Privacy Policy

• Personal information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfer
• Children and teens
• Changes to this Privacy Policy
• How to contact us

Information you provide to us. Personal information you may provide to us includes:

• Business contact data, such as your first and last name, salutation, email address, billing and mailing addresses, phone number, professional title and company name.
• Demographic data, such as your city, state, country of residence, and postal code.
• Account authentication data, such as account name and the username and password that you may set to establish an online account on the Service.
• Event registration information, such as business contact data and any other information you provide when you register for one of our events.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Usage data, excluding any data subject to the relevant commercial agreement, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

• Third-party data service providers, such as data brokers, lead generators and cooperative databases, data analytics providers, and other data licensors.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Partners, such as joint marketing partners and event co-sponsors.
• Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Location data, which will be approximate (for example, as inferred from network data or device settings).
• Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
• Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies, including:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a web browser session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our service providers and other third parties place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide and operate the Service (including to process your orders and transactions) and operate our business;
• establish and maintain your user profile on the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:

• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate the Service.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business, develop new products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information. We may use this anonymous or de-identified data and share it with third parties for any lawful business purposes. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Marketing and events. We may collect and use your personal information for marketing and event-related purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.
• Events. We may use your personal information to communicate with you about events in which you participate, or contact or market to you after collecting your personal information at an event.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. As appropriate, we maintain measures designed not to re-identify any de-identified or anonymized data.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see the 'How we share your personal information' section.

Further uses. In some cases, we may specifically ask for your consent to collect, use or share your personal information for further purposes not set out above, such as when required by law (e.g., if the law requires this where those further purposes are not compatible with the initial purpose for which that personal information was collected).

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as artificial intelligence platforms, hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics). We do not allow third-party AI models to train on customer data.
• Third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party's use of the shared information will be governed by its privacy policy and the settings associated with your account on the third-party service.
• Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above. This may include certain 'social networks' where we use their ad services to display ads to our customers, or other people like them, on social media.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Brae, financing of Brae, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Brae or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

In this section, we describe the choices available to all users.

• Access or update your information. You may have the right to access and update personal information we hold about you.
• Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.
• Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
• Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
  • Browser settings. Changing your internet web browser settings to block third-party cookies.
  • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
  • Platform settings. Some platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option for Google and Facebook at the following websites: Google: https://adssettings.google.com/ ; Facebook: https://www.facebook.com/about/ads
  • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp ; Digital Advertising Alliance: https://optout.aboutads.info. ; AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • You will need to apply these advertising-related opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
• Third-party services. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

We are headquartered in the U.S. and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a minor, we will comply with applicable legal requirements to delete the information.

The "LAST UPDATED" legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the "Last Updated" date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

If you have questions about our practices, please contact us.

Email: privacy@trybrae.com