Privacy Policy

Brave group Inc,（”Brave”）will handle Personal Information relating to users(hereinafter referred to simply as the “Users”, or “you” or “your”) of services provided by Brave(the “Services”) and our business partner(hereinafter referred to simply as the “Partners”) and other Personal Information which we will obtain as follows (“Privacy Policy”). In addition to this Privacy Policy, Brave may stipulate other rules relating special handling of Personal Information about the Users (the “Individual Rules”) for Braves’ individual services. In such cases, the Individual Rules shall constitute a part of this Privacy Policy, and if there is any conflict between the two, the Individual Rules shall prevail. As Brave may revise all or a part of this Privacy Policy as necessary, so please read all this Privacy Policy before using the Services.

1. Acquired information

The information that we obtain in order to achieve the purposes of use in Section 4 (the “Acquired Information”) includes the following;

Personal Information as exemplified below (“Personal Information” as defined in the Act on the Protection of Personal Information)
1. Name, date of birth, gender, occupation (including job title), and other information that may identify a specific individual
2. Information such as address, telephone number, account information (i.e., e-mail address and password), nickname, etc., which is used in connection with specific Personal Information
3. Credit card information, payment information such as crypto currency and blockchain wallet addresses
4. Hobbies, family structure, age, and other personal attribute information that is integrated with Personal Information
5. Information related to identity verification
6. Information about the Users obtained in connection with your use of the Services
Information related to the use and browsing of the Services by the User, such as the content of the Services used by the User, the date, time and number of times used, and the User’s online behavior when using the Services (including information related to the User’s communications, such as cookie information, access logs and other information related to usage status, device information used, location information, IP address, browser information, browser language, etc.)
Information regarding the payment status of the Users and the Partners in relation to the Services or business relationships.
When the User has permitted linkage with external services such as social networking services when using the Services, the ID used by the User on such external services and information that the User has permitted to be disclosed to the linked party according to the privacy settings of such external services

2. Method of collecting the Acquired Information

Brave will collect Acquired information through the following methods;

The User input on the Services directly;
The User provide the information to Brave in person, by e-mail, mail, in writing, or by telephone, etc. (When answering the phone with the User, Brave may record such call to improve the quality of the response, etc.);
Methods to collect information when the User uses or browse the Services; or
Indirect collection from business partners and third parties.

3. Security Management Measures

In order to prevent unauthorized access, theft, loss, destruction, falsification, damage, leakage, etc. (collectively, “Leakage”) of all Personal Information, Brave will properly manage such Personal Information, through establishing the rules, etc. required for managing Personal Information, and implementing the necessary security management measures as follows. In the event of entrusting the handling of Personal Information to any third party, Brave will enter into an agreement setting forth the conditions for Personal Information protection and will also control and supervise such third party in order to ensure that such Personal Information is managed in an appropriate manner.

(1) Organizational Security Management Measures

Brave will exert efforts to prevent any Leakage by way of establishing a person responsible for managing Personal Information protection, etc. in accordance with the internal rules and clearly specifying the employees in charge of each type of Personal Information handling work, and will develop a system for reporting and communication to the responsible person when any of such employees becomes aware of a Leakage, or any fact or indication of any breach of the rules regarding Personal Information handling. Furthermore, Brave will also implement a mechanism to verify the appropriateness of Personal Information handling, by establishing a person responsible for auditing Personal Information protection, etc.

(2) Human Security Management Measures

Brave will conduct training, etc. for its employees regarding the important matters concerning the handling of Personal Information, and incorporate matters pertaining to the confidentiality of Personal Information into the Work Rules, etc.

(3) Physical Security Management Measures

Brave will take various measures to prevent any Leakage, such as by using IC cards to control access to the relevant areas, protecting and managing the Personal Information by assigning passwords to any electronic media containing such Personal Information, managing any print media containing the Personal Information in lockable cabinets, and disposing of any documents, etc. containing the Personal Information in a manner that makes them difficult to be recovered.

