Last Updated: May 2020
WHAT INFORMATION DO WE COLLECT?
**INFORMATION YOU PROVIDE TO US
Personal Information: We may ask you to provide us with certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address, and mobile number (“Personal Information”). We may collect this Personal Information through various forms and in various places through the Services, including account registration forms, contact us forms, or when you otherwise interact with us. When you sign up to use the Services, you create a user profile. The current required data fields are:
- Mobile Phone Number
- Zip Code
If you choose to upload a photo when registering for our Services, the photo may be viewable by us and by the tipper who is providing the gratuity so that they are able to verify your identity. You may remove or update the photo at any time by logging into your account.
Other information required to approve an account to get paid includes address and date of birth per bank regulations. Information may include cars, CVV code, billing address and expiration date. To receive funds, we will ask for routing number and bank account number. This information is not stored by BRAVO. It is provided to our payments processor to facilitate your automatic deposits to receive your funds. In the event of a discrepancy of name or address or a question relating to a payment, we might request a government issued ID or prove of residence. However, this is an uncommon request and only to prevent fraud and protect your account and funds. This information is shared with our payments processors in order to approve your merchant account to get paid.
**INFORMATION WE COLLECT AS YOU ACCESS AND USE OUR SERVICES
In addition to any Personal Information or other information that you choose to provide to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer, mobile or other device used to access the Services (any, a “Device”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier. Usage Information may be anonymous or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information. In addition, tracking information is collected as you navigate through our Services, including, but not limited to geographic areas. The mobile phone (tipper’s and tippee’s) will send GPS coordinates to our servers. We collect this geolocation information for various purposes, including to determine the tip for the location and service, industry and to provide you with customer support, to send you promotions and offers, to enhance our Services, and for our internal business purposes. We may also have features that allow you to share this information with other people (such as your family, friends or colleagues).
A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):
Web Beacons: small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our web and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened or to count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to our customers’ Personal Information.
Embedded Scripts: an embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
**INFORMATION THIRD PARTIES PROVIDE ABOUT YOU
**INFORMATION YOU PROVIDE ABOUT A THIRD PARTY
If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Services. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program, and do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality through our Services, your e-mail address may be included in the communication sent to your friend.
**INFORMATION COLLECTED BY MOBILE APPLICATIONS
Our Services are primarily provided through an application on your mobile, tablet computer or similar device (“Mobile Application”). You agree that we may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.
When you use any of our Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), including without limitation:
- Your preferred language and country site (if applicable)
- Your phone number or other unique device identifier assigned to your mobile device – such as the International Mobile Equipment Identity or the Mobile Equipment ID number
- The IP address of your mobile device
- The manufacturer and model of your mobile device
- Your mobile operating system
- The type of mobile Internet browsers you are using
- Your geolocation
- Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the mobile application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application
- Information to allow us to personalize the services and content available through the Mobile Application
We may use information automatically collected by the Mobile Application (including the Mobile Device Information) in the following ways:
- To operate and improve our Mobile Applications, other Services, our company’s services, and tools;
- To create aggregated and anonymized information to determine which Mobile Application features are most popular and useful to users, and for other statistical analyses;
- To customize the content or services on the Mobile Application for you, or the communications sent to you through the Mobile Application.
We will not provide a tipper’s Personal Information (such as your first name and your photo, if you have chosen to upload your photo to your profile) to the tippee/partners who received a gratuity and comments. The employers of the tippee will be able to access the tippee’s Personal Information, including his/her geo-location data.
We may associate your unique mobile Device Identifier or Mobile Application usage information with any Personal Information you provide, but we will treat the combined information as Personal Information.
**INFORMATION COLLECTED FROM A TIPPEE
If you join Bravo as a tippee through our web site(s), we will collect Personal Information such as your name, email address, phone number and may collect additional information such as resume, ratings, gender, and your ethnicity.
HOW DO WE USE THE INFORMATION COLLECTED?
Our primary goal in collecting your Personal information or Usage Information is to provide you with an enhanced experience when using the Services.
Based upon the Personal Information you provide us when registering for an account, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email, telephone, or SMS or text message, in accordance with your wishes.
We use your information to closely monitor which features of the Services are used most, to allow you to view your tip history, view any promotions we may currently be running and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and/or resources.
We use the information collected from our Mobile Application so that we are able to serve you the correct app version depending on your device type, for troubleshooting and in some cases, marketing purposes. The credit card information you provide in your personal profile at sign-up is not stored by us, but is stored and used by our third party payment processor(s) in order for them to process your payments made in connection with the Services. We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer our web site(s). Your IP address is used to help identify you, but contains no personal information about you.
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Please note that information submitted to the Services via a “contact us” or other similar function may not receive a response.
HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?
