Privacy Policy

At BrandWell, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, and disclose information when you use our services, and outlines your rights as a user of our platform.

We may collect personal data in order to provide and improve our services to you. By using BrandWell, you consent to the collection and use of your information in accordance with this Privacy Policy.

Throughout this document, capitalized terms have specific meanings as defined in the following section. These definitions apply whether the terms are used in singular or plural form.

1. Definitions

For the purposes of this Privacy Policy:

(a) “Account” means a unique account created for You to access our Service or parts of our Service.

(b) “Business”, for the purpose of the CCPA (California Consumer Privacy Act), means the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

(c) “Company” (referred to herein as either the “Company”, “We”, “Us” or “Our”) means Workado, LLC (DBA BrandWell), an Arizona business with offices at 20280 North 59th Avenue | 115-141, Glendale, AZ 85308. For the purpose of the GDPR, the Company is the Data Controller.

(d) “Consumer”, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

(e) “Cookies” means small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

(f) “Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), means the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

(g) “Device” means any electronic device that can access the Service such as a computer, a cell phone or a digital tablet.

(h) “Do Not Track (DNT)” means a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

(i) “Personal Data” means any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

(j) “Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

(k) “Service” means the online and/or mobile services, web site, and software provided on or in connection with the service provided by BrandWell under this Agreement and as detailed on BrandWell’s website at brandwell.ai

(l) “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Process

(m) “Third-party Social Media Service” means any website or any social network website through which a User can log in or create an account to use the Service provided by BrandWell.

(n) “Usage Data” means data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

(o) “Website” means https://brandwell.ai/

(p) “You” means the individual accessing or using the Service provided by BrandWell, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

2. Collection and Use of Personal Data by BrandWell

(a) Personal Data:

When using our services, we may request that you provide us with certain personally identifiable information that can be used to contact or identify you. This may include, but is not limited to:

• Email address
• First and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Usage data

(b) Usage Data:

Usage data is automatically collected when using our services. This data may include information such as your device’s internet protocol (IP) address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. When you access our services through a mobile device, we may collect additional information automatically, such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data. We may also collect information that your browser sends whenever you visit our service or access it through a mobile device.

(c) Information from Third-Party Social Media Services:

We offer the option to create an account and log in to our services through third-party social media services such as Google, Facebook, and Twitter. If you choose to register through or grant us access to a third-party social media service, we may collect personal data that is already associated with your third-party social media account, such as your name, email address, activities, or contact list associated with that account. You may also have the option of sharing additional information with us through your third-party social media service account. By providing such information and personal data during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this privacy policy.

(d) Tracking Technologies and Cookies:

We use cookies and similar tracking technologies such as beacons, tags, and scripts to collect and store certain information about your use of our service. The technologies we use may include:

• Cookies or browser cookies: A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our service. Unless you have adjusted your browser settings to refuse cookies, our service may use cookies.
• Flash cookies: Certain features of our service may use local stored objects (or flash cookies) to collect and store information about your preferences or your activity on our service. Flash cookies are not managed by the same browser settings as those used for browser cookies. For more information on how you can delete flash cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects.
• Web beacons: Certain sections of our service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies may be persistent or session cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. For more information on cookies, please visit “What Are Cookies?”.

In the course of customer or user interactions with the Services, cookies and similar technologies may be deployed by our online data partners or vendors to correlate such activities with other personal information they, or third parties, may possess about you, including but not limited to your email address or online profiles. We, or third-party service providers acting on our behalf, may subsequently use this information to send communications or marketing materials to the associated emails or profiles. You retain the right to opt out of such communications at any time, either by following the instructions provided in the correspondence or by contacting help@brandwell.ai.

