Last Modified: November 9, 2021
Brane Pte. Ltd., a limited liability company incorporated under the laws of the Republic of Singapore with registered number 201812942G, having its office located at: 68 Circular Road #02-01, Singapore (049422), e-mail [email protected]
, provides services as operator (“we”, “us”, or “Operator”), operates the Off.agency website (the “Site”) and provides an advertising video platform service (the "Service"), which is available through the Site.
Please read the policy in full, but here are a few key things:
When you use the Site, even if you're just browsing, we receive some information from you, such as the type of device you’re using and your IP address.
You can choose to share additional information with us, such as your email address, by creating an account, making purchases, or providing content to the Site.
If you have questions about this policy, how we collect or process your personal data, or anything else related to our privacy practices, we want to hear from you; contact us to [email protected]
2. INFORMATION COLLECTION
3. Where we collect information you provide
3.1 OPERATOR MAY COLLECT PERSONAL INFORMATION FROM YOU WHEN YOU:
3.1.1 Create an Account on, Login to, or Interact with the Site. Operator collects your name and email address and the other information that you provide, such as ID details, bank details and so on, when you register or login, update, or add information or content to your account. We require you to create a username and password if you create an account, although we may enable other methods such as logging in through one of your existing social media accounts (collectively, "Social Media Platforms"). Operator also collects certain information relating to any Social Media Platform account that you use to login to or link to your Site account (such as your username and so on), although linking any such account to your Site account or logging into the Site via such account is entirely up to you.
3.1.2 Make a Purchase through the Site. Operator collects the information that you provide when you request a Brane Video.
3.1.3 Contact Customer Service through the Site. Operator collects the information that you provide in connection with us providing you customer service.
3.1.4 Provide Content to the Site. We collect information when you submit content to us, such as a video, review, photo, email, text, social media post, or other communication (each, a "Submission") and, if you are a Creator User, when you submit "Creator Content". Each Submission, whether submitted to the Site directly or through a Social Media Platform, and all Creator Content, is subject to the applicable Creators Terms of Service or Advertisers Terms of Service. As a result, others may access it, use it, and share it in accordance with the applicable Terms of Service.
3.2 Information from third parties
3.2.1 We may also obtain information, such as contact details (for example, name and email address), country, IP address, purchase histories, marketing preferences, cookie information, hardware and software information and other technical information about you from third parties, such as other users of the Site who upload information or sync their contacts, analytics companies, Social Media Platforms, and other third party business partners.
3.2.2 We and our third party business partners may collect information about your visits to and activity on the Site and other websites and services. We may combine that information with other personal information we have collected from or about you. We may share certain of this information with third party business partners for similar purposes.
4. Cookies and tracking technologies
4.1 Cookies and tracking
4.1.1 When you visit the Site or otherwise interact with us or our content, we and third-party advertising and analytics companies and other third party business partners may use a variety of tracking and other technologies that automatically or passively collect certain information ("Usage Information").
4.1.2 We may use these technologies for a number of reasons, including to save your preferences for future visits, to the Site, keep you logged in between visits, to serve targeted advertising to you, and to provide you with improved services. The information we collect may include (but is not limited to):
date and time of your visit to the Site;
areas you visit within the Site;
links that you click on within the Site;
websites or advertisements you visit before or after visiting the Site;
terms you entered into a search engine that lead you to the Site;
IP address, mobile device identifier, or other unique identifier and usage information for the device used to access the Site;
precise location data from your device, if you have opted-in to the collection of that information (you may be able to disable the collection of precise location data through the settings on the device used to access the Site, but your approximate location may remain available through its IP address or other information that we collect);
device and connection information, such as browser type and version, operating system, and platform; and
whether an email message we sent was opened and whether a link in the email message was clicked.
.4.1.3 The methods that may be used to collect Usage Information include the following:
Cookies and Local Storage. A cookie is a data file placed on a device when it is used to visit the Site or otherwise access our content. Certain web browsers and certain browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on the Site may make use of this local storage. Cookies, Flash cookies, and other local storage devices may be used for a variety of purposes (for example, to identify your device when you revisit the Site, to recall your authentication information, to store information related to your navigation throughout the Site, or to enable certain features on the Site). Some cookies are essential to the functioning of the Site, and, without them, some features and services you have requested cannot be provided. If you disable cookies, adjust privacy settings on your device, restrict local storage, or otherwise limit these technologies, you may not be able to use some of the Site features.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "pixels", "1x1 GIFs" or "clear GIFs") may be included in web pages and email messages. Web beacons may not be visible to you. Web beacons or similar technologies may be used for a number of purposes, including to count visitors to the Site, to monitor how users navigate the Site, to count how many email messages we sent were opened, and to count whether a link in an email message we sent was clicked.
Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted after you are no longer connected.
Other Technologies. We may also use other technologies that collect similar information for security and fraud detection purposes.
4.2 "Do Not Track" Signals
4.2.1 Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, Brane does not currently alter our practices when we receive a "Do Not Track" signal from a visitor’s browser except as specifically required by law.
5. How we use information
5.1 We may combine information that we have received from you with information from other sources to operate, tailor content, personalize, adjust, and improve the Site. We use your information:
5.1.1 to fulfill your request for a Brane Video, accept your payment, ship and deliver your orders, deliver email messages, and process information you provide through the Site;
5.1.2 to maintain your account, to assist with payment transactions, to facilitate use of the Site, and to communicate with you about your account, our relationship with you, and your use of the Site, such as by verifying your information, requesting that you respond to a survey, or checking on the status of an order or request;
5.1.3 to establish and manage a relationship with you as a Creator User or Brane business partner;
5.1.4 to send you promotional email or text messages communications from Operator (not from any third party) if you have opted in to receive them;
5.1.5 to provide you and others with customer service, to assist in resolving issues, and to evaluate and improve our customer service and processes;
5.1.6 to use any Submission or Creator Content as set forth in the applicable Creators Terms of Service or Advertisers Terms of Service, which may include the public display of some information, such as your name, username, or where you reside;
5.1.7 to contact you about administrative matters, such as the applicable Creators Terms of Service or Advertisers Terms of Service, or other issues;
5.1.8 to better understand your personal preferences and to enable us to provide you with improved and personalized communications and services;
5.1.9 to compile aggregate data about Site traffic and interaction;
5.1.10 to tailor the content and advertising we display to you or others, on the Site or elsewhere, and to analyze trends and statistics;
5.1.11 to create advertising models through lookalike modelling or other research methodologies;
5.1.12 for internal business purposes, such as improving the Site, products, and services and to comply with legal requirements and our business practices, such as our recordkeeping, backup, and document retention policies; and
6. How we share information
6.1 We share non-personal information, such as aggregated statistics and de-identified information, with third parties to the extent permitted by applicable law. Operator also shares personal information as provided below in more detail. We do not share personal information with any third party to use for its own marketing or promotional purposes without your consent.
6.2 We share information with our affiliates, as relevant, who use it for the same purposes for which we use it.
6.3 We use third parties to perform certain services on our behalf, such as hosting the Site or Site features, providing website usage analytics, fulfilling orders, processing payments, sending email or other communications, providing marketing assistance and data analysis or enhancement, running Promotions, or performing other administrative services. We may share information about you with these third parties to allow them to execute, deliver, or improve the services that they provide for you and for Operator.
6.4 We may share information when you request us to do so, for example, if you opt-in to receive a communication from a third party or if you engage with a Social Media Platform or other third party application or feature through which information about you is shared.
6.5 To the extent permitted by applicable law, we will disclose your personal information pursuant to a law, regulation, court order, or other legal request or process, such as disclosure to law enforcement or other government officials or agencies in connection with any investigation, for example of fraud, intellectual property infringement, or any other activity that is or may be illegal or may expose Operator, you, or another to legal liability.
6.6 We will disclose your personal information when necessary to exercise, enforce, establish, or defend our legal rights. For example, we may review your account information in order to investigate allegations of hacking or a breach of the applicable Terms of Service. We will disclose your personal information to our legal and other advisors, consultants, and law enforcement or other government entities.
6.7 We will disclose your personal information to third parties when we believe the disclosure is necessary to protect the rights, property, or safety of another. For example, we disclose personal information relating to a Site account if we in good faith believe that a Site account is being used in ways that are harmful to another or contrary to the applicable Creators Terms of Service or Advertisers Terms of Service.
6.8 In evaluating or engaging in a sale of assets, merger, acquisition, reorganization, bankruptcy, or other transaction, we reserve the right to disclose, transfer, or assign your personal information and communications. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.
7. Children and Parents
7.1 The Site is intended for a general audience and not for use by anyone younger than the age of 18. We do not knowingly collect personal information from children younger than the age of 18 without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used your child’s personal information without your consent, please contact us to [email protected]
8. Accessing Personal Information and Retention Period
8.1 Please note that if you choose not to provide us with certain personal information, we may not always be able to provide you with the relevant Brane product or service that you request.
