Privacy Policy

Learn more about Brame, what personal data we collect and why we collect it, and why creating your gamification marketing campaigns with us is safe and easy.

Last updated: 04 August 2022

This Privacy Policy describes our policies and procedures for the collection, use and disclosure of personal information collected through your access and use of Brame Ltd’s (“BRAME”) mobile applications and/or website (the “APP/WEBSITE”).

1) What personal data does BRAME collect?

When you visit BRAME’s WEBSITE, BRAME stores certain information about your browser, operating system and IP address.

When you use a contact form, BRAME collects the information you provide to BRAME. This may include the following information: Your first and last name, email addresses, phone numbers, location (country, city) and name of your company.

2) How does BRAME collect your personal information?

In most cases, BRAME collects personal information directly from you. However, BRAME may also obtain personal data from third parties where applicable national laws grant BRAME to do so. BRAME will treat such personal data in accordance with this Privacy Policy and under any additional restrictions imposed on BRAME by the third party that provided the personal data to BRAME or by applicable national laws. These third party sources include, but are not limited to, third parties that you have directed to share your personal information with BRAME.

3) How or for what purpose does BRAME use your personal data and on what legal basis does BRAME use it?

Processing for the performance of contractual obligations. BRAME needs your personal data to deliver its Services under an existing contract between you and BRAME, to enter into a contract between you and BRAME for its Services or to send you invoices for ordered Services. BRAME processes personal data for the purpose of fulfilling contractual obligations under Article 6(1)(b) DSGVO.

Processing for compliance with legislation. In particular, BRAME and its Services may be subject to export regulations and other requirements of various countries, compliance with which requires an examination of your personal data. BRAME processes personal data for the purposes of legal compliance pursuant to Article 6(1)(c) DSGVO.

Processing on the basis of a legitimate interest of BRAME. BRAME may use your personal data on the basis of its legitimate interest under Article 6(1)(f) DSGVO as follows:

  • Fraud and legal claims. If necessary, BRAME will use your personal data for the purposes of preventing or prosecuting criminal offences, for example fraud, and for asserting legal claims or defending against legal claims.
  • Questionnaires and Surveys. BRAME may invite you to participate in customer surveys. The questionnaires used for this purpose are generally designed in such a way that they can be answered without providing personal data from which you can be identified. If you nevertheless provide such personal data in a questionnaire or survey, BRAME will use such personal data to improve its services.
  • Contract Performance. If you purchase or intend to purchase Services from BRAME on behalf of a corporate client or are otherwise the designated contact for the business relationship between a corporate client and BRAME (a “Principal Contact”), BRAME will use your Personal Data for that purpose.
  • Creation of anonymized data sets. BRAME will anonymize Personal Data covered by this Privacy Policy to create anonymized data sets, which will then be used to improve the services of BRAME and its affiliates.
  • Personalized Content. When you consent to receive marketing communications, such as newsletters or brochures from BRAME, among others, BRAME collects and stores details about how you interact with that content in order to design, develop, deliver, perform and improve our communications with you. This information is aggregated and drawn upon so that BRAME can provide you with more useful information and identify what is of most interest to you.
  • To keep you informed and to solicit feedback. As part of an existing business relationship between you and BRAME, BRAME may, to the extent permitted by local law, inform you of services that are similar to or related to services you have already purchased or use from BRAME. Further, if you attend a BRAME webinar, seminar or event, download newsletters, videos, free trials of software, or purchase services from BRAME, BRAME may contact you to solicit feedback with a view to improving the materials or services in question.
 

