This Privacy Policy describes how we collect and use Personal Information we receive from our customers and users (referred to as “you”) by using the BRAGI website bragi.com and any subsites (together referred to as “Website”) and what Personal Information we transfer to which third parties. This Privacy Policy explains different scenarios to give you a clear understanding of what information we collect, process and use and why we do so.
A. What is Personal Information?
Personal information is information about you that can be used by itself, or combined with other information, to identify you personally (referred to as “Personal Information”). We collect this Personal Information directly from you when you provide it to us.
B. Who are we?
The Website is operated by BRAGI GmbH, Sendlinger Straße 7/Angerblock 2. OG, 80331 Munich, Germany (referred to as “BRAGI”, “we”, “our”, or “us”).
C. What Personal Information do we collect?
We collect Personal Information in a number of different ways:
1) Website
When you connect to our Website, your browser automatically sends information. This data may include your internet protocol (IP) address, browser type and settings, the date and time of your requests and how you used our Website. We only use and process this data where legally permitted.
Depending on how you’re accessing our Website, we may use cookies. For more information on cookies, please refer to our Cookie Policy.
We are present on various social media platforms. From these platforms, we receive anonymized and aggregated demographic and use information related to our presence on the respective social media platform. This happens when you visit us on those sites or communicate with us.
Please refer to sections E and F below to understand for what other purposes we collect data and which third-party providers we use for these purposes.
What do we use this data for?
We use information that we collect about you or that you provide to us on our Website, including any Personal Information, to:
2) Cookies (Cookie Policy)
When an individual visitor accesses this website, we may use a browser feature called a ‘cookie' to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed, and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor's browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are.
What do we use this data for?
In addition to the identified purposes described in this Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies at any time.
3) E-mail communication
You may provide us with your e-mail address when you purchase a product or contract our services, subscribe to our newsletter or otherwise contact us.
What do we use this data for?
If you have given us your consent or if otherwise legally permitted, we send marketing and product support e-mails from time to time, including a newsletter. Our marketing e-mails related to our product and services offerings: software solutions, promotions, news, and events. Our e-mails may contain “beacons” which are small images that inform us about recipients’ receptiveness to our e-mails. See our Cookie Policy for more information on beacons. Our third-party mail service provider also provides us with anonymized and aggregated demographic information about the respondents to our e-mails (c.f. section F below). You can unsubscribe from our marketing e-mails at any time by following the instructions included in the mails.
We may also communicate with you to address your questions.
Data Protection Principles and Accountability
Bragi GmbH has appropriate security measures and policies in place to protect our customers' and partners’ personal data and ensure accountability on that personal data.
Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Bragi legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
Bragi may process your Personal Information because:
Performance of a contract with you
We process your personal information to perform our obligations under the Terms and Conditions applicable to the product or service you are using. This Terms and Conditions are provided before you enter into a contract with us or before you have access to our services.
Your consent
We process your personal information if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your personal information based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent.
Legal obligations
We process your personal information as needed to comply with laws and regulations.
Legitimate interests
We process your personal information to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your personal information, and in any event, will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided before you purchase a Bragi product or use Bragi’s services.
D. How and when do we share information?
We will only share your Personal Information when we have a legal basis to do so.
E. Third parties that we use to perform our services
Some services that we provide require the involvement of third parties. We have carefully selected those third parties and concluded contracts with them that ensure that your Personal Information is adequately protected.
F. Third parties that we use to perform our services
We want to process as little personal information as possible when you use our website. That's why we've chosen Fathom Analytics for our website analytics, which doesn't use cookies and complies with the GDPR, ePrivacy (including PECR), COPPA and CCPA. Using this privacy-friendly website analytics software, your IP address is only briefly processed, and we (running this website) have no way of identifying you. As per the CCPA, your personal information is de-identified. You can read more about this on Fathom Analytics' website.
