Brave Publishers and Creators Privacy Notice

DATED 2022-02-18 · VERSION 20220315_rev01 · COMPARED WITH 20220205_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20220205_rev01 to 20220315_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+LAST UPDATED January 5, 2021
+LAST UPDATED February 18, 2022
 Read this document to learn how we use data for publishers and content creators. In this policy "we", "us", etc. refers to Brave Software Inc.
 (To learn how we use data to operate this website and other Brave sites, forums, and communications, see the [Website Privacy Policy](https://brave.com/privacy/website/). To learn how we use data for the Brave Browser, see the [Brave Browser Privacy Policy](https://brave.com/privacy/browser/)).
 ## Basic Attention Token Tips
 | To comply with tax obligations. | Uphold wallet ID (plus Brave revenue from transactions, which are not personal data), and transaction details. | Necessary for compliance with a [legal obligation](https://www.irs.gov/businesses/small-businesses-self-employed/how-long-should-i-keep-records). | 4 years after end of creator's account. |
 | Internal communications. | Name, e-mail address, and internal publisher ID at the time of communication. | Necessary for the performance of [the contract agreed between both the creator and Brave](https://basicattentiontoken.org/publisher-terms-of-service/) (and necessary for us to provide the requested service). | Indefinite. |
 | To detect fraudulent claims of "referral rewards" and "user growth pool" BAT grants. | Name, e-mail, phone number, names and addresses of channels (websites, Youtube, Twitch URI[1]() etc.) including their favicons or avatars, an internal publisher ID, internal identifiers. Where PayPal is used, the PayPal user's country, verification status, and PayPal account ID. | Necessary for the performance of [the contract agreed between both the creator and Brave](https://basicattentiontoken.org/publisher-terms-of-service/) (and necessary for us to provide the requested service). | Necessary for the performance of the contract agreed between both the creator and Brave (and necessary for us to provide the requested service). The duration of the creator's account with Brave. (Data may be stored indefinitely in the case of detected fraudsters). |
 We are always interested in hearing and responding to questions and concerns at [twitter.com/brave](https://twitter.com/brave) and at [github.com/brave](https://github.com/brave). More in-depth conversations can be had at [community.brave.com](https://community.brave.com/).
+You can contact our data protection officer and the rest of our privacy team at [privacy@brave.com](mailto:privacy@brave.com). We are represented in Europe by Brave Software Europe Ltd.
+We are represented in Europe by Brave Software Europe Ltd (based in the UK). You can contact our data protection officer and the rest of our privacy team at [privacy@brave.com](mailto:privacy@brave.com). However, from the 1st January 2021, given the UK's exit from the EU, Brave has appointed an EU nominated representative and which you may contact if you would prefer not to contact Brave directly:
+Brave EU Nominated Representative
+Care of Castlebridge
+Unit 7, 12 Mountjoy Square,
+Dublin 1
+Ireland
+[brave@gdprnomrep.eu](mailto:brave@gdprnomrep.eu)
 You can ask to know what information we have about you, update incorrect information, delete it, object to our use of it, or get a copy of it. If you're in the European Union, you also have the right to complain to your [local data protection authority](https://edpb.europa.eu/about-edpb/board/members_en) (though everyone should have this right).
 We'll update this policy whenever we make material changes to our practices, and we'll announce it to let you know.
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