Processing based on your consent. In the following cases, BRAME processes your personal data on the basis of your previously given consent to the specific proposed processing of your personal data pursuant to Article 6(1)(a) DSGVO:

  • Marketing / news about services provided by BRAME. Subject to relevant provisions and your consent, BRAME may use your personal data to contact you regarding any matter related to your activities on the WEBSITE. In particular, but not limited to, BRAME may use your name, email address, postal address, telephone number, and an interaction profile based on your past interactions with BRAME to keep you informed of current product announcements, software updates and upgrades, special offers, and other information regarding BRAME software and services, and BRAME events, and to display relevant content on BRAME’s WEBSITE.
  • Sharing your personal information with third parties. At your request and in accordance with your consent, BRAME may provide your personal data to third parties.
 

Withdrawal of your consent. You may revoke any consent given under this Privacy Policy at any time by withdrawing it. In the event of withdrawal, BRAME will no longer process the personal data to which the consent applied, unless there is another legal basis for processing personal data. The revocation has no effect on BRAME’s past processing of personal data up to the time of the revocation.

4) How does BRAME protect your personal data?

BRAME restricts access to Personal Data to those BRAME employees or other parties who need access to such Personal Data in order to provide the Services. BRAME takes reasonable physical, electronic and procedural safeguards to protect your Personal Data, including firewalls, individual passwords and encryption and authentication technologies, and takes all other necessary and appropriate administrative, organizational, technical, personnel and physical measures to protect against unauthorized or unlawful processing and use, accidental loss or destruction, or damage, theft, disclosure or alteration and to safeguard your integrity.

Please note, however, that data transported over an open network, such as the Internet or e-mail, may be accessible to anyone. BRAME cannot guarantee, and is not responsible for, the confidentiality of communications or information transmitted over such open networks. When you share data over an open network, you should keep in mind that it is potentially accessible to others and, as a result, may be collected and used by others without your consent. In particular, while individual data packets are often encrypted, the names of the sender and recipient are not. Even if the sender and recipient are in the same country, data can be transmitted regularly and uncontrolled to other countries via such networks, including countries that do not offer the same level of data protection as Switzerland. Your data and information may be lost during transmission or accessed by unauthorized persons. BRAME accepts no liability for any direct or indirect loss relating to the security of data and information during transmission over the Internet.

5) How long will your personal data be kept?

BRAME will retain your personal data only for as long as is necessary for the purposes for which it is processed or for as long as you withdraw your consent given in this Privacy Policy, to the extent that BRAME processes your personal data on the basis of your consent.

6) With whom is your personal data shared?

Personal data will be shared with the following categories of third parties for processing:

  • Companies with a direct or indirect connection to BRAME.
  • Third party service providers, e.g. for consulting services and other additional services.

 

The concept of the APP/WEBSITE involves the disclosure of personal data provided by you and accessible through the APP/WEBSITE to third parties for the purposes of marketing activities, technical support and security audits and all activities aimed at the secure provision of the Service. In doing so, BRAME shall endeavor to ensure that the third parties comply with the GDPR.

7) Cookies and similar technologies

BRAME may use cookies to make the visit to the WEBSITE more attractive and to enable the use of certain features. These are small text files that are stored on your computer. Most of the cookies used are deleted from your hard drive at the end of the browser session (so-called session cookies). Other cookies remain on your computer and enable us to recognize you on your next visit (so-called permanent cookies).

You can prevent the storage of cookies in your browser by restricting or turning off the storage and reading of cookies. Please note that you will not be able to use certain features of the WEBSITE without cookies.

BRAME may use third party services such as YouTube, Twitter, Google Maps, Google Ads, Google Custom Search, Facebook, Instagram, etc. and integrate them directly into the WEBSITE. These sites or services are offered and operated by third parties. Each of these sites has its own privacy policy. The providers also use cookies, among other things. When using the WEBSITE, user data may be automatically transmitted to these companies. The data protection provisions of the respective provider expressly apply. Users must be aware that data may be collected via these services and may also be passed on to third parties. If users simultaneously use an account of a service, the operator can assign this transmitted information directly to the respective personal account.

