Privacy Policy

The following Privacy Policy (hereinafter “Privacy Policy”) explains how Reverb Inc. (hereinafter referred to as “Reverb”) collects and uses any information users (hereinafter referred to as “User”, “You”, “Your”) submit when using the Site, as defined within the Brahma Terms of Service (hereinafter “Terms”), available at the following link:
https://www.brahma.fi/terms-and-conditions.

This Privacy Policy should be read in conjunction with the User Terms, in which it is integrated. 


All capitalized proper nouns not defined in this Privacy Policy meet the same definitions and have the same meanings set out in the User Terms. 


Please, review the Privacy Policy periodically, as it may be subject to changes. 

In case You do not agree with or accept our Privacy Policy in its entirety, You must not access or use the Interface. If You use the Interface following a change to the terms of this Privacy Policy, You agree to accept the revised terms. 


Reverb is committed to handling Your personal data with integrity, ensuring that the processing of Your information is fair, lawful, and transparent. Our Privacy Policy outlines the specific terms and conditions governing how we protect Your data and utilize cookies.

1. Data Collected

Reverb may collect the following information from You when You access or use the Interface:

  • Digital Wallet address, transaction history and other associated information.

  • Interactions with the Interface, including but not limited to usage data and preferences.

  • Online identifiers, like computer and browser information, operating system, data usage, IP address, and data transferred.

  • Information provided by third parties or publicly accessible databases which Reverb may combine with other information collected.

2. Who is the person determining the purposes and means of the processing?

The legal person that determines the purposes and means of the processing of personal data is

Reverb Inc., with principal office in the Republic of Panama, email privacy@brahma.fi

3. Use of Your Data

Where applicable, Reverb will use any data collected as directed by You and in accordance with the User Terms. 

Furthermore, Reverb may use Your data in the following ways:

  • to provide any services offered by the Interface, to process transactions, to maintain, develop and operate the Interface;

  • to enforce the Privacy Policy or User Terms; 

  • to comply with applicable laws; 

  • to respond to third party, legal, governmental inquiries and to investigate any illegal or fraudulent activity;

  • to enhance or improve our users’ experiences;

  • to send You and receive information via selected communication methods as set forth within the User Terms or where requested by You;

  • to notify You of additional Reverb services and updates;

  • to assist in maintaining the functionality, safety, and security of the Interface;

  • to share Your information with third-party contractors hired by Reverb to perform functions and provide services to us such as infrastructure providers, Blockchain technology providers, marketing providers, and other vendors Reverb uses to make available the Interface;

  • to release to governmental entities, authorities, or legal claimants as required.

4. Analytics

Third party analytics tools collect or use information about Your use of the Interface, which helps Reverb to improve it. 

Reverb uses Google Analytics to store and count page views and to calculate visitor, session and campaign data and track site usage for the Site’s analytics report.

5. Governmental Entities

Reverb may combine any data collected with information made available in third-party databases and public sources. Reverb may use such information to address claims, to respond to governmental inquires or requests, or to investigate issues. Furthermore, such information may be shared with governmental entities including criminal, civil and regulatory agencies.

Please, be aware that Reverb may keep copies of Your information subject to our internal retention policies for the purposes of abiding by applicable laws or to prevent fraud or injury to a third-party.

6. Cookies

What is a Cookie

A cookie is a small string of text that a website (or online service) stores on a user’s browser. It saves data on Your browser about Your visit to our site or other sites. It often includes a unique identifier (e.g., cookie #123).

  • Necessary cookies 

Necessary cookies are required to enable the basic features of the Site, such as providing secure log-in or adjusting Your consent preferences. These cookies do not store any personally identifiable data.



  • Functional cookies 

Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.



  • Analytical cookies 

Analytical cookies are used to understand how users interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.



  • Performance cookies 

Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.



  • Advertisement cookies 

Advertisement cookies are used to provide visitors with customized advertisements based on the pages You visited previously and to analyze the effectiveness of the ad campaigns.

Cookies used by the Site

_ga_*

Domain: .brahma.fi

Description: Google Analytics sets this cookie to store and count page views.

Duration: 1 year 1 month 4 days

Type: Analytical

_ga

Domain: .brahma.fi

Description: Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.

Duration: 1 year 1 month 4 days.

Type: Analytical.

_hjSessionUser_*

Domain: .brahma.fi

Description: Hotjar sets this cookie to ensure data from subsequent visits to the same site is attributed to the same user ID, which persists in the Hotjar User ID, which is unique to that site.

Duration: 1 year.

Type: Analytical.

_hjSession_*

Domain: .brahma.fi

Description: Hotjar sets this cookie to ensure data from subsequent visits to the same site is attributed to the same user ID, which persists in the Hotjar User ID, which is unique to that site.

Duration: 1 hour.

Type: Analytical.

__cf_bm

Domain: .walletconnect.com

Description: This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.

Duration: 1 hour.

Type: Necessary.

__cf_bm

Domain: .walletlink.org

Description: This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.

Duration: 1 hour.

Type: Necessary.

Disabling Cookies Through Your Browser

Most browsers automatically accept cookies, but this is typically something You can adjust. For instance, information for can be found in the links below:


  • Safari on desktop and Safari Mobile (iPhone and iPads)

Link: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

Please, note that, by default, Safari is engineered to protect You from being tracked from site to site unless You disable Intelligent Tracking Prevention (ITP).