(4) Technical Security Management Measures

Brave will take various measures to prevent any Leakage, such as limiting the information system that can handle the Personal Information database, etc. and limiting the access granted to such information system, maintaining, managing and regularly reviewing systems, and granting and controlling access to each folder for each type of Personal Information handling work.

(5) Identification of External Environment

In the case of handling Personal Information in a foreign country, Brave will identify the Personal Information protection system of that foreign country and take appropriate security management measures. Please contact Brave for the specific names of the foreign countries in which Brave handles Personal Information.

(6) Response in the Event of a Leakage

In the event of any Leakage of the Personal Information that Brave handles, Brave will provide an appropriate response, such as reporting to the supervisory authority, or notifying the relevant User thereof, etc., in accordance with the laws and regulations.

4. Purpose of use of the Acquired Information

Brave will use the Acquired Information appropriately to the extent necessary to achieve (i)the purposes notified or announced at the time of acquisition or collection, (ii)the purposes stipulated in the Terms of Use, etc., or (iii)the following purposes. In addition, Brave may change the purpose of use to the extent that it is reasonably deemed to be related to the purpose of use before such change, and Brave will announce such change in a notice when it occurred on the Services or on the website operated by us, or in any other easily understandable manner.

Information collected from the Users of the Services

For identity verification
To communicate and provide information on various matters related to the Services
To provide the Services
To simplify the input of information required for the Users registration for the Services
To link information between the Services that the Users has applied for
To confirm applications for e-mail delivery services and to deliver e-mails
To confirm and deliver purchases related to the Services
To confirm billing and payment for the Services
To send you rewards for your cooperation in surveys, etc.
To send prizes for prize competitions, etc. to which you have applied.
To survey and analyze the usage of the Services
To improve and enhance the Services to better satisfy our customers or to develop new services.
To prevent fraudulent activities that interfere with normal service provision (including detection of the Users violating the Terms of Use, etc. and notification to such users, and investigation, detection, prevention, and response to fraudulent activities such as fraud and unauthorized access that abuse the services, etc.)
To customize the contents of the Services to suit the Users.
To survey the level of satisfaction with the Services
To aggregate and publish the results of the survey of the information which is statistically processed from the Acquired Information.
To send information and notices about the Services, new services, and other various services
To request cooperation for surveys and participation in various events, and to report the results of such surveys and events.
To distribute or display advertisements of Brave or third parties
To distribute or display product information within services provided by Brave or third parties
To resolve problems in the operation of the Services and to comply with laws and regulations

Personal Information (name, affiliation, contact information, etc.) related to the Partners

To communicate, consult, place and receive orders, settle payments and execute and manage other transactions with Brave
To manage customer information
To prevent fraudulent activities that interfere with normal transactions
To send information and notices regarding the Services, new services, and other various services
To resolve problems related to transactions and to comply with laws and regulations

Personal Information regarding applicants who have applied for or participated in our recruitment activities

To provide information on recruitment and job openings, to conduct employment screening, and to confirm application histories.
To communicate with applicants and respond to inquiries from applicants
To provide information on recruitment-related events and seminars operated by Brave
To prepare statistical data for use in the formulation of our future recruitment policy, etc.
To resolve problems related to recruitment and to comply with laws and regulations

Personal Information concerning our directors, employees, retirees and their family members (hereinafter collectively referred to as the “Employees, etc.”)

To notify and communicate with the Employees, etc.
To manage the employment of the Employees, etc. (payment of compensation, etc., performance of personnel and labor management, provision of benefits, etc.)
To manage the health of the Employees, etc. and to ensure an appropriate working environment
To provide benefit services to the Employees, etc. and to handle various insurance procedures, etc.
To submit notifications and reports to government and other public offices concerning the Employees, etc.
To resolve problems related to the Employees, etc., and to comply with laws and regulations

5. Joint use

Brave may jointly use the Acquired Information as follows;

