Privacy Policy

1. Scope and Updates to This Policy

This policy covers personal information that BRANIA processes across everything we offer — our websites, our applications, and our other online and offline activities. Throughout this document we refer to all of those collectively as the “Services.”

Revisions. We may update this policy at our discretion. Where a change is material, we will let you know in whatever manner the law requires. If you keep using the Services once an updated version takes effect, you are treated as having accepted it.

One important exception. This policy does not govern the information we handle on behalf of our business customers when they use the Services (“Customer Data”). That data is governed by our customers' own privacy notices and by the contracts and data processing agreements we hold with them; we act only on their instructions. If you want to access, correct, or delete information held by one of our customers, please approach that customer directly — we support them in responding to such requests as our agreements require.

2. Personal Information We Collect

What we collect depends on how you interact with us and on what applicable law requires. Broadly, it falls into three groups: information you give us, information gathered automatically as you use the Services, and information we receive from other sources.

A. Information you provide

• Account details. Identifiers and related details used to set up or administer an account — name, email address, telephone number, address or location, professional background, and anything else you choose to share with us.
• Enquiries you send us. When you write in to ask a question or request support, we keep the details you include so that we can respond.
• Surveys and interactive features. We sometimes invite people to take part in surveys, and we collect what participants choose to share. Anything you post through a public feature of the Services should be treated as public unless the law says otherwise, and is not covered by the protections described here.
• Conversations with BRANIA agents. When you interact with an AI agent we run for ourselves — a demonstration agent or a recruiting agent, for example — we may keep what you type, such as your name and email address.
• Business development. We collect contact and role information from individuals and third parties in order to identify and pursue commercial opportunities, including through our website and at conferences, trade shows, and events we attend or host.
• Job applications. If you respond to a role we have posted, we collect your application materials — CV, cover letter, employment history, and anything else you send. Some of that material may reveal sensitive details, including characteristics that are legally protected.
• Purchases. We keep commercial records relating to purchases of the Services, including business contact details. Payments are handled by third-party processors; we do not collect or store card numbers ourselves, though we may receive associated details such as billing information.

B. Information collected automatically

Certain information is gathered as a by-product of your using the Services: IP address, user settings, MAC address, cookie identifiers, mobile carrier, advertising and other unique identifiers, browser and device characteristics, approximate location inferred from your IP address, and your internet service provider.

We also record how the Services are used — which pages you view before, during, and after a visit, what you search for, which links you follow, what content you engage with, and how often and how long you do so. In some cases third parties supply the functionality that collects this. See “Cookies and other technologies” below.

C. Information from other sources

We may obtain your name, contact details, and role at your company from elsewhere: public records, business data providers such as ZoomInfo or Clay, and firms that aggregate publicly available information. We also enter into arrangements to co-sponsor events or content about the Services, distributed through channels such as newsletters and advertising.

Cookies and other technologies

We — and third parties who supply content, advertising, or functionality on the Services — use cookies, pixel tags, web beacons, and similar tools (“Technologies”) to collect information automatically as you use the Services.

• Cookies are small text files stored by your browser that hold preferences and improve your experience.
• Pixel tags and web beacons are small pieces of code embedded in a page or an email that register engagement — that a particular page was visited, an advert was clicked, or a message was opened, acted on, or forwarded.

Which Technologies are set by default, and what choices you have, depends on where you are when you reach the Services. Use the Cookie Preferences control on our website to review and change your settings. The section on your choices and rights below covers this further.

We use these Technologies for four purposes:

• Strictly necessary. Required for the site to work, and not switchable in our systems. They are typically set in response to something you do — setting privacy preferences, signing in, completing a form. Your browser can block or warn you about them, but parts of the site will then stop working.
• Functional. These enable richer functionality and personalisation. Some are set by us, some by providers whose services we have added. Blocking them may cause parts of the site to misbehave.
• Analytics and performance. These help us understand how the Services are used, count visits and traffic sources, see which pages are popular, and improve accordingly. Google Analytics is one of the providers we use; information about how Google handles data, and how to opt out of Google Analytics, is available from Google directly.
• Marketing and advertising. We work with advertising networks and social platforms, including LinkedIn, that observe which content you access on the Services and on other sites. Those partners group that information into categories, and our campaigns are shown to people in the categories we consider relevant to our business. We may share personal data with third parties for this purpose, which is why you may see our advertising on social platforms and other sites. Industry bodies — among them the Network Advertising Initiative and the Digital Advertising Alliance and its European and Canadian counterparts — operate opt-out tools for targeted advertising. Opting out does not stop advertising altogether; you may still see untargeted ads based on the page you are reading.