  • Firefox

Link: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US

By default, Firefox protects You from cross-site tracking so long as You have not disabled Enhanced Tracking Protection (ETP). There is therefore less need to manage cookies to protect Your privacy.


  • Chrome

Link: https://support.google.com/accounts/answer/32050 


  • Internet Explorer

Link: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc


If You refuse cookies, You might not be able to use other cookie-dependent features of the Interface. To manage specific cookie settings, review this Privacy Policy for further information.

7. Accessing and Editing Your Information

If You have any questions regarding any information collected, please contact us at privacy@brahma.fi.

8. Opt-Out of Commercial, Non-Commercial Communications and Do Not Track

If You decide to provide Reverb with Your contact information, You agree that Reverb may send You communications via emails or other methods. 

However, You may choose to unsubscribe from certain communications by notifying Reverb that You no longer wish to receive them. If so, Reverb will endeavor to honor such requests promptly. 

If You wish to opt out of certain communications or data collection, please contact us at privacy@brahma.fi.

9. Third-Party Websites and Links

When accessing a third-party site through our Interface, You acknowledge that You are aware that these third-party websites are not screened for privacy or security issues by Reverb, and You release us from any liability for the conduct of these third party’s websites. 

Please, be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, do not create rights enforceable by third parties. 

Reverb bears no responsibility for the information collected or used by any third-party website. 

Therefore, we encourage You to read the privacy policies of these websites because their practices may differ from ours.

10. Rights of the Data Subject

Right to withdraw consent 

You have the right to at any time withdraw Your consent for processing, upon which we will stop processing Your personal data based on this legal basis unless a different legal basis is applicable. The withdrawal does not affect the lawfulness of processing Your personal data based on legitimate interests before Your withdrawal.


Right of access 

You have the right to obtain access to the personal information collected about You, as well as its sources, purpose, and sharing.


Right to rectification

You have the right to obtain the rectification of inaccurate or incomplete personal data concerning You without undue delay.


Right to erasure 

You have the right to obtain the deletion of Your personal data without undue delay.

 

Right to data portability 

You have the right, under certain circumstances, to receive personal information about You in a structured format that can be transferred to another entity.


Right to restriction of processing 

You have the right to obtain the restriction of processing of Your personal information if: 

(1) the user disputes the accuracy of personal information about him or her; 

(2) the user claims that the processing is unlawful;

(3) the user claims that the controller no longer needs to retain the information for the establishment, exercise, or defense of a legal claim;

(4) the user objects to the processing pending verification as to whether the data controller's legitimate grounds prevail over those of the data subject.


Right to object 

You have the right to object at any time to the processing of Your personal data if it is processed on the basis of legitimate interests, if it is used for direct marketing purposes (including profiling), or if the processing is for scientific, historical, or statistical research purposes.


Automated individual decision-making 

You have the right not to be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning You or similarly significantly affects You.


In the event that You wish to exercise any of Your above rights, please contact us at privacy@brahma.fi.

11. Security Measures

Reverb makes reasonable attempts to protect Your data by using physical and electronic safeguards, such as encryption. However, as the Interface relies on Blockchain Technology and electronic infrastructure on which Reverb has no control, Reverb cannot guarantee the security or privacy of the information submitted. For this reason, Reverb recommends that You use anti-virus software, firewalls, and other precautions in order to protect Yourself from security and privacy threats.

12. Age Compliance

We do not collect or process any data concerning persons under the age of majority in Your jurisdiction (“Minors”). Please do not submit information to us if You are under the age of majority in Your applicable jurisdiction. In the event that we have inadvertently collected any data from a Minor, please contact us immediately.

13. International Transfer

Your information may be transferred to – and maintained on – computers located outside of Your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. Information that is submitted to Reverb will be collected, processed, stored, disclosed, and disposed of in accordance with applicable law and the present Policy. In addition, such information may be stored on servers located outside Your resident jurisdiction. Reverb is committed to manage the eventual transfer of Your personal data with integrity and according to the applicable legislation and practices that are most protective of Your rights.

14. Merger and Acquisition

In the event that Reverb is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, Your data may be transferred as part of that transaction. Please, be aware that once the data is transferred Your privacy rights may be subject to change.

15. Amendments and Policy Review

As provided under the User Terms, Reverb may amend this Privacy Policy from time to time. 

When Reverb amends this Privacy Policy, it may contact You. 

If Reverb makes any material changes to this Privacy Policy, it will notify You by posting the updated Privacy Policy on the Site and update the effective date at the end of the Privacy Policy. In order to continue to use our Interface, You must agree to the amendments. If You do not agree, You must immediately cease using our Interface.

Because this Privacy Policy may be subject to change, we encourage You to periodically review this Privacy Policy to stay informed about how we collect, use, and share Your personal information. Any changes will be effective immediately upon posting of the revised Privacy Policy, unless otherwise specified.

16. Contact

If You have any questions regarding our Privacy Policy, please contact us at privacy@brahma.fi.

Contact Information

If you have any questions about these Terms, please contact legal@brahma.fi