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BRAWTA LIVING PRIVACY POLICY

Effective Date: March 1st, 2022

This Privacy Notice (“Privacy Notice”) explains how WVM Brawta Living Limited, Brawta Living Inc., its affiliates, and its subsidiaries (“Brawta,” “us,” “our,” and “we”) use your information and applies to all who use our website and platform – including mobile applications, touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control (collectively, the “Terms and Conditions”). For terms that govern the use of our website and platform, please review our “Terms and Conditions”

By using our website and platform, you acknowledge you have read the terms of this Privacy Notice. If you do not want your information handled as described in this Privacy Notice, please do not provide us with your information or interact with our website and platform.

We may modify this Privacy Notice at any time. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of notice on our website and platform prior to the change becoming effective. You can determine when this Privacy Notice was last revised by referring to the “Effective Date” above.

1.Types of Information We Collect

We may collect the following categories of personal information from and about you:

  • Identifiers: such as your name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
  • Demographic information: such as your age, birthdate, and gender.
  • Commercial information: such as information that enables us to determine lifestyle, interests, and activities, including purchasing tendencies and order history (such as the Brawta vouchers you purchase and redeem); areas of interest; information collected through your interactions with social networks; information about persons for whom you have purchased Brawta vouchers as gifts or who have bought Brawta vouchers as gifts for you; and information about friends who refer you or whom you have referred.
  • Location information: such as information related to your parish, city, state or neighborhood, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access our website and platform.
  • Financial information: such as information collected from you as needed to process payments for Brawta vouchers or other products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and card verification number.
  • Internet and network activity information: such as information about your browsing behavior, search history, and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons.
  • Inferences regarding preferences and other characteristics: such as our assessment of the types of products or services you may have an interest in.

2. How Brawta Collects Information

We may collect personal information about you from a variety of sources, including:

  • From you: We collect information that you submit to us. For example, when you use our website and platform; make a purchase; register to receive information, products, or services available on our website and platform; or interact with us in other ways. We will collect any information you voluntarily provide, and we may also request optional information to support your use of our website and platform. We also collect any information that you voluntarily enter into any postings, comments, or forums within our website and platform. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.
  • From your device: When you use our website and platform, we may collect information about the devices you use to access our website and platform, including hardware model, operating system and version, Internet Protocol (“IP”) address, and other unique device identifiers, mobile network information, and information about the device’s interaction with our website and platform. We also collect information about how you use our website and platform, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of our website and platform so we can analyze and improve it. To collect this information, we use cookies and web beacons, and other similar technologies. Note that this Privacy Notice covers only how we use information collected via cookies; it does not cover the use of such information by third parties.
  • Location information: We may collect different types of information about your location, including general information, such as the city, town, parish, state, and/or country code / zip code associated with your IP Address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access our website and platform. We may use such location information to customize our website and platform, including advertising that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, vendors or advertisers. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the Brawta application in iOS privacy settings.
  • Social media networks and other third parties: We may obtain information about you or your use of our website and platform from third party sources, such as our vendors, like web hosting providers, analytics providers, or advertisers. You may give us permission to access your information from services offered by third parties, including social media networks. The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences. When you access our website and platform through social media networks and other third party platforms, you are authorizing Brawta to collect, store, and use such information and content in accordance with this Privacy Notice. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

3. How Brawta Uses Information

We may use information collected as described in this Privacy Notice to:

  • Operate, maintain, and improve the Service and other programs, features, and functionality related to our website and platform;
  • Provide you with interest-based ads, push notifications, communications, and offers for products and services from us and our business partners, including based on your precise geolocation;
  • Facilitate and fulfill orders – for example, for Brawta vouchers and other goods and services, including tracking redemption;
  • Process and confirm bookings with our partners;
  • Process your payments;
  • Evaluate your eligibility for certain types of offers, products, or services that may be of interest to you, and analyze advertising effectiveness;
  • Answer your questions and respond to your requests;
  • Perform analytics and conduct customer research;
  • Communicate and provide additional information that may be of interest to you about Brawta and our business partners, sometimes by combining your information with information we obtain from other sources;
  • Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners;
  • Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners;
  • Manage our everyday business needs, such as administration of our website and platform, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms and Conditions or to comply with the law;
  • Allow you to apply for a job, post a video, or sign up for special offers from merchants, our business partners, or other companies;
  • Verify your requests made pursuant to this Privacy Notice;
  • Enhance other information we have about you to help us better understand you and determine your interests; and

We also may use information collected as described in this Privacy Notice with your consent or as otherwise required or permitted by law.

Brawta uses your geolocation, including your precise geolocation, consistent with this Privacy Notice as described in section 2 above to deliver location-based offers, products or services that may be of interest to you.

If you use any features on our website and platform to send information about a product or service to another person, we will also collect the personal information of that other person to the extent disclosed by you and may contact them using the information you provided us.