“Do Not Track.” Some browsers offer a Do Not Track setting. We do not currently respond to or honour those signals.

You can adjust your browser to refuse non-essential cookies, or visit us with the Global Privacy Control (GPC) signal enabled for a frictionless opt-out; guidance on browsers and extensions that support GPC is published by the Global Privacy Control project. Your choice is tied to the browser you make it in — use a different device or browser, or clear your cookies, and you may need to make it again. Blocking or deleting non-essential cookies can affect how our sites behave.

3. How We Use Your Personal Information

We use personal information for a range of business purposes: to deliver the Services, to run our operations, and to market what we do.

A. Delivering the Services

To meet our contract with you, we use your information for things such as managing your account and details; giving you access to areas, features, and content of the Services; answering customer and technical support requests; contacting you about your account, your activity, and changes to our policies; measuring and improving how the Services perform; and registering you for events.

B. Administrative purposes

We also use personal information to run the business, including to:

• pursue legitimate interests such as direct marketing and research and development, including market research;
• keep our networks and information secure, detect security incidents, and guard against malicious, deceptive, fraudulent, or unlawful activity;
• measure interest and engagement in the Services;
• improve, upgrade, and extend the Services, and develop new products;
• maintain internal quality control and safety;
• authenticate and verify identity, both for systems access and when someone exercises the rights described here;
• debug and repair faults;
• audit interactions, transactions, and other compliance activity;
• share information with third parties where that is needed to provide the Services;
• enforce our agreements and policies;
• process job applications and manage candidacies; and
• carry out whatever our legal obligations require.

C. Marketing and advertising

We may tailor the content and advertising you see. That can take the form of email campaigns, custom-audience advertising, and personalised or targeted advertising, including across devices — which is why our advertising may appear on third-party sites and services. The cookies section above explains the Technologies involved.

We work with third parties, Google among them, to reach people likely to be interested in what we do. We analyse customer and prospect information and share it in hashed form, so that no individual is directly identifiable from what we pass on. The receiving party can match that hashed information back to our customers and prospects in order to deliver our messages to them.

If you have questions about any of this, contact us at any time using the details at the end of this policy.

D. With your consent

We may use personal information for other purposes that we make clear to you at the point of collection, or that you have consented to.

E. Other purposes

We also use personal information as you ask us to, or as applicable law otherwise permits.

De-identified and aggregated information. We may turn personal information into de-identified or aggregated material — demographic summaries, usage statistics, information about the devices used to reach the Services. Once it can no longer be linked to an individual, it is not personal information, and we may use, disclose, and retain it for research, analysis, analytics, and any other lawful purpose.

4. How We Disclose Your Personal Information

We disclose personal information to third parties for several business reasons: to run the Services, to protect ourselves or others, and in the event of a significant corporate transaction.

A. Disclosures made to provide the Services

• Service providers. Vendors that help us operate — IT support, hosting, payment processing, customer service, and related functions. Some of them supply generative AI and other AI capabilities that we use to aggregate or analyse data, summarise it, make predictions, suggest responses, or identify trends.
• Third-party services. Parts of the Services may link to, or let you connect with, outside websites, products, and technology. Anything shared with or collected by one of those is governed by that party's own privacy policy, and we are not responsible for how they handle it.
• Business partners. Where we need to work with a partner to deliver something you have asked for, or where we offer products jointly.
• Affiliates. Other companies within the BRANIA corporate group.
• Advertising partners. These partners may set Technologies and other tracking tools on the Services to collect details of your activity and device — IP address, cookie identifiers, pages viewed, location, time of day. They combine this with information from elsewhere in their networks to deliver personalised advertising to you, a practice usually described as interest-based, personalised, or targeted advertising.

B. Disclosures to protect us or others

We may access, preserve, and disclose information we hold about you where we believe in good faith that doing so is necessary or appropriate to: comply with law enforcement or national security requests and legal process such as a court order or subpoena; protect the rights, property, or safety of you, of us, or of others; enforce our policies or contracts; recover amounts owed to us; or assist in investigating or prosecuting suspected or actual unlawful activity.

