Privacy Policy

‍Effective as of October 9,2025

Bragi GmbH, a German limited liabilitycompany with its address at Sendlinger Straße 7, Angerblock, 2. OG, 80331Munich, Germany ("we," "us," or "our") iscommitted to protecting your privacy. This Privacy Policy explains how wecollect, use, store, and protect your data when you use our Services.

This Privacy Policy applies to theinformation we collect about you in the course of our business, includingthrough Bragi websites, Bragi enabled products, services, and mobileapplications offered by or on behalf of Bragi.

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1. Definitions

• "Services": Refers to all products, mobile applications, and platforms provided by Bragi GmbH.

• "User": Any individual or entity using the Services.

• "Content": All materials accessible through the Services, including firmware, software, updates, and other media.
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2. Information We Collect

• Information You Provide: Contact details and support inquiries.  
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• Automatically Collected Data: For example, aggregated analytics data such as device information, usage data, and crash reports.  
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• Device Information: Device type, operating system, app version, unique device identifiers, and IP address.
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• Usage Data: Logs of interactions with the App, such as downloads, installations, updates, and session durations.
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• Crash Data: Reports on crashes or errors for debugging and improving app performance.
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• Data from Third Parties: Information from third-party integrations (e.g., social logins) if you choose to connect them to your account.
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• Third-Party Providers: We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.  
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• Voice and Audio Data: When you use our     AI-powered audio features, we may process short snippets of your voice     input to generate responses. Unless otherwise stated, these snippets are     processed in real time and are not stored beyond the session, except where     you have explicitly consented to retention for service improvement.
• Information You Provide via Forms: When you complete forms on our website or apps (for example, to request     support, sign up for newsletters, register for events, or provide     feedback), we collect the information you choose to provide, such as your     name, email address, company, and message content.
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3. Cookies and Similar Technologies

We use cookies and similartechnologies such as pixels, tags, SDKs, and local storage (collectivelyreferred to as “cookies”) to operate, personalize, and improve our Services.Cookies help us recognize you, remember your preferences, understand how you useour Services, and measure the effectiveness of our communications.

Types of Cookies We Use

• Essential     Cookies:     These are necessary for the operation of our Services, enabling basic     functions such as page navigation, secure login, and remembering your     consent preferences. Without these cookies, the Services may not function     properly.
• Performance     and Analytics Cookies:     These cookies help us understand how users interact with our websites and     applications, which allows us to improve usability and performance.
• Functional     Cookies:     These remember your settings and preferences, such as language, region,     and accessibility options.
• Marketing     and Advertising Cookies: These are used to deliver relevant advertisements     and to measure the effectiveness of marketing campaigns.

Legal Basis for Using Cookies

Weuse essential cookies based on our legitimate interest in ensuring theproper functioning and security of our Services.
All other cookies (analytics, marketing, or personalization) are used onlywith your consent, which you can provide or withdraw at any time throughour cookie settings.

Managing and Withdrawing Consent

Youcan manage or withdraw your consent for cookies at any time by clicking “CookieSettings” at the bottom of our website or within our apps.
You can also modify your browser settings to block or delete cookies. Pleasenote that disabling essential cookies may impact the availability orfunctionality of some features.

Third-Party Cookies

Some cookies are placed by thirdparties that provide analytics, advertising, or other integrations on ourbehalf (for example, Google Analytics or advertising networks). These thirdparties may collect information about your online activities over time andacross different websites.
We encourage you to review their respective privacy policies for furtherinformation about their processing and opt-out options.

Retention

Cookiesare stored for varying periods depending on their purpose.

• Session cookies are deleted     automatically when you close your browser or app.
• Persistent cookies remain on your device     until they expire or you delete them through your browser settings.
      We retain cookies only as long as necessary for the purposes for which     they were set.

Cookie Consent

When you visit our websites or use ourServices for the first time, you will be presented with a cookie banner thatallows you to accept, reject, or customize your cookie preferences.
Your consent choices are stored securely and can be modified at any time.

If you have questions about our use ofcookies or your preferences, you can contact us at dpo@bragi.com

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4. How  Bragi Uses Your Information

Bragi may utilize the information we collect to enhance your experience and provide our services effectively. Specifically, we may use your data in the following ways:

• Delivering Requested Services: To fulfill your requests, such as completing purchases, providing subscriptions, offering customer support, or integrating with your chosen streaming services.