Scope of joint use Our group companies (for details, please click here )
Purpose of use
- To be used by our group companies for the same purposes as described in section4.
- To communicate and hand over information to company in charge in the event of an inquiry, application for use, or other request regarding the products or services provided by Brave or our group companies.
- For management and internal administration of our group companies.
Items of Personal Information to be jointly used Name, date of birth, address, gender, telephone number, account information, nicknames and other information, SNS account information, transaction details (including information on service usage, purchase history, payment information such as credit card information or wallet address, payment status, etc.), etc.
Responsible for the management of Personal Information used jointly Brave group Inc. (for details, please click here)

6. Provision of the Acquired Information to third parties

Brave will provide the Acquired Information to third parties within the scope permitted by law in the following cases;

Providing information on the Services in order to provide the Services.
A portion of the Acquired Information may be disclosed on the Services or provided directly to the Users to the extent permitted by law. In such cases, the Users will use the Acquired Information disclosed or provided to them only in accordance with the Terms of Use of the Services and to the extent necessary for the use of the Services.
When providing information to delivery companies, settlement agents, subcontractors, or other third parties for the purpose of product delivery, payment settlement, response to inquiries from the Users, inquiries from Brave to the Users, provision of related after-sales services, etc.
When requested by a court, administrative agency, supervisory authority, or other public agency to provide the Acquired Information in accordance with laws and regulations.
When Brave deems it necessary to provide information in order to resolve disputes with third parties or to protect the rights or interests of the Users or third parties
When providing information to a third party to whom Brave outsource such research and analysis in order to research and analyze the usage of the Services
When the information is provided to a third party for the purpose of distributing or displaying advertisements of Brave or a third party
When Brave deems it necessary to provide the Acquired Information and has obtained the User’s consent
Other cases in which the provision of information to a third party is permitted by law.

7. Outsourcing of handling of the Acquired Information to third parties

To the extent necessary to achieve the purpose of use stipulated in Section 4, Brave may outsource all or part of the handling of the Acquired Information to subcontractors. In such cases, Brave will thoroughly screen such subcontractors to ensure that they meet our standards for selecting subcontractors, and ensure that the Acquired Information is properly managed in making the contract.

8. Personally relevant information

For the purpose of maintaining and protecting the convenience improvement sessions such as automatic input of e-mail addresses when logging in to the Services, for security protection, and for researching and analyzing the usage of the Services and the effectiveness of advertisements related to the Services, Brave may acquire cookies, device type, device identifier, browser type, referrer, IP address, and other advertising identifiers (collectively, the “Personally Relevant Information”) by incorporating information collection modules selected by us, such as Google Analytics. These information collection modules collect the Personally relevant information without including personally identifiable information, and the collected information is managed in accordance with the privacy policy and other rules stipulated by each information collection module provider and Brave may use cookies and the Personally relevant information obtained from information collection module providers in conjunction with Personal Information that Brave already has.If you do not want your data to be collected by Google Analytics or other information collection modules, please reject the use of your data in the manner prescribed by Google Inc. or other information collection modules. However, if you prohibit the use of cookies and other personally identifiable information, you may not be able to use the Services properly, or you may not be able to reflect advertising settings that require Personally relevant information. For an explanation of the Google Analytics Terms of Service and Privacy Policy, please visit the following site; Google Analytics Terms of Service: https://marketingplatform.google.com/about/analytics/terms/us/ Google Privacy Policy: https://policies.google.com/privacy?hl=en Google Analytics Opt-out Add-on: https://tools.google.com/dlpage/gaoptout?hl=en

9.Retention of Personal Information

Brave will retain the Acquired Information to the extent necessary for the purposes stated in “Purpose of use of the Acquired Information” The criteria for determining the retention period includes, but is not limited to: (i) the duration of the contractual relationship between you and Brave; (ii) the legal obligations assumed by Brave; and (iii) a need to perform an agreement to which you are a party.

10.Information of minor users

If the Users are minor, the Users’ parents, guardians or guardian must agree to the contents of the Privacy Policy and Terms of Use, etc., and comprehensively agree to the Users’ use of the Services in accordance with the Privacy Policy and Terms of Use.

