Bravura Software takes the security and privacy of its EU citizen members very seriously. Bravura Software is intent on complying with the European
Union's General Data Protection Regulation (GDPR) and has created the following policy and disclosures in accordance with GDPR.
GDPR Data Processing Policy
Bravura Software LLC ("Bravura Software") recognizes that the European Economic Area (the "EEA") has established strict protections regarding
the handling of EEA personally identifiable information, the EU General Data Protection Regulation ("GDPR"). In recognition of the importance
of GDPR, Bravura Software has adopted the following GDPR Data Processing Policy (the "Policy").
This Policy is intended to ensure that you understand the following: (a) the entity that is collecting your personal data; (b) the purposes
for which your personal data is collected; (c) how and why your personal data will be used; (d) the period during which your data will be
retained; and (e) how you can contact Bravura Software regarding your data.
This Policy supplements the Bravura Software Privacy Policy located here and
unless specifically defined in this Policy, defined terms in this Policy have the same meaning as they do in the Privacy Policy.
Entity/Data Controller
Any data collected through www.bravurasoftware.com or any other website associated with (collectively the "Bravura Software Websites"), or related to,
the Bravura Software Websites will be collected by Bravura Software LLC which is a limited liability company formed in Redmond, WA USA with its
principal place of business located at 12356 Northup Way, Suite 100, Bellevue WA 98005, USA.
Lead Data Protection Authority
The Bravura Software Websites' lead data protection authority is:
Bravura Software LLC
12356 Northup Way
Suite 100
Bellevue WA 98005 / USA
Telephone number: (425) 577-6215
Email: dataprivacy@bravurasoftware.com
You may lodge any complaints about Bravura Software's data processing with this Lead Data Protection Authority.
Data Processing Officer
You can contact the Bravura Software Data Processing Officer by emailing dataprivacy@bravurasoftware.com
Categories of Data Subjects and Data Collected
Bravura Software only collects data from users who either join, or engage with, the Bravura Software Websites and products. Bravura Software is
committed to only collecting data that is necessary for Bravura Software to provide the content and services of the Bravura Software products.
The Bravura Software Privacy Policy describes the categories of personally identifiable information that Bravura Software may receive including:
(a) name, (b) postal address, (c) e-mail address, (d) telephone number, or any other information the Bravura Software Websites collect that
is defined as personal or personally identifiable information under an applicable law or any other identifier by which you may be contacted
online or offline.
Depending on which services you choose to use, Bravura Software may require additional information, such as a company name, billing information
(including billing address, phone number, credit card information), a mobile telephone number, a physical mailing address, and/or payment information.
Bravura Software may require information such as your social security number, or the equivalent, applicable tax ID, date of birth, bank account
information and/or credit card information to verify your identity and provide this service to you.
You may also provide information to Bravura Software such as the following: (a) information that you provide by filling in forms; (b) information
provided at the time of registering to use Bravura Software Websites; (c) information when you enter a promotion sponsored by Bravura Software;
(d) information when you report a problem with Bravura Software Websites; (e) records and copies of your correspondence (including email addresses),
if you contact Bravura Software; (f) your responses to surveys that we might ask you to complete for research purposes; (g) details of transactions
you carry out through the Bravura Software Websites and of the fulfillment of your orders; (h) financial information before placing an order through
the Bravura Software Websites; and (i) your search queries on the Bravura Software Websites.
Basis for Processing
Bravura Software processes data based on (a) consent of the user; and (b) the necessity of the data for providing the services that users are
contracting for when they become members of the Bravura Software Websites. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR DATA IN ORDER TO
ACCESS AND USE THE BRAVURA SOFTWARE WEBSITES, PLEASE DO NOT USE, OR ENGAGE WITH, THE BRAVURA SOFTWARE WEBSITES.
Cross-Border Transfer
Data centers hosting Bravura Software's data, including user data, are located within the United States and the European Union. Accordingly,
as an EU citizen, to access the services and content provided by Bravura Software, your data may be transferred outside of the EU. By using
the Bravura Software Websites, you consent to the cross-border transfer of your data to receive access to the Bravura Software Websites.
Potential Recipients
Bravura Software does not provide your data to third party recipients who are not necessary to the services and content provided on the
Bravura Software Websites without your permission. Third parties who may receive your data so that Bravura Software can provide the
services and content on the Bravura Software Websites include Bravura Software's cloud infrastructure provider and Bravura Software's
third party marketing cloud and service providers.
Use of Data
Please refer to the Bravura Software Privacy Policy located here for more information on how Bravura Software uses your personal data.
Data Retention Period
Bravura Software will retain your information for as long as your account is active or as needed to provide you services. If you no
longer want Bravura Software to use your information to provide you services, you may follow the "Withdrawal of Consent/Erasure" provision below.
After closing your account, Bravura Software will solely use your information as necessary to comply with any applicable legal obligations.
Security Policies for Data
Bravura Software's data security policy is detailed in the Privacy Policy located here. In summary,
Bravura Software has implemented measures designed to secure your personal information from accidental loss and from unauthorized access,
use, alteration, and disclosure. All information you provide to Bravura Software is stored on secure servers behind firewalls. Any payment
transactions and other sensitive information will be encrypted using secure socket layer (SSL) technology. Bravura Software follows generally
accepted industry standards to protect the personal information submitted, both during transmission and once Bravura Software receives it.
The safety and security of your information also depends on you. Where Bravura Software has given you (or where you have chosen) a password for
access to certain parts of the Bravura Software Websites, you are responsible for keeping this password confidential. Bravura Software asks you
not to share your password with anyone.
Withdrawal of Consent/Erasure
If, at any point, you no longer wish to have your personal data processed by Bravura Software, simply send an email to dataprivacy@bravurasoftware.com
with the phrase "consent withdrawn" or "erase" in the subject line. Your request should include your name, company name, email address and
physical address. Bravura Software will move expeditiously to stop the processing of your personal data and to remove your personal data from
its systems. Please understand that, without access to your personal data, Bravura Software may not be able to provide certain services.
For example, Bravura Software will not be able to send you communications, sales, offers, newsletters. Additionally, it may be impossible for
Bravura Software to fulfill purchases or sales without access to personal information.
Right to Correct, Access or Portability of Data and Associated Procedure
You have the right to have any inaccurate data corrected by a data controller. You also have the right to request access to your data or request
that Bravura Software make your data portable to another data controller. To affect any such request, you should send the request to
dataprivacy@bravurasoftware.com. Your request should include your name, company name, email address and physical address.
Bravura Software will endeavor to correct the data or to provide you your data in a simplistic and easily readable format as
quickly as possible, but in no more than thirty (30) days.