We utilize both Session and Persistent Cookies for the following purposes:

i. Necessary / Essential Cookies:

• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are crucial for providing you with the available services on the Website and enabling you to utilize its features. They assist in authenticating users and preventing fraudulent use of user accounts. Without these Cookies, the requested services cannot be provided, and we solely use these Cookies to deliver those services.

ii. Cookies Policy / Notice Acceptance Cookies:

Type: Persistent Cookies:

• Administered by: Us
• Purpose: These Cookies determine whether users have accepted the use of cookies on the Website.

iii. Functionality Cookies:

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow us to remember the choices you make while using the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personalized experience and avoid the need for you to re-enter your preferences each time you use the Website.

iv. Tracking and Performance Cookies:

· Type: Persistent Cookies

· Administered by: Third Parties

· Purpose: These Cookies are employed to track information about website traffic and how users interact with the Website. The collected information may indirectly or directly identify you as an individual visitor since it is typically associated with a pseudonymous identifier linked to the device you use to access the Website. We may also use these Cookies to test new pages, features, or functionality of the Website in order to gauge user response.

v. Targeting and Advertising Cookies:

• Type: Persistent Cookies
• Administered by: Third Parties
• Purpose: These Cookies track your browsing habits to enable us to display advertising that is more likely to be of interest to you. They utilize information about your browsing history to group you with other users who share similar interests. With our permission, third-party advertisers can place Cookies to present advertisements that we believe will be relevant to your interests while you are visiting third-party websites.

For more detailed information about the cookies we use and your options regarding cookies, please refer to our Cookies Policy or the Cookies section of our Privacy Policy.

(e) Use of Your Personal Data

At BrandWell.ai, we may utilize your Personal Data for the following purposes:

i. Provision and Maintenance of Our Service: This includes monitoring the usage of our Service to ensure its proper functioning.

ii. Account Management: Managing your registration as a user of our Service. The Personal Data you provide enables you to access various functionalities of the Service available to registered users.

iii. Contract Performance: Facilitating the development, compliance, and execution of purchase contracts for products, items, or services you have acquired, as well as any other contracts with us through the Service.

iv. Communication with You: Contacting you via email, telephone calls, SMS, or other electronic communication methods, such as push notifications from mobile applications. This includes updates and informative communications regarding the functionalities, products, or contracted services, including necessary or reasonable security updates.

v. News and Marketing: Providing you with news, special offers, and general information about goods, services, and events similar to those you have previously purchased or inquired about, unless you have chosen not to receive such information.

vi. Request Management: Addressing and managing your inquiries and requests.

vii. Targeted Advertising: Developing and displaying content and advertising tailored to your interests and/or location. We may collaborate with third-party vendors for this purpose and evaluate the effectiveness of such advertising.

viii. Business Transfers: Evaluating or carrying out mergers, divestitures, restructurings, reorganizations, dissolutions, or other sales or transfers of some or all of our assets. This may occur as part of a going concern or in situations such as bankruptcy, liquidation, or similar proceedings, where Personal Data held by us about our Service users is transferred as an asset.

ix. Other Purposes: Utilizing your information for data analysis, identifying usage trends, assessing the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and overall user experience.

Please note that your Personal Data will be used in compliance with applicable laws and regulations, ensuring the protection of your privacy and rights.

We may disclose your personal information in the following circumstances:

i. Service Providers: We may share your personal information with service providers to facilitate the monitoring and analysis of our Service usage, display advertisements to support and maintain our Service, advertise on third-party websites to you after you have visited our Service, process payments, and contact you.

ii. Business Transfers: In connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, we may share or transfer your personal information.

iii. Affiliates: We may share your information with our affiliates, including our parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. We will require our affiliates to comply with this Privacy Policy.

iv. Business Partners: We may share your information with our business partners to offer you specific products, services, or promotions.

v. Other Users: When you share personal information or interact in public areas with other users, such information may be viewed and publicly distributed by all users. If you interact with other users or register through a Third-Party Social Media Service, your contacts on that platform may see your name, profile, pictures, and activity descriptions. Likewise, other users will be able to view and communicate with you, as well as access your profile and activity descriptions.

vi. With Your Consent: We may disclose your personal information for any other purpose with your explicit consent.

Please note that we will take appropriate measures to ensure that your personal information is protected and handled in accordance with applicable privacy laws and regulations.

(f) Retention of Your Personal Data

At brandwell.ai, we will only retain your personal data for as long as necessary to fulfill the purposes stated in this Privacy Policy. We will keep and use your personal data to the extent required to comply with our legal obligations, resolve disputes, and enforce our agreements and policies.

We may also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, unless it is necessary to enhance the security or improve the functionality of our service, or if we are legally obligated to retain such data for longer periods.

(g) Transfer of Your Personal Data

Your information, including personal data, is processed at our operating offices and other locations where the parties involved in the processing are located. This means that your information may be transferred to and stored on computers located outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.

