Importance of Your Privacy. At BravoTran, Inc. ("Company"), your privacy is of great importance to us. We understand that you entrust us with certain information provided through www.bravotran.com (the “Site” or “Website”) and/or any software or mobile applications through which Company offers the Services (as herein defined) from time to time. In exchange for your trust, you expect and deserve our commitment to treat your information with respect and in accordance with this Privacy Policy. Under no circumstances will Company sell or share any personal information about you collected through the Services to or with any person or organization except (i) as authorized by you, (ii) as described in the relevant portion of Services, and/or any Company Terms of Use or similar agreement between Company and you or your company, (iii) in connection with providing various products and/or services to you, (iv) to third parties on an aggregated, non-identifiable basis, (v) as may be required by law or court order, or (vi) as otherwise set forth herein (collectively, the "Permitted Uses"). The Website, any Company mobile applications, and Company software platforms and/or above-described services are referred to herein, collectively, as the "Services". The Privacy Policy below describes the standards we adhere to in handling information about you and any personal information you submit through the Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE SUBMITTING ANY INFORMATION TO COMPANY OR THROUGH THE SERVICES. BY SUBMITTING ANY INFORMATION YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY AND THAT YOU AGREE TO BE BOUND BY ITS TERMS. IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY, DO NOT USE ANY OF THE SERVICES OR SUBMIT ANY INFORMATION THROUGH THE SERVICES.

A Special Note About Children. Children are not eligible to use our Services and we ask that minors (under the age of 13) do not submit any personal information to us or use the Services. Company does not collect or maintain information from those actually known to be under the age of 13, and no part of the Services is structured to attract anyone under the age of 13. Other age restrictions may be set forth in Company's Terms of Use from time to time.

Important Categories of Information for you to Know:

1. Who we are
2. Information we may collect through the Services
3. How your information is used
   
4. Altering the information you submit through the Services

1. Who We Are. Company makes the Services available for the purposes of providing information regarding Company’s software and business.

2. Information We Collect. There are various areas within the Services where you may be asked to enter contact lists or other information. In addition, when you use or access the Services, Company may receive and record information on our server logs from your computer or mobile platform, which may include your location. We do not sell or share any personal information about you to or with any person or organization except for the Permitted Uses. In addition, and not in limitation of the foregoing and subject to restrictions imposed under applicable law, information you enter through the Services may be shared with third-party service providers with which Company has entered into a business relationship in order to make the Services available. In addition, Company may sell or disclose information gathered within the Services to third parties on an aggregated, non-identifiable basis.

(a) Information we receive from you.

1. “Personal Information” is information which may include, without limitation, your name, company, title, location, e-mail address and possibly other information that, when taken together, can uniquely identify you. To use and/or take advantage of certain portions of the Services, you may need to provide such Personal Information, either about your or other third parties. We and our third-party providers collect your Personal Information when you voluntarily provide it to us.

2. “Non-Personal Information” is aggregated information, including demographic information that does not uniquely identify you. We and our third-party service providers may collect your Non-Personal Information, including information about the device you are using in accessing our Services, and information pertaining to your interaction with our Services. We and our third-party service providers may also aggregate Personal Information in a manner such that the end-product does not uniquely identify you or any other user of the Services, for example, by using Personal Information to calculate the percentage of our users who have a particular telephone area code. This collective information constitutes Non-Personal Information.

3. “Public Content” is information that you contribute through the Services that is intended for public consumption, including, without limitation, photos, comments and account profile. We may display this information through the Services, share it with businesses and further distribute it to a wider audience through third-party sites and services.

(b)Other Information we get from your use of the Services. We may also collect information about the Services that you use and how you use them.

(c) Information from the "Contact Us" section of the Website and/or mobile application. You may contact Company through the "Contact Us" feature or other features. Participation in these areas is completely voluntary and it is your choice whether or not you wish to disclose any Personal Information or other information to us.

(d)Communication. We may at our discretion, but are not obligated to, monitor the communications that take place on our Service, such as messaging, in order to protect our users and monitor the effectiveness of our Service. You acknowledge that you have no expectation of privacy with respect to any such communications or postings, and you expressly consent to such monitoring.

(e)Information collected from other sections of the Website and/or mobile application. Company may, from time to time, make various resources available to you within the Services. At times we may collect Personal Information or other information in connection with providing such services.

3. How your information is used. We use the information you provide to make the Website and Services available to you. Company may, subject to any restrictions imposed by applicable law, also share certain aggregated data with other third parties for general marketing and demographic purposes; however, this data does not include any of your personal identifying information. Some portions of the Services may be offered in conjunction with partner companies, affiliates or other companies or websites with which we work. In order for us make these features available within the Services, it may be necessary for us to share your personal information with one of such entities. These parties are not allowed to use personally identifiable information except for the purpose of making such features available through the Services. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular feature.

Subject to applicable law, unless otherwise disclosed at the point of collection or otherwise consented by you, the following are various ways in which your information may be used:

• To provide Services to you

• To communicate with you through e-mail, text messaging, push notifications, cloud-enabled voice services or other means and devices regarding your account or your other uses of the Services

• To respond to your inquiries, resolve your problems and concerns, and for other customer service purposes, including, without limitation, for business purposes such as record keeping, quality assurance, training purposes and to improve our customer service operations

• To distinguish you from other users of our Services

• To measure traffic and the effectiveness/success of our ad campaigns and other Services (including those offered through third parties, including our online targeted advertising and offline promotional campaigns)

• To offer you personalized search capability, recommendations, instructions or help on our Website, within our Services and/or on third-party sites

• To assist us in advertising our Services on third-party websites, mobile apps and other online services, and provide you with a better, more personalized experience when you use our Services or when we send you marketing communications, or when we otherwise display our content to you within our Services or on third-party sites, or when you otherwise interact with any of our Services