• Communicating with You: To keep you informed about your transactions, shipments, software or product updates, and any changes to our terms, policies, or conditions.

• Marketing and Promotions: To share information about new products, special offers, promotions, and upcoming events that may interest you.

• Personalizing Your Experience: To tailor our services to your preferences by delivering relevant content, saving settings, offering product recommendations, and maintaining wish lists.

• Enhancing Our Services: To identify and resolve issues, improve usability, understand user interactions, perform research, and develop new products and features.

• Operational and Security Needs: To manage your account, address concerns or complaints, ensure security, prevent fraud, and comply with legal obligations such as detecting and addressing malicious or illegal activities.

• Unified User Experience: To recognize and connect your interactions across various touchpoints (e.g., devices, browsers, or services) using details like usernames, IP addresses, and device identifiers. This allows us to provide a seamless, personalized experience.

• With Your Consent: For specific purposes communicated to you, where your consent is sought in compliance with applicable legal requirements.
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5. Legal Basis for Processing Your Information

Bragi processes your data in accordance with legal requirements and uses the following grounds:

• Contractual Obligations: When processing is necessary to fulfill our commitments, such as providing requested services or adhering to our terms of use.

• Legitimate Interests: When necessary to support our operations, ensure service security, process payments, defend legal rights, and prevent fraud.

• Legal Compliance: When required to meet legal obligations, such as record-keeping for tax or audit purposes.

• Consent: When you provide explicit consent for a particular purpose.

To enhance your experience, we may combine data collected through our services with information obtained from other online or offline sources. This aggregated information will be managed in line with this Privacy Policy.
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6. How Bragi Shares Your Information

To deliver and enhance our services, we may share your information in the following ways:

• Service Providers: We collaborate with trusted third-party vendors to support our operations and provide our services. These partners assist us with tasks such as hosting, payment processing, shipping, marketing, customer support, data storage, security, fraud prevention, legal services, and product development. These service providers are authorized to use your information solely to perform their contracted services or comply with legal obligations.

• Integrated Platforms and Services: In certain cases, your information may be shared with third-party platforms, applications, or services that you connect with Bragi. These integrations enable features and functionality to operate seamlessly across different services, always in compliance with applicable laws and agreements.

• Compliance with Legal Obligations: We may disclose your information to law enforcement, government authorities, or other third parties when required by law, regulation, or legal process.

• Business Transactions: If Bragi undergoes a business transaction, such as a merger, acquisition, or sale of assets, your information may be transferred as part of that process. In such events, we will ensure that your data remains protected and used in accordance with this Privacy Policy.
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7. International Data Transfers
‍To provide our Services, we may transfer your data to countries outside the European Economic Area ("EEA"). These countries may have data protection laws that differ from those in your jurisdiction. However, when we transfer your personal data internationally, we ensure adequate safeguards are in place to protect your information, including:

• Standard Contractual Clauses (SCCs): Ensuring contractual obligations for data protection are adhered to in line with GDPR requirements.

• Adequacy Decisions: Transferring data only to countries approved by the European Commission as providing an adequate level of data protection.

• Binding Corporate Rules (BCRs): Internal policies adopted by Bragi GmbH to ensure compliance with data protection laws for international transfers.

You can request a copy of these safeguards by contacting us at dpo@bragi.com  
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8. Children’s Privacy
Our Services are intended for general audiences and are not directed at or intended for children. If we become aware that we have collected data without legally valid parental consent from children under an age where such consent is required, we will take reasonable steps to delete it as soon as possible.  

We do not knowingly collect personaldata from individuals under the age of 16 (or under 13 where permitted by locallaw) without verified parental consent.
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9. Your Data Rights Under GDPR, you have the following rights:

• Right to Access: Obtain a copy of your personal data.

• Right to Rectification: Request corrections to inaccurate or incomplete data.

• Right to Erasure: Request deletion of your data under specific conditions.

• Right to Restriction: Restrict the processing of your data under certain circumstances.

• Right to Data Portability: Receive your data in a structured, machine-readable format.