By providing your information and consenting to this Privacy Policy, you agree to the transfer of your personal data. At brandwell.ai, we will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We will not transfer your personal data to any organization or country unless adequate controls are in place, including the security of your data and other personal information.

(h) Disclosure of Your Personal Data

At brandwell.ai, we prioritize the protection of your personal data. However, there are certain circumstances where we may need to disclose your personal data as follows:

i. Business Transactions:

If the Company is involved in a merger, acquisition, or sale of assets, your personal data may be transferred. We will notify you before your personal data is transferred and becomes subject to a different privacy policy.

ii. Law Enforcement:

In certain situations, the Company may be required to disclose your personal data if mandated by law or in response to valid requests by public authorities, such as a court or government agency.

iii. Other Legal Requirements:

The Company may disclose your personal data in good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate potential wrongdoing in connection with our service
• Ensure the personal safety of users of the service or the general public
• Safeguard against legal liability

(i) Security of Your Personal Data

We are committed to safeguarding the security of your personal data. While we strive to utilize commercially acceptable measures to protect your personal data, it is important to note that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security for your personal data.

3. Information on the Processing of Your Personal Data

When you use our services, certain personal data may be collected. We may engage third-party service providers who will have access to your personal data. These providers collect, store, use, process, and transfer information about your activity on our service in accordance with their privacy policies.

(a) Analytics

We may utilize third-party service providers to monitor and analyze the usage of our service for analytical purposes. These providers collect data and provide insights to improve our service. The following analytics providers are currently in use:

i. Google Analytics

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google may use the collected data to personalize ads on its advertising network. You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on. For more information, please refer to Google’s Privacy & Terms web page: https://policies.google.com/privacy.

(b) Advertising

To support and maintain our service, we may engage service providers to display advertisements to you. These providers use various technologies to deliver relevant ads. The following advertising providers are currently utilized:

i. Google AdSense & DoubleClick Cookie

• Google utilizes cookies to serve ads on our service and other websites based on users’ visits. To opt-out of interest-based advertising, visit the Google Ads Settings page: http://www.google.com/ads/preferences/.

ii. Facebook

• For information on Facebook’s privacy practices, please refer to their Privacy Policy: https://www.facebook.com/policy.php.

iii. Linkedin

• For information on Linkedin’s privacy practices, please refer to their Privacy Policy: https://www.linkedin.com/legal/ads-policy.

(c) Email Marketing

We may use your personal data to send you newsletters, marketing materials, and other relevant information. You can opt-out of receiving these communications by using the unsubscribe link or following the instructions provided in our emails. We may engage email marketing service providers to manage and send emails to you.

i. ConvertKit

• ConvertKit’s Privacy Policy can be viewed at https://convertkit.com/privacy.

(d) Payments

If you make payments for our products or services, we may utilize third-party payment processors to securely process your payment information. We do not store or collect your payment card details. The handling of your personal information by these payment processors is governed by their respective privacy policies.

i. Stripe

• Stripe’s Privacy Policy can be viewed at https://stripe.com/us/privacy.

(e) Behavioral Remarketing

We engage remarketing services to advertise to you after you have accessed or visited our service. These services utilize cookies and non-cookie technologies to understand your preferences and display ads that may interest you. The purposes of behavioral remarketing include measuring and analyzing traffic, showing ads on third-party websites or apps, and evaluating advertising campaign performance.

You have the option to decline the collection and use of information for interest-based advertising through various third-party tools, such as the NAI’s opt-out platform (http://www.networkadvertising.org/choices/), the EDAA’s opt-out platform (http://www.youronlinechoices.com/), and the DAA’s opt-out platform (http://optout.aboutads.info/?c=2&lang=EN). Additionally, you can enable privacy features on your mobile device to opt-out of personalized advertising.