11. Improvement and update of the Privacy Policy

Brave will review the status of our operations regarding the handling of the Users information, etc., as appropriate, and change this Privacy Policy from time to time in response to changes in laws and regulations, business needs, etc. Brave will notify the Users of any changes to this Privacy Policy. Brave will notify the Users of any changes to this Privacy Policy, so please confirm the latest Privacy Policy before accessing or using the Services.

12. Procedures for Disclosure, Correction, Suspension of Use, etc. of Personal Information

Brave will accept requests for disclosure, correction, deletion, or suspension of use (the “Disclosure, etc.”) of Personal Information (including records of provision of Personal Information to third parties) on the Services only from the person himself/herself or his/her representative in accordance with the prescribed procedures separately stipulated by Brave. However, Brave may not be able to perform these procedures if Brave is not obligated to do so under the Act on the Protection of Personal Information or other laws and regulations, if the same request is repeated many times without justifiable reason, or if excessive technical work is required. In addition, when requesting disclosure of Personal Information, you may be required to submit identification documents and pay a disclosure fee in accordance with our separate regulations.

13. Contact for inquiries

If you have any opinions, questions, complaints, or other inquiries regarding our handling of acquired information, please contact us at the following address. Inquiries to contact@bravegroup.co.jp 7F PMO Tamachi III, 4-1-28, Shiba, Minato-ku, Tokyo Brave group Inc. Personal Information contact

Supplementary Provisions for Processing of Personal Information of EEA and UK Residents

The following supplementary provisions apply to the processing of Personal Information (meaning information relating to an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person) of residents in the European Economic Area (the “EEA”) and the United Kingdom in accordance with the General Data Protection Regulation (the “GDPR”) or the United Kingdom General Data Protection Regulation (the “UK GDPR”).

1.Legal Basis for Processing Personal Information

If you reside within the EEA or the UK, Brave shall process your Personal Information within the scope necessary for achieving the purposes of use above based on your consent to this Privacy Policy. Brave shall also process your Personal Information within the scope necessary for achieving the purposes of use above in the case where Brave’s processing of your Personal Information meets any of the following requirements:

Such processing is necessary for the performance of a contract to which you are a party or in order to respond to your request prior to entering into a contract; or
Such processing is necessary for the purposes of the legitimate interests pursued by Brave or any third party (including, without limitation, interests such as those pertaining to the provision of services by Brave).

Where provision of your Personal Information is mandatory and you choose not to provide the same, then Brave will not be able to provide you with the relevant services. You may withdraw your consent via the contact point for inquiries provided above; provided, however, that the consent which you have provided for Brave’s collection, use and provision of your Personal Information will remain valid until such time as this consent is withdrawn by you.

2.International Transfer of Personal Information

Brave may transfer your Personal Information to countries other than your country of residence, including, without limitation, Japan and the United States, for storage or other processing. Please note that the laws and regulations of such countries or regions may provide a lower level of data protection than those in your country of residence. In such cases, Brave will take the appropriate measures to protect your Personal Information in compliance with our legal obligations. As required under the GDPR or the UK GDPR, Brave protects your Personal Information by entering into Standard Contractual Clauses (Article 46(2) of the GDPR) regarding the transfer of your Personal Information outside the EEA or the UK. If you would like to review the Standard Contractual Clauses, please contact us as described via the contact point for inquiries.

3.Your Rights Under the GDPR or the UK GDPR

You have the right to request Brave: (i) for a copy of your Personal Information; (ii) to revise, delete or restrict the processing (suspend the use) of your Personal Information; and (iii) to provide you with the Personal Information you have provided to Brave for a contract or based on your consent, in a structured, machine-readable format. In addition, you may object to the processing of your Personal Information in certain circumstances (in particular, where Brave is processing the information for direct marketing purposes). However, these rights may be limited, for example if fulfilling your request would reveal Personal Information of a third party or would infringe upon the rights of a third party (including Brave’s rights), or if Brave is required by law to retain or has legitimate interests in retaining your Personal Information. Relevant exemptions are included in applicable laws on privacy. Brave will inform you of the relevant exemptions which Brave relies upon when responding to any request you make. If you wish to exercise any of these rights, please contact Brave via the contact point for inquiries. If you have any unresolved concerns, you may lodge a complaint with an EU data protection authority having jurisdiction over the area in which you live or work, or where you believe a breach may have occurred.