• Right to Object: Object to processing based on legitimate interests or direct marketing.

• Right to Lodge a Complaint: File a complaint with your local data protection authority.

• Right to withdraw consent: When the processing is based on your consent, you can withdraw your consent in the App settings.

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10. App-Specific Data Practices  
Bragi AI Enabled Application

• The App offers firmware updates and device optimization for Bragi-enabled products as well as AI-powered audio recommendations tailored to your user preferences.

• The App offers real-time device control through adaptive features.

• The App may request access to your device's microphone, location, and other sensitive data to deliver specific functionalities (e.g., real-time device control or AI-powered recommendations). These permissions will only be used as described and require your explicit consent.

• You can manage, modify, or revoke these permissions at any time through your device settings. Revoking certain permissions may limit the availability of specific features or functionalities but will not affect your general ability to use the App.

• The App offers customizable controls for tailored functionality. Detailed information about how these permissions are used is available in the Privacy Policy.
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11. Retention of your information

The duration for which we retain yourinformation depends on the specific purposes outlined in this Privacy Policy.We will securely delete or anonymize your data when it is no longer needed forthose purposes unless a longer retention period is required by applicable lawsor regulations.

In certain situations, technical oroperational constraints may prevent complete deletion or anonymization of yourinformation. In such cases, we implement appropriate safeguards to ensure thatyour data is no longer actively processed or used for any purpose.

Examples:
– Account information is retained until you delete your account or requesterasure.
– Crash reports are retained for 12 months.
– Marketing consent records are retained for up to 5 years.
– Voice input data for AI features is processed in real time and not retainedunless you opt in to retention for improvements.
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12. Security and Data Breaches

We use technical and organizationalmeasures to safeguard your personal data, including encryption in transit andat rest, strict access controls, and regular security audits.
In the event of a data breach, we will notify the competent supervisoryauthority within 72 hours where legally required and, if the breach poses ahigh risk to your rights and freedoms, we will notify you without undue delay.

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13. Changes to our Privacy Policy

We may periodically revise this Privacy Policy to reflect changes in laws, our data practices, service features, or technological advancements. We encourage you to review this policy regularly. You can determine if the Privacy Policy has been updated by checking the "Last Updated" date at the top of the document.

By continuing to use our services, you acknowledge that you have reviewed and understood the most recent version of this Privacy Policy. For significant updates, we will notify you through our services or other appropriate channels, ensuring you have the opportunity to review the changes before they take effect, as required by applicable laws.

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14. Automated Decision-Making and Profiling

Currently, Bragi does not engage inautomated decision-making that produces legal or similarly significant effects.

If we engage in profiling or automatedprocessing that significantly affects you, we will provide clear notice andensure safeguards are in place. You may request human review, challenge thedecision, or opt out where legally permissible.

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15. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Germany without regard to its conflicts of law principles. You are encouraged to contact us first for informal resolution at dpo@bragi.com  

Disputes not resolved informally shall be initiated and conducted in the courts of Munich, Germany, and you and Bragi consent to the exclusive jurisdiction of such courts.

However, if you are an international user, you may be entitled to additional protections under the mandatory consumer protection or data privacy laws of your jurisdiction.

For users residing outside Germany, any disputes related to the Services will be resolved under the laws of your local jurisdiction where such protections are mandatory and override this agreement's governing law.
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16. AI-Powered Audio Features

Our Services include AI-poweredfeatures that process voice or audio inputs. Please note:

– AI responses are generatedautomatically and may not always be accurate or reliable.

– Bragi and its partners, are notliable for decisions or actions taken based on AI outputs.

– These features are intended forconvenience and personalization only, not professional advice.

– Users must not input or use theServices to transmit illegal, offensive, or harmful content.

– By enabling these features, youacknowledge the limitations of AI technology and agree to use them responsibly.

Audio inputs used for AI features areprocessed in real time and not stored beyond the session. In limited cases, andonly with your explicit consent, audio inputs may be retained or anonymized forservice improvement or troubleshooting purposes.

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17. Contact Information

Bragi GmbH
Sendlinger Str.7, Angerblock / 2. OG, 80331 Munich, Germany
Email: dpo@bragi.com

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