BRAME has no influence on the data collection and its further use by these operators. To what extent, where and for how long the data is stored, to what extent they comply with any existing deletion obligations, what evaluations and links they make with the data and to whom they pass on the data, is not discernible for BRAME.

The main services operated by third parties that BRAME uses are:

Google Analytics:

We use Google Analytics on our WEBSITE to understand how long a visitor stays on our WEBSITE, which pages he/she finds most useful, and how he/she navigates through our WEBSITE. To learn more about Google Analytics and how to opt out, visit the Google Analytics website: https://analytics.google.com

Facebook for Developers:

We have implemented a simplified sign-in method for some of our applications. We use Facebook for Developers (formerly Facebook Connect) to allow you to sign in using your existing Facebook login.

8) Your privacy rights

You have the right to be informed by us about the processing of your personal data and to receive a copy of our personal data (right of access). If you are affected by inaccurate or incomplete personal data, you may request the correction or completion of the personal data in question (right to rectification). You may request the erasure of your personal data (right to erasure) or, in certain cases, temporary restriction of processing (right to restriction of processing). You may object to the processing of your personal data (right to object) and have the right to receive your personal data in a structured, commonly used and machine-readable format or to transfer your personal data to another controller where technically feasible (right to data portability).

Your rights are subject to the limitations necessary to comply with (a) applicable laws, regulations, legal process or governmental requests; and (b) in connection with legal proceedings (including prospective legal proceedings), obtaining legal advice or exercising or defending legal rights.

Further, keep in mind that once you request deletion of your personal information, you will no longer be able to use BRAME services that require BRAME to use your personal information.

 

If you believe that BRAME is not processing your personal data in accordance with the requirements described in this Privacy Policy or with applicable data protection laws, you may at any time file a complaint with the supervisory authority having jurisdiction over you.

9) How can you exercise your data protection rights?

Direct all requests related to the exercise of your rights to info@brame.ch.

BRAME will reject requests that are manifestly unfounded, disproportionate, fraudulent or not otherwise obligated by applicable laws.

10) Disclosure of personal data

We reserve the right to disclose Personal Data as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms, including investigation of a possible breach thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to support requests from Users, or (v) protect the rights, property, or safety of BRAME, its Users, and the public.

11) Additional Points

Please note that BRAME uses encryption software that may be subject to export control regulations.

The APP/WEBSITE may contain links to apps/sites or materials that are not operated by BRAME. These other apps/sites are not subject to this Privacy Policy, and BRAME is not responsible in any way for the content or accuracy of such apps/sites or for the policies that apply to the handling of personal data and information. Connecting to or otherwise accessing such Apps/Sites is at your own risk. We encourage you to read the policies used by such apps/sites to determine how they protect your personal data and information and whether they are trustworthy.

In general, the WEBSITE and Services are not directed to users under the age of 16 or under the appropriate minimum age applicable in the relevant jurisdiction.

12) Updates to this Privacy Policy

BRAME may revise this Privacy Policy from time to time. The most current version will always be available on our APP/WEBSITE (www.brame.ch). The revised Privacy Policy will be effective as of the date it is posted on the APP/WEBSITE. If these changes are material, we will notify you and, if required by applicable law, obtain your consent. This notice will be provided to you by email or by posting on the APP/WEBSITE.

13) Data Controller and Data Protection Officer

If you are dissatisfied with any aspect of the processing of your personal data, we would like to understand how we can resolve this issue.

 

Please contact us at:

Brame Ltd.

Neuhofstrasse 10

CH-8834 Schindellegi

Switzerland

 

The Data Protection Officer is located at the same address and can be contacted by mail or e-mail at:

Dmytro Shyshchenko

Neuhofstrasse 10

CH-8834 Schindellegi

Switzerland

info@brame.ch

14) Jurisdiction

This Privacy Policy is governed in all respects by Swiss substantive law. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts located at BRAME’s registered office, and you consent to the jurisdiction and venue of such courts and waive any objection to inconvenient forum.

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