Supplementary Provisions for Processing of Personal Information of U.S. California Residents

The following supplementary provisions apply to the processing of Personal Information (any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household; the same shall apply to these supplementary provisions hereinafter) of U.S. California residents in accordance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA; collectively, the “California Privacy Laws”).

1.Information Collected by Brave

Brave has collected in the last twelve (12) months and will continue to collect the following categories of Personal Information from you for the purposes stated in “Purpose of use of the Acquired Information.”

Category	Examples
Identifiers	Name, date of birth, gender, occupation (including job title), address, telephone number, account information (i.e., e-mail address and password), nickname, hobbies, family structure, age
Commercial information	Credit card information, payment information such as crypto currency and blockchain wallet addresses, payment information for the Services or our transactions
Internet or other electronic network activity information	Information related to the use and browsing of the Services by the User, such as the content of the Services used by the User, the date, time and number of times used, and the User’s online behavior when using the Services (including information related to the User’s communications, such as cookie information, access logs and other information related to usage status, device information used, location information, IP address, browser information, browser language, etc.)
Professional or employment-related information	Information regarding the department in or company by which you are employed (company name, address, telephone number)
Sensitive Personal Information	[Credit card number, ID and password]

2.Disclosure of Personal Information

Brave may disclose your Personal Information (including sensitive Personal Information; the same shall apply to these supplementary provisions hereinafter) to third parties for business purposes. When disclosing Personal Information to a service provider or contractor for such purpose, Brave executes an agreement that indicates such purposes and requires that the service providers or contractors keep such Personal Information confidential and not use Personal Information for any purpose except performing such agreement. Brave has shared or disclosed Personal Information to the following categories of third parties for business purposes during the last twelve (12) months:

Our group companies (for details, please click here); and

[Purposes of sharing and disclosure]

To be used by our group companies for the same purposes as described in “Purpose of use of the Acquired Information.”
To communicate and hand over information to a company in charge in the event of an inquiry, application for use, or other request regarding the products or services provided by Brave or our group companies.
For management and internal administration of our group companies.
Delivery companies, settlement agents, subcontractors, or other third parties.

[Purposes of sharing and disclosure]

For the purpose of product delivery, payment settlement, response to inquiries from the Users, inquiries from Brave to the Users, provision of related after-sales services.
To research and analyze the usage of the Services

3.Sale or Sharing of Personal Information

Brave has not sold [or shared] any Personal Information in the preceding twelve (12) months. [In the preceding twelve (12) months, Brave has distributed cross-text behavioral advertisements by sharing online identifiers, etc. collected from you with advertising companies, etc. If you do not wish for cross-context behavioral advertisements to be distributed, please perform the procedures described in “Do Not Share My Personal Information.”] In these supplementary provisions, the term “sale” means disclosing, etc. your Personal Information to a third party for monetary or other valuable consideration, and the term “sharing” means disclosing your Personal Information to a third party for cross-text behavioral advertisements, regardless of monetary or other valuable consideration.

