Brave Publishers and Creators Privacy Notice

ARCHIVED 2024-09-08, DATE APPROXIMATE · VERSION 20240908_rev01 · COMPARED WITH 20240101_rev01

Full text changes — 20240101_rev01 to 20240908_rev01

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

 | To maintain accounts, statistics, and billing with publishers and creators that have signed up as Brave business partners. | Name, e-mail address, Uphold wallet ID, phone number, names and URIs[1]() of websites, Youtube, Twitch etc., including their favicons or avatars, an internal publisher ID, and transaction details. | 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). | The duration of the creator's account with Brave. |
 | To enable all publishers and creators to accumulate contributions of BAT from Brave, and from Brave users. | Names and URIs[1]() of websites, Youtube, Twitch etc., and publicly available contacts, and transaction details. | Our interest in providing publishers and content creators with BAT as soon as they start to work with Brave. The data are used in a way that does not negatively affect your rights or interests. | Indefinite. |
 | 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", ads and "user growth pool" BAT grants. | Name, e-mail, phone number, IP address, 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/).
+To contact our data protection officer and privacy team with privacy related enquiries, or to exercise your data protection and privacy rights, email [privacy@brave.com](mailto:privacy@brave.com).
+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:
+It's Brave's policy to not collect personal data[2]() unless it's necessary to provide services to our users, or to meet certain legal obligations. We do not buy or sell personal data about consumers.
+Where we process personal data about you (subject to laws such as the EU General Data Protection Regulation ([GDPR](https://brave.com/glossary/gdpr/)), or California privacy [laws](https://cppa.ca.gov/regulations/) such as the [CCPA](https://brave.com/glossary/ccpa/) or CPRA), you have the following rights:
+- **Right to be informed**: You have the right to know what personal data we process about you and why, together with information about your rights. We explain this via our product privacy policies and/or contextual privacy notices.
+- **Right of access**: Where we process personal data about you, you have the right to request a copy of it.
+- **Right to delete**: When certain grounds apply, you can ask us to delete personal data we are processing about you. Please note, we have a separate global policy for Brave Search results and the [right to be forgotten](https://search.brave.com/help/brave-search-index-right-to-be-forgotten).
+- **Right to rectification**: You can ask us to correct inaccurate personal data and/or to update incomplete data.
+- **Right to restriction**: In certain circumstances, you can request that we refrain from processing your personal data.
+- **Right to object**: In certain circumstances, you can object to the processing of your personal data (for example to object to the use of your data for profiling and/or purely automated decision making). Please note that we do not buy or sell personal data about consumers.
+- **Right to data portability**: In certain circumstances you have the right to request and receive personal data in a structured, commonly used, machine readable format that makes it possible to reuse the data. Please note, anonymous data is not subject to this right.
+- **Right to lodge a complaint with a regulatory authority**: Brave is based in the USA. The authority to lodge a complaint about Brave will depend on where you live. If you're in the EU you can contact our nominated representative under the General Data Protection Regulation (GDPR), or you can complain to the [Irish Data Protection Commissioner](https://www.dataprotection.ie/). If you're in the UK you can complain to the [Information Commissioner's Office](https://ico.org.uk/). If you're in California you can complain to the [California Privacy Protection Agency](https://cppa.ca.gov/).
+For EU residents, we have appointed a nominated representative under the GDPR to act on our behalf regarding GDPR compliance. You may contact our nominated representative if you wish; however, the representative will refer enquiries to Brave's data protection officer for consideration.
+Our EU nominated representative is:
 Brave EU Nominated Representative
 Care of Castlebridge
+Unit 7, 12 Mountjoy Square,
+Dublin 1
+New Work Junction
+Clonard, Wexford
 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/about-edpb/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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 . For an explanation of what a URI is see [https://en.wikipedia.org/wiki/Uniform\_Resource\_Identifier](https://en.wikipedia.org/wiki/Uniform_Resource_Identifier). If some of the names of these websites and channels that Brave has recorded to facilitate BAT gifts from Brave and donations from users happen to contain people's names, then we treat these URLs as personal data. [↩︎]()
+. Personal data means any information that relates to an identified or identifiable living individual. In the USA, this is often referred to as Personal Information (PI) or Personally Identifiable Information (PII). These terms are equivalent but not identical.
+    This can include information that can directly identify an individual-such as name or email address-and any other information that may make a person indirectly identifiable-such as online identifiers that could be combined with other data to identify an individual, or used on their own to single out individuals and distinguish one person from another with an intent to learn something about them or to take an action towards them. [↩︎]()