4. When and Why Brawta Discloses Information

We may share your personal information as follows:

  • as required to comply with the law or legal obligations, such as to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
  • in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Jamaica or the United States;
  • with our vendors who perform a variety of services and functions for us, such as data storage, order fulfillment, transmitting emails, and managing digital content. We may share your information with such vendors subject to confidentiality obligations consistent with this Privacy Notice and on the condition that the service providers use your information only on our behalf and pursuant to our instructions;
  • with our merchants to provide you with the Services you request (such as to facilitate and fulfill orders and to process and confirm bookings);
  • in the event we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets.
  • to combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting Brawta;
  • with our affiliates and subsidiaries who may only use the personal information for the purposes described in this Privacy Notice;
  • if the information has been aggregated, de-identified, or otherwise does not identify you personally; and
  • otherwise with your consent.

We may disclose your personal information to the following categories of third parties:

Brawta Entities

  •  Merchants
  • Co-marketers
  • Distributors
  • Resellers
  • Advertising Networks
  • Payment Services Providers
  • Internet Service Providers
  • Data Analytics Providers
  • Operating Systems and Platforms
  • Social Networks
  • Government or Law Enforcement Entities
  • Fraud Protection and Prevention Providers
  • Delivery Services Providers
  • Service Providers

We may disclose the following categories of personal information for our own business and operational purposes:

  • Identifiers;
  • Demographics;
  • Commercial information;
  • Location information;
  • Financial information;
  • Internet and network activity information; and
  • Inferences regarding preferences or characteristics.

We may disclose certain personal information in exchange for services, insights, or other valuable consideration. These disclosures may involve:

  • Identifiers;
  • Demographics;
  • Commercial information;
  • Location information;
  • Financial information;
  • Internet and network activity information; and
  • Inferences regarding preferences or characteristics.

5. Security of Personal Information

Brawta has implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, we cannot guarantee its absolute security.

6. Your Rights Regarding Personal Information

You have certain rights with regard to your personal information:

  • You have the right to know and request information about the categories and specific pieces of personal information we have collected about you within the last 12 months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information for business purposes.
  • You have the right to update your personal information
  • You have the right to request a portable copy of your personal information
  • You have the right to request that Brawta delete your personal information, subject to certain exceptions allowed under applicable law.
  • You have the right to opt-out of certain disclosures of your personal information for valuable consideration.
  • You have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

In addition to the above rights, you can deactivate your Brawta account.

7. Your Choices

We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to Brawta, and you can limit the communications that Groupon sends to you. In particular:

  • Commercial Emails: You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial emails related to your account and your transactions. You may update your subscription preferences at any time.
  • Cookies and Other Technologies: You may manage how your browser handles cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain ad-service companies.
  • Device Data: You may manage how your mobile device and mobile browser share certain device data with Brawta, as well as how your mobile browser handles cookies by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

When you first visit or use our website and platform we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, or permit it only when using the mobile app, but it may limit certain functions or features. You can control how and whether we collect your precise geolocation information through your device’s settings.

  • Emails from Business Partners: If you wish to opt-out of receiving offers directly from our business partners, you can follow the opt-out instructions in the emails they send you.

8. Social Community Areas

Our website and platform may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms andConditions carefully. All the information you post may be accessible to anyone with Internet access, and any personal information you include in your posting may be read, collected, and used by others. We recommend that you do not post any personal information in the social community areas.

9. Privacy Practices of Third Parties

This Privacy Notice only addresses the use and disclosure of information by Brawta through your interaction with our website and platform. Other websites that may be accessible through links from our website and platform may have their own privacy notices and personal information collection, use, and disclosure practices. Our business partners may also have their own privacy notices. We encourage you to familiarize yourself with the privacy notices provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

10. Business Transfers and Corporate Changes

Brawta reserves the right to disclose, transfer, or license any and all information related to our website and platform, including personal information:

  • to a subsequent owner, co-owner, or operator of our website and platform or any portion or operation related to part of our website and platform; or
  • in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

11. Notice to Residents of Countries outside of Jamaica and the United States of America

This Service is intended only for users in Jamaica and the United States. If you live outside of Jamaica and the United States, your information will be handled in accordance with this Private Policy for Jamaica and the United States. By using our website and platform or giving us your personal information, you are directly transferring your personal information to us in Jamaica and the United States. You agree and consent to our collection, transfer, and processing of your personal information in accordance with this Privacy Notice. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use the Service or provide us with personal information. Regardless of where we transfer your information, we still protect your information in the manner described in this Privacy Notice.

12. Children’s Privacy

Our website and Platform is a general audience site but not directed at children under the age of 16 and Brawta has no actual knowledge of the sale of information of minors under 16 years of age.

By using Brawta’s website and platform, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised on our website and platform.

13. Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice. You can reach us online at info@brawtaliving.com

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