C. Mergers, sales, and other transfers

If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale or purchase of assets, or a transition of service to another provider, your information may be sold or transferred as part of that transaction, so far as law and contract allow. We may also disclose information in any other way applicable law permits.

5. Your Privacy Choices and Rights

A. Your choices

The choices open to you depend on the law that applies to you.

• Email. Every marketing email carries an unsubscribe link at the foot of the message. Transactional messages continue regardless — invoices, notices about Services you use, and updates to our terms or to this policy are not something you can opt out of.
• Phone calls. If you receive a marketing call you did not want, you can opt out of future calls by following whatever instructions are given on the call, or by contacting us using the details below.

B. Your rights

Depending on where you live, you may have the right to:

• Access your information and port it — to learn what has been collected, where it came from, why it is processed, and whether it has been sold or shared; to obtain a copy of it; and to receive what you gave us in a structured, commonly used, machine-readable format, or to have us send it to another company.
• Correct information that is inaccurate or incomplete. In some cases we provide self-service tools for this.
• Delete your information.
• Opt out of certain processing — targeted advertising, the “sale” or “sharing” of your information, or profiling used in decisions that have legal or similarly significant effects, as those terms are defined by the applicable privacy laws. For example, we may “sell” or “share” personal information under the CCPA by disclosing it to data analytics providers and advertising partners so they can analyse use of the Services and deliver cross-context behavioural advertising about BRANIA. California residents may opt out of that. To do so, use the Cookie Preferences control on our website, or browse with the Global Privacy Control signal enabled. Your choice is tied to that browser; a new device or browser, or a cleared cookie store, means renewing it.
• Restrict or object to our processing of your information.
• Appeal a decision where we decline to act on your request.
• Withdraw consent. Withdrawal applies going forward only; it does not make earlier processing unlawful.

To exercise any of these, you or an authorised agent can reach us using the contact details below. We handle requests in line with applicable law, and we may need further information from you in order to assess and act on a request properly.

6. Notice at Collection for California Residents

This section applies only to personal information about California residents that falls under the California Consumer Privacy Act, as amended (the “CCPA”).

A. Sources

We collect information you provide, information gathered automatically as you use the Services, and information from third-party sources. Section 2 above sets these out in full.

B. What we collect, disclose, sell, and share

The CCPA gives California residents the right to know which categories of personal information BRANIA has collected about them, whether we disclosed it for a business purpose, whether we “sold” it, and whether we “shared” it for cross-context behavioural advertising in the preceding twelve months. The answer follows.

Categories collected

• Identifiers, such as name, email address, and log-in identifiers
• Categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name and telephone number
• Commercial information, such as transaction records and purchase details
• Internet and other electronic network activity, such as IP addresses, site usage, and browser information
• Geolocation data, such as approximate location derived from an IP address
• Account log-in credentials that permit access to an account
• Information revealing racial or ethnic origin, religious or philosophical belief, or union membership
• Protected classification characteristics under California or federal law, such as race or gender declared in a job application
• Professional or employment-related information, such as job title and company name

Disclosed for a business purpose to

• BRANIA corporate affiliates
• Service providers
• Business partners
• Third-party services you choose to connect with, share information with, or direct us to share information with

Sold and/or shared with

• Advertising partners

C. Uses

We use and disclose the information we collect for the business and commercial purposes described in sections 3 and 4 above.

D. Retention

We keep personal data as described in section 8 below.

E. Sensitive personal information

BRANIA uses and discloses sensitive personal information only for the purposes permitted by section 7027(m) of the CCPA regulations.

F. Non-discrimination

California residents will not be treated less favourably by us for exercising rights the CCPA gives them.

7. International Transfers

Personal information we process may be transferred to, processed in, and stored anywhere in the world, including the United States and other countries whose data protection laws differ from those where you live. Wherever it goes, we work to safeguard it in the manner applicable law requires.

Where we transfer information to a country that has not been recognised as providing adequate protection, one of the safeguards we may rely on is Standard Contractual Clauses, such as those adopted by the European Commission.

BRANIA is also certified under the EU–US and Swiss–US Data Privacy Framework and the UK Extension to the EU–US DPF, which the European Commission has found to provide an adequate level of protection. Section 11 gives further detail on the safeguards applying to transfers from the European Economic Area, Switzerland, and the United Kingdom to the United States; you may also contact us.