The following third-party vendors are used for behavioral remarketing:

i. Google Ads (AdWords)

• Google Ads (AdWords) remarketing service provided by Google Inc. You can customize Google Display Network ads and opt-out of Google Analytics for Display Advertising through the Google Ads Settings page: http://www.google.com/settings/ads.

ii. Twitter

• Twitter remarketing service provided by Twitter Inc. To opt-out of Twitter’s interest-based ads, follow their instructions: https://support.twitter.com/articles/20170405. For more information on Twitter’s privacy practices, please refer to their Privacy Policy: https://twitter.com/privacy.

iii. Facebook

• Facebook remarketing service provided by Facebook Inc. You can learn more about interest-based advertising and opt-out options through Facebook’s Privacy Policy: https://www.facebook.com/help/164968693837950. Facebook adheres to self-regulatory principles for online behavioral advertising established by the Digital Advertising Alliance.

For more information on the privacy practices of Facebook, please visit their Data Policy: https://www.facebook.com/privacy/explanation.

4. Legal Basis for Processing Personal Data under GDPR

4.1 Contact Us

If you have any questions or concerns regarding this Privacy Policy or our data practices, please contact us at help@brandwell.ai. We are committed to addressing and resolving any privacy-related issues.

The Company may process personal data under the following conditions:

• Consent: Processing personal data is based on your explicit consent for one or more specific purposes.
• Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations.
• Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing personal data is necessary to protect your vital interests or the vital interests of another natural person.
• Public interests: Processing personal data is related to a task carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by the Company.

The Company is committed to clarifying the specific legal basis that applies to the processing, whether it is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4.2 Your Rights under the GDPR

The Company respects the confidentiality of your personal data and ensures that you can exercise your rights. If you are within the EU, you have the following rights under this Privacy Policy and by law:

Right to access: You can request access to your personal data and receive a copy of the information the Company holds about you. Whenever possible, you can access, update, or delete your personal data directly within your account settings. If you require assistance, please contact us.

• Right to correction: You have the right to request the correction of any incomplete or inaccurate personal data the Company holds about you.
• Right to object: You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to erasure: You have the right to ask the Company to delete or remove your personal data when there is no valid reason for its continued processing.
• Right to data portability: The Company will provide your personal data in a structured, commonly used, and machine-readable format upon your request. This right applies to automated information you provided consent for or information used to perform a contract with you.
• Right to withdraw consent: You have the right to withdraw your consent for the use of your personal data. However, please note that withdrawing consent may limit your access to certain specific functionalities of the service.

4.3 Exercising Your GDPR Data Protection Rights

To exercise your rights of access, rectification, erasure, objection, data portability, or withdrawal of consent, please contact us. We may request verification of your identity before responding to such requests. We will make our best effort to respond to you promptly upon receiving your request.

If you are in the European Economic Area (EEA), you have the right to lodge a complaint with your local data protection authority regarding the collection and use of your personal data.

For more information, please contact your local data protection authority in the EEA.

5. Privacy Under the CCPA

This Privacy Policy (“Policy”) explains how BrandWell (“we,” “us,” or “our”) collects, uses, and discloses personal information of users who visit or reside in the State of California. This Policy supplements our main Privacy Policy and applies specifically to California residents.

5.1 Categories of Personal Information Collected

We collect various categories of personal information that can be associated with or linked to an individual (“Consumer” or “Device”). The following list includes categories of personal information that we may have collected from California residents in the past twelve (12) months. Please note that the examples provided within each category are defined by the California Consumer Privacy Act (CCPA), and while we make our best effort to collect such information, it does not imply that all examples within a category have been collected. Some categories of personal information may only be collected if directly provided by you.

i. Category A: Identifiers.

Examples: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

ii. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

iii. Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

iv. Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

v. Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

vi. Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisements.

Collected: Yes.

vii. Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

viii. Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

ix. Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

x. Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

xi. Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Please note that personal information under CCPA excludes publicly available information from government records, deidentified or aggregated consumer information, and information covered by specific privacy laws such as HIPAA, CMIA, FRCA, GLBA, FIPA, and the Driver’s Privacy Protection Act of 1994.

5.2 Sources of Personal Information

We obtain the categories of personal information listed above from the following sources:

• Directly from you: For example, from forms you complete on our Service, preferences you express or provide through our Service, or from your purchases on our Service.
• Indirectly from you: For example, from observing your activity on our Service.
• Automatically from you: For example, through cookies we or our Service Providers set on your Device as you navigate through our Service.
• From Service Providers: For example, third-party vendors that monitor and analyze the use of our Service, provide advertising on our Service, deliver targeted advertising to you, process payments, or provide other services related to our Service.