The purpose of us using this software is to understand our website traffic in the most privacy-friendly way possible so that we can continually improve our website and business. The lawful basis as per the GDPR is "f); where our legitimate interests are to improve our website and business continually." As per the explanation, no personal data is stored over time.
Marketing e-mails (MailChimp)
We use MailChimp (provided by The Rocket Science Group, LLC) located in the USA to send newsletters and other marketing e-mails. MailChimp uses web beacons in order to identify who opened e-mails and who clicked links. To learn more about web beacons, please visit our Cookie Policy.
Storage by us
Your Personal Information is stored by us in the data centers of Page Cloud Inc. which store the information in secured locations and on servers located at the facilities of their service providers.
Others
Where we employ third party companies or individuals to process Personal Information provided by us, they only process such Personal Information on our behalf, based on our instructions and in compliance with this Privacy Policy.
We may share your Personal Information if sharing is reasonably necessary to comply with a law, regulation or legal request or legal process; to protect the safety, rights, or property of the public, any person, or us; or to detect, prevent, or otherwise address fraud, security or technical issues. If not legally forbidden, we will inform you as soon as possible about any sharing of your Personal Information that we are obliged to.
Anonymous information
We may also share aggregated or non-personally identifiable information with our partners, advertisers, or others, where legally permitted.
G. How we store and secure your Personal Information
We are concerned about safeguarding the confidentiality of your Personal Information. We use industry standard practices to protect the confidentiality, integrity, and availability of your data, e.g. by access controls. All Personal Information you provide to us is secured using industry standard procedures. Any payment transactions will be encrypted in transit using SSL. We strive to update our security measures on a regular basis to keep track of new industry standards.
1) How long do we retain Personal information?
We endeavor to only collect personal information that is necessary for the purposes for which they are collected and to retain such data for no longer than is necessary for such purposes. The length of time personal information is retained, and criteria for determining that time, are dependent on the nature of the personal information and the purpose for which it was provided.
2) Transfer of Personal Information
Information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Bragi will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information and only when we have a legal basis to do so, such as a legitimate interest.
The Website is not directed to children under 14. If you learn that your child under 14 has provided us with Personal Information without your consent, please contact us immediately and we will delete such information within reasonable time.
H. Our policy on children’s information
I. What rights do you have?
Right to access, modify or delete your Personal Information
You can always access your Personal Information by asking us what Personal Information we hold about you.
You may modify, add, delete or update your Personal Information or request deletion of Personal Information by emailing us at hello@bragi.com or by contacting us as described in section J below. We will usually respond to all access requests within 30 days. We will retain your Personal Information as needed to provide you with our services.In case you request to delete Personal Information, you may no longer be able to use all features and functions of our services.
Please note that we may be required to keep some of your Personal Information for legal reasons, for instance, to comply with statutory retention periods or for tax purposes. In such cases, we will mark your Personal Information accordingly to make sure that it is not used for any other purpose than complying with the retention requirement.
Right to opt-out of marketing
If you signed up for our newsletter and no longer want us to use your Personal Information for marketing purposes you can unsubscribe from marketing-related e-mails by following the unsubscribe instructions included in each e-mail.
Other rights to opt-out
If you want to opt-out from certain data collection parts on our Website please refer to our Cookie Policy or the links provided in this Privacy Policy.
J. How to contact us
If you have any questions or other enquiries regarding our Website, our products or this Privacy Policy, please feel free to contact us at any time:
BRAGI GmbH
Sendlinger Straße 7 / Angerblock 2.OG
80331 München
Germany / Deutschland
Email: hello@bragi.com
Phone: +49 (0) 89 215 484 210
K. How do we make changes to this Privacy Policy?
We may update this Privacy Policy from time to time and for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here or, if the changes are material with regard to information collected from you, by posting a prominent notice on our Website or by sending an e-mail to the e-mail address you provided to us prior to the change becoming effective. If required, we may also seek your prior consent. You should consult this Privacy Policy regularly for any changes.