8.2 If you have a Site account, you may access, view, correct, or update certain personal information collected about you, as well as deactivate or delete the account. To delete your account please use this function in your account settings or write us to [email protected]
8.3 If you have any concerns about how we are using your personal information, would like to access, correct, or delete the personal information that you have provided to us, please contact us to [email protected]
8.4 Retention Period. When you request that we delete your personal information, we will take commercially reasonable steps to remove it from our active databases but will keep original information consistent with our business practices to the extent permitted by applicable law (for example, for purposes of dispute resolution, enforcement of agreements, complying with legal requirements, recordkeeping, backup, and document retention).
9. Data Security
9.1 Operator takes commercially reasonable security measures to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and you use the Site and transmit information to us at your own risk. If you have any questions about security on the Site, please contact us to [email protected]
10. This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).
10.1 California residents that have an established business relationship with us can request a notice disclosing the categories of Personal Information we have shared with third parties during the preceding calendar year for the third parties’ direct marketing purposes. To make such a request from us, if entitled, please use the contact information listed below.
10.2 Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:
10.2.1 Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
10.2.2 Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
10.2.3 Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place. We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or the Site visitors.
10.2.4 Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
10.2.5 Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and Service that you do not wish such operators to track certain of your online activities over time and/or across different websites. We do not support Do Not Track requests at this time.
10.2.6 To submit a request to exercise any of the rights described above, you may contact at [email protected]
. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.
11. If you have questions or concerns regarding privacy using our Service, please contact us at [email protected]
12. Notice to UK And EEA Users
12.1 For privacy-related information applicable to people located in the UK or EEA:
12.2 If you have any questions about how we use your personal data, or to exercise your data protection rights please contact us at [email protected]
12.3 Legal Basis for Processing Information
12.3.1 We process your information for the performance of the Site, to provide or support our products and services, or for any other reason you request or enable. This includes, for example, using your information to:
administer your Site account;
facilitate your participation on the Site as a Creator User, or prospective Creator User;
support purchases you make, including, but not limited to, processing payments and orders;
support Site functionality;
provide customer service;
if you are a Creator User of the Site, to assist you in connection with your participation in our platform, offering and providing Brane Videos and other offerings, and in connection with payments from our third-party payment provider, as specified in the Creators Terms of Service.
12.3.2 We process your information based on your consent where consent is the lawful basis for such processing. This processing includes Operator providing you with:
newsletters, direct emails and surveys about the Site;
certain other marketing features.
12.3.3 Where Operator relies on your consent as the lawful basis for processing your personal information, you have the right to withdraw your consent to further use of your personal information at any time. Please contact us at [email protected]
12.3.4 To process your information when Operator has a legitimate interest to do so. This includes, for example, processing your information to:
provide you with requested customer service or technical support;
debug and improve the current and future Site;
provide you with certain content, personalize your Site experience with us and contact you in accordance with your applicable marketing preferences;
monitor activity on the Site to prevent or detect any fraudulent use of the Site;
prevent or detect any fraudulent payment;
establish, exercise, or defend legal claims or in connection with any court or jurisdiction.
12.3.5 You may request more information regarding our legitimate interest balancing test where this is our lawful basis by sending an email message to [email protected]
with your request and confirmation that you are in the UK or EEA.
12.3.6 To process your information for compliance with any legal obligation to which Operator is subject.
12.4 Your rights to your information
12.4.1 In addition to your rights to view, correct, and update your information, you may submit a request to access or remove your personal information, by sending an email message to [email protected]
with your request and confirmation that you are located in the UK or EEA.
12.4.2 In certain circumstances, you can request that we transfer personal information that you have provided to us by sending an email message to [email protected]
with your request and confirmation that you are located in the UK or EEA.
12.5 Your right to object
12.5.1 You may object to the processing of your personal information based on a legitimate interest on grounds relating to your circumstances. You may, in particular, control the extent to which Operator markets to you and you have the right to request that we stop sending you marketing messages at any time. To do so, please contact us at [email protected]
12.6 .Exercising your rights and complaints
12.6.1 For each of the rights described above, please contact us at [email protected]
12.6.2 Your right to file complaints with a data protection supervisory authority in the country where you live or work or where you consider a breach has occurred remains unaffected.
12.6.3 Your information will be collected, processed, and stored directly on or transferred to servers in the Singapore In addition, it may be transferred to other countries where Operator, other Operator affiliates, or third party business partners maintain facilities or business operations, which may include countries outside the UK or EEA. Where we are required by law to implement appropriate safeguards to protect your personal information, we use European Commission-approved contract clauses to do so. If you have questions, please contact us at [email protected]
13. Notice to Users Outside the California, UK and EEA
13.1 Your information will be collected, processed, and stored directly on or transferred to servers in the Singapore and may be transferred to other countries where Operator, Operator affiliates or our third party business partners maintain facilities or business operations. Your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such countries.