8. How Long We Keep Information

We hold personal information for as long as you use the Services, or as long as is necessary to achieve the purpose it was collected for — providing the Services, resolving disputes, establishing legal defences, conducting audits, pursuing legitimate business aims, enforcing our agreements, and complying with the law.

In setting a retention period we weigh legal requirements, the volume, nature, and sensitivity of the information, the associated risks, the purposes we are processing it for, and whether those purposes can be met another way.

9. Our Lawful Bases for Processing

Where the EU or UK General Data Protection Regulation applies to your information, our processing — including for AI use cases — may rest on the following bases:

• Performance of a contract. We may need to process your information to perform our contract with you, or to take steps before entering into one. Without it we cannot deliver the Services.
• Legitimate interests. We may process information to further our legitimate interests, but only where those are not overridden by your interests or fundamental rights — for instance, analysing how the Services perform and how people use them, and improving our products, our customer service, and the Services. Where permitted, we also rely on this basis to deliver certain content to you.
• Legal obligations. We may process information to comply with the law, such as keeping payment records for tax and accounting purposes.
• Consent. In some cases we rely on your consent.

10. Children

The Services are not directed at children under 18, or such other age as local law sets, and we do not knowingly collect, sell, or share children's personal information. BRANIA has no actual knowledge of having “sold” the personal information of anyone under 16, or of having “shared” it for cross-context behavioural advertising under the CCPA.

If you are a parent or guardian and believe your child has submitted personal information to us without your consent, please contact us. Where we learn that a child has given us personal information contrary to law, we delete what we hold — unless we are legally required to keep it — and close the account if there is one.

11. Additional Provisions for EU, UK, and Swiss Individuals

If you are in the European Union, the United Kingdom, or Switzerland, the following applies to you in addition to everything above.

Data Privacy Framework

BRANIA complies with the EU–U.S. Data Privacy Framework, the UK Extension to the EU–U.S. DPF, and the Swiss–U.S. Data Privacy Framework, as administered by the U.S. Department of Commerce. We have certified to the Department of Commerce that we adhere to the EU–U.S. DPF Principles for personal data received from the European Union under the EU–U.S. DPF and from the United Kingdom and Gibraltar under the UK Extension, and that we adhere to the Swiss–U.S. DPF Principles for personal data received from Switzerland under the Swiss–U.S. DPF. Where anything in this policy conflicts with those Principles, the Principles prevail. Details of the programme, and our certification, are published on the Data Privacy Framework website.

If you are an EU, UK, or Swiss individual and we pass your personal data to third-party providers performing services for us or on our behalf, we remain responsible for their processing of it, and remain liable if they handle it in a way inconsistent with the DPF Principles — unless we are not responsible for the event that caused the harm.

In line with the EU–U.S. DPF, the UK Extension, and the Swiss–U.S. DPF, BRANIA undertakes to resolve complaints relating to the Principles about how we collect and use your personal information. If you have an enquiry or complaint about personal data we received in reliance on any of these frameworks, contact us first at Hello@brania.ai. Complaints we cannot resolve are referred to JAMS, an alternative dispute resolution provider based in the United States, at no cost to you; if you do not receive timely acknowledgement from us, or if our response does not satisfy you, JAMS publishes information on how to file. Where a dispute cannot be settled by these routes, a binding arbitration process may be available to you under certain conditions, as described in the Data Privacy Framework programme materials.

The Federal Trade Commission holds investigatory and enforcement authority over BRANIA's compliance with these frameworks. In certain circumstances, BRANIA may be obliged to disclose personal data in response to lawful requests from public authorities, including to meet national security or law enforcement requirements.

12. Other Provisions

Third-party websites and applications. The Services may link out to other sites and applications, and others may link to us. We do not control those services. We encourage you to read the privacy policy of every site and application you deal with. We do not endorse, screen, or approve them, we are not responsible for their content or their privacy practices, and any personal information you give them is given at your own risk.

13. Contact Us

If you have questions about our privacy practices or this policy, or you wish to exercise any of the rights described here, write to us at Hello@brania.ai.

For the purposes of European Union, Swiss, and UK law, BRANIA is the data controller. Our local affiliates may also act as controllers in respect of local operations such as marketing and prospecting.