5.3 Use of Personal Information for Business or Commercial Purposes

We may use or disclose the personal information we collect for “business purposes” or “commercial purposes” as defined by the CCPA. These purposes may include:

• Operating our Service and providing you with our Service.
• Providing support and responding to your inquiries.
• Fulfilling or meeting the reason you provided the information.
• Responding to law enforcement requests and complying with applicable laws and regulations.
• Internal administrative and auditing purposes.
• Detecting and protecting against security incidents and illegal activities.

Please note that the examples provided above are illustrative and not exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section in our Privacy Policy.

5.4 Disclosure of Personal Information for Business or Commercial Purposes

We may disclose the following categories of personal information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that while we disclose personal information for business purposes, it does not imply that all examples within a category have been disclosed. We enter into contracts with recipients to ensure the confidentiality and limited use of the personal information shared.

5.5 Sale of Personal Information

As defined by the CCPA, “sell” means sharing personal information for valuable consideration. While we may have received benefits for sharing personal information, they may not necessarily be monetary. We may have sold the following categories of personal information in the past twelve (12) months:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined by the CCPA, and not all examples within a category have been sold. Our good faith belief is that some information within these categories may have been shared for valuable consideration.

For more information on how we handle personal information, including your rights and choices, please refer to our main Privacy Policy.

This Privacy Policy may be updated in the future if we collect additional categories of personal information or use collected information for materially different purposes.

6. Share of Personal Information

At brandwell.ai, we may need to share your personal information, as described in the following categories, with the following parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Third-party vendors authorized by you or your agents to receive your personal information in connection with the products or services we provide to you.

(a) Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of consumers we actually know are under 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us. If you believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

(b) Your Rights under the CCPA

If you are a resident of California, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information. These rights include:

• The right to notice: You have the right to be notified about the categories of personal data that are being collected and the purposes for which the personal data is being used.
• The right to request: Under the CCPA, you have the right to request information about our collection, use, sale, disclosure for business purposes, and sharing of personal information. 

Once we receive and confirm your request, we will disclose to you:

• The categories of personal information we collected about you
• The categories of sources for the personal information we collected about you
• Our business or commercial purpose for collecting or selling that personal information
• The categories of third parties with whom we share that personal information
• The specific pieces of personal information we collected about you

If we sold your personal information or disclosed it for a business purpose, we will disclose to you:

• The categories of personal information categories sold
• The categories of personal information categories disclosed
• The right to opt-out of the sale of personal data: You have the right to direct us to not sell your personal information. To submit an opt-out request, please contact us.
• The right to delete personal data: You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your consumer rights.

(c) Exercising Your CCPA Data Protection Rights

To exercise any of your rights under the CCPA, as a California resident, you can contact us:

• By email: help@brandwell.ai

Only you or a person registered with the California Secretary of State and authorized by you to act on your behalf may make a verifiable request related to your personal information.

Your request to us must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the required information if we cannot:

• Verify your identity or authority to make the request.
• Confirm that the personal information relates to you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable request. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

(d) Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.

i. Website

You can opt-out of receiving personalized ads served by our service providers by following the instructions presented on our website:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt-out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.

ii. Mobile Devices

Your mobile device may provide you with the ability to opt-out of the use of information about the apps you use to serve you ads targeted to your interests. For instructions, please refer to the settings on your mobile device.

(e) “Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our service does not respond to Do Not Track signals. However, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.

(f) Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal data with

Third parties for the third parties’ direct marketing purposes.

If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

(g) California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request the removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account.

Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

7. Miscellaneous

(a) Links to Other Websites

The BrandWell platform may contain links to other websites that are not operated by us. If you click on a link that directs you to a third-party site, we encourage you to carefully review their Privacy Policy. We do not have control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

(b) Changes to this Privacy Policy

We may periodically update our Privacy Policy. When we make changes, we will notify you by posting the updated Privacy Policy on this page. We will also send you an email and/or provide a prominent notice on our platform prior to the changes taking effect. The “Last updated” date at the top of this Privacy Policy will reflect the most recent revisions. We recommend that you review this Privacy Policy periodically to stay informed about any modifications. Changes to this Privacy Policy become effective when they are posted on this page.

(c) Contact Information

If you have any questions or concerns about this Privacy Policy, you can reach out to us by email at help@brandwell.ai.