4.Your Rights and Choices Under the California Privacy Laws

The California Privacy Laws grant rights regarding Personal Information to consumers who are residents of California. The following describes your rights and how to exercise those rights under the California Privacy Laws. (1) Right to Access Specific Information You have the right to request that Brave disclose certain information to you in relation to the collection, sharing, disclosure, or use of your Personal Information by Brave. Upon receipt and confirmation of your verifiable consumer request, Brave will disclose to you any or all of the following information: (i) The categories of your Personal Information that Brave has collected; (ii) The categories of sources of your Personal Information from which Brave has collected; (iii) The business or commercial purpose of Brave for the collection, sale, or sharing of such Personal Information; (iv) The categories of third parties Brave discloses, sells, or shares such Personal Information; (v) The categories of your Personal Information that Brave has disclosed, sold, or shared to each; and (vi) The specific pieces of your Personal Information that Brave has collected. (2) Right to Request Deletion You have the right to request that Brave delete any of your Personal Information that Brave has collected from you and retained, subject to certain exceptions. Upon receiving your verifiable consumer request, Brave will delete your Personal Information from our records and will notify any service providers and contractors, as well as third parties to which Brave has sold or with which Brave has shared Personal Information, that they must delete such Personal Information from their records, unless an exception applies. Brave may deny your request to delete your Personal Information if it is necessary for Brave or Brave’s service providers or contractors to retain your Personal Information in order to: (i) Complete the transaction for which Brave collected the Personal Information, fulfill requirements for a product recall conducted in accordance with a written warranty or federal law, provide a good or service that you requested, enable you to take measures reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform an agreement between Brave and you; (ii) Provide support to ensure the security and integrity of your Personal Information to the extent reasonably and proportionally necessary for the purpose of use; (iii) Debug products to identify and repair errors that impair existing intended functionality; (iv) Exercise free speech, ensure the right of other persons to exercise their free speech rights, or exercise other rights provided by law; (v) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres or adapts to all other applicable ethics and privacy laws, where Brave’s deletion of such information may render impossible or seriously impair the ability to compete such research, if you previously provided informed consent; (vii) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Brave and compatible with the context in which you provided the information; or (viii) Comply with legal obligations. (3) Right to Request Correction of Inaccurate Personal Information You have the right to request that Brave correct any inaccuracies in your Personal Information that Brave retains in view of the nature of the Personal Information and the purpose of processing the Personal Information. Upon receipt and confirmation of your verifiable consumer request, Brave will use commercially reasonable efforts to correct inaccurate Personal Information as you instruct in accordance with laws and regulations. (4) Right to Opt Out Brave has not and will not sell [or share] any Personal Information collected from you. [In the preceding twelve (12) months, we have distributed cross-context behavioral advertisements by sharing online identifiers, etc. collected from you with our advertising companies, etc. If you do not wish for cross-context behavioral advertisements to be distributed, please perform the procedures described in “Do Not Share My Personal Information.”] (5) Right to Request Restriction of Use Brave will not use or disclose sensitive Personal Information collected from you for purposes other than the following: (i) To provide products and services that are reasonably expected by average consumers; (ii) To provide support for ensuring security and integrity; (iii) For short-term temporary use (except for any use involving profiling or modification to future consumer experiences); (iv) To provide services on behalf of Brave; and (v) To maintain or improve the quality and safety of Brave’s services and devices. (6) Right of Non-Discrimination Brave shall not discriminate against California residents for exercising any of their rights under the California Privacy Laws. Moreover, unless permitted by the California Privacy Laws, Brave will not engage in any of the following acts: (i) Deny goods or services to you; (ii) Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (iii) Provide you with a different level or quality of goods or services; or (iv) Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. (7) Exercising Your Rights To exercise your rights under the California Privacy Laws, please submit a verifiable consumer request to Brave by contacting us via the contact point for inquiries. Only you, a natural person authorized by you, a person registered with the California Secretary of State, a person entrusted by you, or your conservator may submit a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. A “verifiable consumer request” must: • Provide sufficient information that allows Brave to reasonably verify that you are the person whose Personal Information Brave has collected or an authorized representative thereof; and • Describe your request with sufficient detail that allows Brave to properly understand, evaluate, and respond thereto.

5.Processing of Personal Information of Children

Our services are not directed to and we do not knowingly collect Personal Information from anyone under the age of 13 or share the Personal Information of anyone under the age of 16. If we learn that we have collected or shared Personal Information of a child in violation of this Privacy Policy without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us via the contact point for inquiries.

Revised: Sep. 6, 2024