs, etc. Brave will notify the Users of any changes to this Privacy Policy, so please confirm the latest Privacy Policy before accessing or using the Services.

Data Subject’s Rights

Pursuant to the PDPA, you shall have the following rights towards your Personal Data:

Right to withdraw your consent;
Right to access Personal Data;
Right to correct Personal Data;
Right to erase, destroy, or anonymize Personal Data;
Right to restrict the use of Personal Data;
Right to request a data portability; and
Right to object the Processing of Personal Data.

The request for exercising the abovementioned rights or for any general inquiries regarding the processing of your Acquired Personal Data may be submitted to Brave via the contact information as provided in Section 14.

Please be informed that, in certain circumstances to the extent applicable under the PDPA, Brave may reserve the rights to refuse your requests. For instance, if Brave deems that there is no legitimate basis for such requests, or if such request is excessive, or the requestor could not verify himself/herself that he/she is the data subject who has those rights toward the Acquired Personal Data retained by us. You may lodge a complaint to the Personal Data Protection Committee of Thailand (PDPC) if you do not agree with Brave’s decision.

Contact for inquiries

If you have any opinions, questions, complaints, request or other inquiries regarding our handling of your Acquired Personal Data, please contact us at the following address.

Inquiries to
contact@bravegroupapac.co.th

No.65, 42 Tower, 6th Floor, Room 601, Soi Sukhumvit 42 (Kluaynamthai), Sukhumvit Rd.,Phra Khanong, Khlong Toei, Bangkok 10110

Brave group APAC (Thailand) Co., Ltd.
Privacy Policy Last Updated and Effective: 7/16/2024

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

If you reside within the EEA or the UK, Brave shall process your personal information within the scope necessary for achieving the purposes of use above based on your consent to this Privacy Policy. Brave shall also process your personal information within the scope necessary for achieving the purposes of use above in the case where Brave’s processing of your personal information meets any of the following requirements:

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
Such processing is necessary for the purposes of the legitimate interests pursued by Brave or any third party (including, without limitation, interests such as those pertaining to the provision of services by Brave).

Where provision of your personal information is mandatory and you choose not to provide the same, then Brave 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 Brave’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

Brave 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, Brave 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, Brave 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 Brave: (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 Brave 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 Brave 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 Brave’s rights), or if Brave is required by law to retain or has legitimate interests in retaining your personal information. Relevant exemptions are included in applicable laws on privacy. Brave will inform you of the relevant exemptions which Brave relies upon when responding to any request you make.

If you wish to exercise any of these rights, please contact Brave via the contact point for inquiries. If you have any unresolved concerns, you may lodge a complaint with an EU 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 Brave

Brave 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.”

Category	Examples
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

Brave 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, Brave 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.

Brave has shared or disclosed personal information to the following categories of third parties for business purposes during the last twelve (12) months:

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 Brave or our group companies.
For management and internal administration of our group companies.
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 Brave to the Users, provision of related after-sales services.
To research and analyze the usage of the Services

Sale or Sharing of Personal Information

Brave has not sold any personal information in the preceding twelve (12) months.

In the preceding twelve (12) months, Brave 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.

Right to Access Specific Information

You have the right to request that Brave disclose certain information to you in relation to the collection, sharing, disclosure, or use of your personal information by Brave. Upon receipt and confirmation of your verifiable consumer request, Brave will disclose to you any or all of the following information:

The categories of your personal information that Brave has collected;
The categories of sources of your personal information from which Brave has collected;
The business or commercial purpose of Brave for the collection, sale, or sharing of such personal information;
The categories of third parties Brave discloses, sells, or shares such personal information;
The categories of your personal information that Brave has disclosed, sold, or shared to each; and
The specific pieces of your personal information that Brave has collected.
Right to Request Deletion

You have the right to request that Brave delete any of your personal information that Brave has collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, Brave will delete your personal information from our records and will notify any service providers and contractors, as well as third parties to which Brave has sold or with which Brave has shared personal information, that they must delete such personal information from their records, unless an exception applies.

Brave may deny your request to delete your personal information if it is necessary for Brave or Brave’s service providers or contractors to retain your personal information in order to:

Complete the transaction for which Brave 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 Brave and you;
Provide support to ensure the security and integrity of your personal information to the extent reasonably and proportionally necessary for the purpose of use;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law;
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;
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 Brave’s deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Brave and compatible with the context in which you provided the information; or
Comply with legal obligations.
Right to Request Correction of Inaccurate Personal Information

You have the right to request that Brave correct any inaccuracies in your personal information that Brave 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, Brave will use commercially reasonable efforts to correct inaccurate personal information as you instruct in accordance with laws and regulations.

Right to Opt Out

Brave 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.”

Right to Request Restriction of Use

Brave will not use or disclose sensitive personal information collected from you for purposes other than the following:

To provide products and services that are reasonably expected by average consumers;
To provide support for ensuring security and integrity;
For short-term temporary use (except for any use involving profiling or modification to future consumer experiences);
To provide services on behalf of Brave; and
To maintain or improve the quality and safety of Brave’s services and devices.
Right of Non-Discrimination

Brave 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, Brave will not engage in any of the following acts:

Deny goods or services to you;
Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Provide you with a different level or quality of goods or services; or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your Rights

To exercise your rights under the California Privacy Laws, please submit a verifiable consumer request to Brave 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 Brave to reasonably verify that you are the person whose personal information Brave has collected or an authorized representative thereof; and
Describe your request with sufficient detail that allows Brave to properly understand, evaluate, and respond thereto.

Processing of Personal Information of Children

Our services are not directed to and we do not knowingly collect personal information from anyone under the age of 13 or share the personal information of anyone under the age of 16. If we learn that we have collected or shared personal information of a child in violation of this Privacy Policy without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us via the contact point for inquiries.