What this policy covers
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
What information we collect about you
How we use information we collect
How we share information we collect
How we store and secure information we collect
How to access and control your information
Other important privacy information
When we refer to “Bravo,” “we,” or “us” in this policy, we mean O2 Financial JSC, which controls the information Bravo collects when you use the Services. Bravo offers collaborative tools, including our site admin and mobile products, which help you improve organization’s employee engagement. We refer to all of these products, together with our other services and websites as “Services” in this policy.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services.
INFORMATION YOU PROVIDE TO US
We collect information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when your organization/employer register your account on our services, when you create or modify your profile, set preferences, claim and redeem reward through the Services. For example, you provide your contact information and you also have the option of adding a profile photo and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.
Content you provide through our products: The Services include the Bravo site admin and mobile products you use, where we collect and store content that you send, receive and share. This content includes any information about you that you may choose to include. Content also includes the files and links you upload to the Services. Examples of content we collect and store include: files you attach to an activity, descriptions of reward, announcement, message you send or receive, profile photo uploads.
Content you provide through our websites: The Services also include our site admins owned or operated by us. We collect other content that you submit to these websites. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES
We collect information about you when you use our Services and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the rewards you claim and redeem, the activities you join in; the type, size and filenames of attachments you upload to the Services; frequently used search terms; and how you interact with others on the Services. We also collect information about the teams and people you work with and how you interact with them, like who you collaborate with and communicate with most frequently.
Device and Connection Information: We collect information about your phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, device identifiers and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by someone else on a message, or a team member may upload or share content about you in an activity.
How we use the information we collect
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, we use the name and picture you provide in your account to identify you to other Service users.
For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. For example, we used information collected about how users “submit a proof” from within the product to design a better, more user-friendly “Activities”. In some cases, we apply these learnings across Bravo to improve and develop similar features or to better integrate the services you use.
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services. Where you give us permission to do so, we share your information with a Bravo expert for the purpose of responding to support-related requests.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
How we share information we collect
We make collaboration tools, and we want them to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
SHARING WITH OTHER SERVICE USERS
When you use the Services, we share certain information about you with other Service users.
For collaboration: You can create content, which may contain information about you, and grant permission to others to see, share, copy and download that content. Some of the collaboration features of the Services display some or all of your profile information to other Service users when you share or interact with specific content. For example, when you receive points from your manager, we display your profile picture and name on Award Feed so that other users with access to Bravo understand who received points. Similarly, when you join a team, your name, profile picture and contact information and will be displayed in a list for other team members so they can find and interact with you.
Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization, or associate that email address with your existing account and such organization wishes to establish a Bravo certain information about you including your name, profile picture, contact info, content, and account use may become accessible to that organization’s administrator and Bravo service users, as permitted by your administrator, to provide you additional products and services. For example, your organization may request that we provide extra security controls around your account to protect information about your organization. If you are the administrator or manager of a team within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
SHARING WITH THIRD PARTIES
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws: Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Bravo, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure the information we collect
INFORMATION STORAGE AND SECURITY
We use data hosting service providers in Viet Nam to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable time frame.
HOW LONG WE KEEP INFORMATION
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your information as long as required by the administrator of your account. We also retain some of your information after your account was disable to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate formation that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display message or content you sent to other or administrator.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable time frame.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Please contact your administrator to assist with your requests.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep.
Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you using key word searches in the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate or delete subscription to a team or enterprise: Only your administrator can deactivate your access to a team or enterprise. Please contact your administrator. If you are an administrator and are unable to deactivate an account through your administrator settings, please contact Bravo support. Please be aware that deactivating access to a team or enterprise does not delete your information from that team or enterprise; your information remains visible to other Service users based on your past participation within the Services.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings. Please note, you will continue to receive generic ads.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information.
Other important privacy information
Notice to End Users
Our products are intended for both personal use and use by organizations. Because the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the end-users and/or Service sites over which it has control. Please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Even if the Services are not currently administered to you by an organization, if you are a member of a team administered by an organization, or if you use an email address provided by an organization (such as your work email address) to access the Services, then the administrator of that team or the owner of the domain associated with your organizational email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens.
Team and enterprise administrators or managers are able to restrict your access to and privileges within the Services. In some cases, enterprise administrators can also:
Require you to reset your account password;
Restrict, suspend or terminate your access to the Services or your account;
Control your ability to edit, restrict, modify or delete account information;
Change your account information, including profile information or the email address associated with your account;
Access information in and about your account;
Access or retain information stored as part of your account; and
Please contact your organization or refer to your administrator’s organizational policies for more information.