**WHEN YOU AGREE TO RECEIVE INFORMATION FROM THIRD PARTIES
**THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
We use third party companies and individuals to facilitate our Services, provide or perform certain aspects of the Services on our behalf, such as tippee and companies they work for to provide the Services, and other third-parties to host the Services, perform payment processing, design and/or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, provide customer support, provide geo-location information to our tippee, enable us to send you special offers, perform technical services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services‘ features), or perform other administrative services. We may provide these vendors with access to user information, including Personal Information; this information sharing is limited to only the information needed by the vendor to carry out the services they are performing for you or for us. Each of these vendors are obligated not to disclose or use Personal Information for any other purpose.
While we may use third party analytics service providers to evaluate and provide us with information about the use of the Services and viewing of our content, we do not share Personal Information with these analytics service providers, but they may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information.
Certain aspects of the Services may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors and charities, and may require you to disclose Personal Information to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you may be providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Service with a username and password obtained through our Services, your Personal Information may be disclosed to the identified third parties for that Co-Branded Service and will be subject to their posted privacy policies.
SWEEPSTAKES, CONTESTS AND PROMOTIONS
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
ADMINISTRATIVE AND LEGAL REASONS
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; (ii) to protect and/or defend the Terms and Conditions for online and mobile Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Company, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; an /or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.
We may share your information, including your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
WHAT ABOUT INFORMATION I DISCLOSE PUBLICLY?
** USER GENERATED CONTENT AND PUBLIC INFORMATION
To request removal of your User Content from our blog or community forum or similar features, contact us through firstname.lastname@example.org. In some cases, we may not be able to remove your User content, in which case we will let you know if we are unable to do so and why.
However, any content published by you on BRAVO might be removed from our platform but no other platforms that might have copied and broadcasted it so, think twice before posting content as it will be potentially seen by countless people all over the world.
Most non-payment related activities on BRAVO are public, including your profile information, location and language when you created your account, and your postings and certain information about your postings like the date, time, and application. The lists you create, people you follow and who follow you, send you messages and/or likes, emojis, messages in your postings and re-postings are also public. If you like, re-post, reply, or otherwise publicly engage with an ad on our services, that advertiser might thereby learn information about you associated with the ad with which you engaged such as characteristics of the audience the ad was intended to reach. Any likes, comments, or other content you contribute to another account’s broadcast will remain part of that broadcast for as long as it remains on BRAVO. Information posted about you by other people who use our services may also be public.
You are responsible for your content and other information you provide through our services, and you should think carefully about what you make public, especially if it is sensitive information. If you update your public information on BRAVO (profile, content), we will reflect your updated content on BRAVO.
By publicly posting content on BRAVO, you are directing us to disclose that information as broadly as possible, including through our APIs.
NAME AND LIKENESS
We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Services, please review our Terms and Conditions.
DOES THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES APPEAR ON THE SERVICES?
The Services may contain content that is supplied by a third party, and those third parties may collect web site usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from one of our websites onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third party web sites or applications before submitting any Personal Information to third parties.
WHAT ABOUT SOCIAL MEDIA FEATURES AND WIDGETS?
HOW DO I CHANGE MY INFORMATION AND WHAT IF I CANCEL MY ACCOUNT?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through email@example.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
You may also cancel or modify your communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.
If you wish to cancel your account or request that we no longer use your information to provide you services, contact us through firstname.lastname@example.org.
We will retain your Personal Information and Usage Information (including geo-location) for as long as your account with the Services is active and as needed to provide you services. Even after your account is terminated, we will retain your Personal Information and Usage Information (including geo-location, trip history, transaction history) as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other lawful business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
WHAT SHOULD PARENTS KNOW ABOUT CHILDREN?
The Company cares about the safety of children. Because our Services are not directed toward minors, no one under 18 (and certainly no children under 13) are allowed to register with or use the Services. We do not knowingly collect personal information from anyone under the age of 18. If we discover that we have collected personal information from a person under 18, we will delete that information immediately. If you are a parent or guardian of a minor under the age of eighteen (18) and believe he or she has disclosed Personal Information to us, please contact us at Privacy at Bravo.
WHAT ABOUT SECURITY?
The Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information – such as any portions of your credit card number which we retain (we do not ourselves retain your entire credit card information) and geo-location information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to the Company you do at your own risk. We recommend that you not disclose your password to anyone.
YOUR CALIFORNIA PRIVACY RIGHTS
California’s “Shine the Light” law, California Civil Code § 1798.83, requires certain businesses to respond to requests from California customers (those who have an established business relationship with us) asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes unless the customer first affirmatively agrees to the disclosure (opt-in) or if the customer has exercised an option to opt-out of such information-sharing (opt-out).
We have elected to follow this alternative approach and, therefore, we do not share Personal Information of customers to third parties for the third parties’ direct marketing purposes unless you provide us with permission at the time you provide such Personal Information.