• To customize your experience when you engage with us

• To better understand how you and others access and use our Services, both on an aggregated and individualized basis, and to conduct further analysis such as identify usage trends, with the goal of continuously improving our Services and enhancing your experience when engaging with us across our Services

• For research, product development, Services enhancement and analytics purposes

• To manage cookies and allow you to manage your cookie preferences

• To administer surveys and questionnaires for market research or member satisfaction purposes

• To comply with legal obligations, as part of our general business operations and for other business administration purposes

• To manage the security of the data in our possession and where we believe necessary, to investigate, prevent or take action regarding illegal activities, suspected fraud, cyber security threats, situations involving potential threats to your safety or the safety of any other person or violations of our Terms of Use or this Privacy Policy, or to bring or defend legal claims

• To debug or repair errors in our systems

• To facilitate arrangements we have with business partners

• For other purposes as permitted by applicable law and not inconsistent with this Privacy Policy or any other express statement we make at the point of collection of the applicable information

In addition, Company may disclose account information, Personal Information and/or other information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with Company’s rights or property, the Services, other users or anyone else that could be harmed by such activities.

4. Cookies and Tracking Technology

We may automatically collect certain types of usage information when you visit our Website or use our Services. For instance, when you visit our Website, we may send one or more cookies — a small text file containing a string of alphanumeric characters used by many websites — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information about your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications and other information that assists us in analyzing and improving the Service. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

What information is collected through the use of cookies and/or the above-described technology depends on how you use our Services, and includes:

• domain name visited

• your browser type and version

• your operating system

• the web pages and other content you view

• the links you click on

• your IP address

• the length of time you spend interacting with the Services

• the referring URL

• the device type from where you access our Sites

• the advertising ID and other unique identifiers associated with your device

• the screen resolution of your device

• the manufacturer of the device you use to access our Services

• the exit page

• your language preferences

• what devices you use to access the Services

• your mobile device ID

• your device name and model

• your mobile operating system, type, name, and version

• the App version

When you access the Service by or through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

If you upload photographs to the Service, those files may contain location information or other metadata. This metadata may be accessible to others if you share content on the Service.

We may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of the Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our Website and the Services; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance the Services.

We may permit third-party ad networks, social media companies, and other third-party services to collect information about browsing behavior from visitors to our Service through cookies, social plug-ins or other tracking technology. Typically, the information is collected through cookies or similar tracking technologies. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies and other tracking/recording tools. Depending on your mobile device, you may not be able to control tracking technologies through settings.

5.Altering Information You Submit.

(a)Deleting your information. Federal and state regulations may require that we store questions or submissions for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.

(b)Altering Information. Company may alter, modify or delete any information you submit through the Website and/or mobile application if it believes, in its sole discretion, it is necessary or desirable to do so.

(c)Request to stop receiving emails from us. Periodically, Company may send you emails to alert you to various new features within the Services. If you do not wish to receive any of these offers, please send an e-mail to support@bravotran.com to remove yourself from our mailing list.

Security

Although Company has taken reasonable measures to ensure that your personal information is delivered and disclosed securely, Company cannot and does not guarantee that the personal information you provide will not be intercepted by others and decrypted.

Storage and Processing

Your information collected through the Service may be stored and processed in the United States or any other country in which the Company or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which the Company or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

Changes to Privacy Policy

If we make a change to our Privacy Policy in the future that will affect how we treat your information, we will post such change within the Services, and such change will be deemed to be effective 2 days from the date of such posting. In that case, your ability to opt out of the new policy will be determined by applicable laws.

Business Transfer

We may, in the future, sell or otherwise transfer some or all of our assets or equity to a third party. Your personally identifiable information and other information we obtain from you via the Website or Services may be disclosed to any potential or actual third-party purchasers of such assets or equity and may be among the assets transferred.

Acceptance

If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use the Services. By using the Services and/or voluntarily providing information which will pass through the Website or Services, you consent to our collection and use of the information as set forth in this Privacy Policy.

Miscellaneous

a. Do Not Track. The Company does not respond to Do Not Track signals and/or other mechanisms that provide consumer choice about tracking.

b. CalOPPA. CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. According to CalOPPA, we agree to the following: (i) users can visit our site anonymously; (ii) once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our Website; (iii) our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above; (iv) you will be notified of any Privacy Policy changes on our Privacy Policy Page; and (v) you can change your personal information by emailing us.

This section provides specific information for California consumers, as required under California privacy laws, including the California Consumer Privacy Act as amended, and its implementing regulations (“CCPA”). The CCPA requires that we provide certain information to California consumers about how we handle their personal information (“PI”), and their rights in that regard. Under the CCPA, “PI” is any information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer, device or household, including the categories identified in the chart below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household, subject to certain exceptions (e.g., publicly available information is not PI).

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect and Cookies and Tracking Technology sections above. We collect this information for the business and commercial purposes described in the How Your Information is Used and Cookies and Tracking Technology sections above. We share this information with the categories of third parties described in the above-referenced sections. We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we may use third-party cookies for our advertising purposes as further described in our Cookies and Tracking Technology section above.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@bravotran.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

c. Nevada Consumers. Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, if you are a Nevada consumer, please contact us at support@bravotran.com and provide an e-mail address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact e-mail address for notices. Changing your e-mail elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.

Links

The Website and/or mobile application may contain links to other websites or applications that are owned and operated by third parties that are not affiliated with us. When you use those links, you leave the Website and we are unable to control how the owners of the websites or applications you link to handle any information they gather about you, including their privacy practices. This Privacy Policy applies only to our Services and does not govern activities on linked websites or applications.

PLEASE PRINT AND RETAIN A COPY OF THIS AGREEMENT FOR YOUR RECORDS.