Privacy Policy

Dice Media Group, LLC. Privacy Policy – December 28, 2023

This Privacy Policy explains the privacy practices of DMG, LLC and our affiliates (“DMG”, “us” or “we”) when you use Bravura.com or our other websites and online channels (collectively, the “Site”) as well as our mobile applications, software, contents, products, and services available through our websites and online channels (the “Services”). By accessing our Services in any manner, you agree to our privacy practices as described in this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use our Services.

This Privacy Policy is governed by and part of our Terms of Use. Additional, separate terms apply to your use of Bravura, specifically the DMG Terms of Use, and Bravura Terms of Use, each of which are considered part of these Terms. Please note that this Privacy Policy does not apply to any third-party platforms or services, including a website or platform developed or operated by our Users. If you have any questions about our privacy practices or would like to make a complaint, please contact DMG at mike@dicemediagroup.com.

Personal Data.

When we say, “Personal Data,” we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data falls within certain categories, for example:

• Identifiers (e.g., name, email, telephone number, address, username);
• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
• Internet or other similar activity (e.g., browsing history; content interactions);
• Employment-related information (e.g., current or past employment);
• Legally protected information (e.g., race, citizenship, marital status, sex);
• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);
• Sensitive Personal Data (e.g., government identification number; precise geolocation; racial or ethnic origin; religious beliefs; health information; contents of messages when we are not the recipient; in some cases, information about a known child);
• Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information; and
• Inferences drawn from Personal Data to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.

Some information is not legally protected as Personal Data, such as publicly available information; aggregated information (meaning data summaries or reports with Personal Data removed); and anonymized information that cannot be linked back to an individual.

1. Age Requirements.

DMG Services are intended for use by adults, not children. You must be at least 18 years of age to use the Services. No individual under the age of 18 should attempt to use the Services or provide any Personal Data to DMG. If we learn we have collected or received Personal Data from a minor under 18 we will delete that information. If you believe we might have any information from or about a minor under 18, please contact mike@dicemediagroup.com.

2. Personal Data Collection and Use.

DMG may collect Personal Data from you when you visit the Site or interact with the Services as a User, or if you contact us by email or other means. DMG collects Personal Data: with your consent as informed by this Privacy Policy and freely given at the time you provide the information; if we have a legitimate interest in doing so; or as authorized or required by law.

2.1. Categories and Sources of Personal Data Collected.

During the preceding 12 months, DMG has collected identifiers, commercial history, and internet and similar information from your visits to the Site and use of the Services, as detailed below:

2.1.1. Users.

When you register as a User of our Services, DMG will collect your name, email address, and password to create your account. You have the option to login via your GitHub account, which allows DMG to receive and sync your account profile with your GitHub profile. Once registered with DMG, you can select and use the various free or paid Services we offer. If you choose to include optional details in your account profile or post User Content to the Services, you consent to our collection of that information as well. If you contact DMG by email or otherwise, we will collect any Personal Information you choose to include your message to us. Any payments for fee-based Services are processed using a PCI-DSS payment processor, so we never access, use, or store your payment information.

2.1.2. Site Visitors.

When you visit the Site to learn about our company and Services, you have the option to communicate with us via email or electronic form. If you do, we will collect your name, email address and other contact information as needed to provide you with the information you request. We collect this information with your consent, and we use it for the purposes stated at the time of collection, to provide you with our Services, and to send you more information about our Services.

2.1.3. Site Activity.

When you visit the Site, DMG automatically collects data about your internet activity, some of which qualifies as Personal Data. We use cookies and similar technologies to collect data like your IP address, ISP, device data, browser type, and content interactions to achieve our legitimate interest of providing, managing, and improving the Services.

2.2. Uses of Personal Data.

We only collect, use, retain, and disclose Personal Data: to provide our Services; for other purposes that we disclose to you and are compatible with the context of how we collected your Personal Data; or as reasonably necessary and proportionate, adequate, and relevant to the specific, express purposes described in this Privacy Policy. We use the Personal Data we collect to provide you with the Services you request, for our internal business purposes, and for any other purpose to which you consent.

We also reserve the right to use Personal Data to monitor your compliance with our agreements and policies; maintain the security and integrity of the Services; for internal testing, analysis and development; in response to law enforcement and government requests; to bring legal action as necessary to protect DMG, you, or others; or to evaluate or conduct a business transition involving some or all of our company assets where Personal Data held by DMG is among the assets transferred.

We will not collect additional categories of Personal Data or use already collected Personal Data for purposes that are materially different, unrelated or not reasonably necessary or compatible with the original purpose without notice and consent to you as required by law.

2.3. Disclosure of Personal Data to Third Parties.

DMG will only disclose Personal Data to the third parties as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed all types of Personal Data that we collected to third parties for a business purpose. More specifically, we may disclose Personal Data to:

2.3.1. Service Providers.

DMG uses trusted service providers like data hosting services, email platforms, analytics tools, and payment processors to provide key features of the Services and to operate our business. These service providers may have access to the Personal Data we collect if necessary to perform their contractual obligations to us. We prohibit our service providers from selling or disclosing the Personal Data we provide, and we require all service providers to maintain confidentiality standards and appropriate technical and organizational measures to ensure the security of your Personal Data.

2.3.2. Law Enforcement, and other governmental agencies, as permitted or required by law.

2.3.3. Other Recipients, as permitted by applicable law, for example:

if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

2.3.4. Aggregated and Deidentified Information.

DMG reserves the right to share aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.

2.4 Retaining Personal Data.

DMG only retains Personal Data for the minimum period necessary to provide our Services or achieve our business goals. User account data is retained while your account remains active and we delete it when you cancel your account. Data collected from cookies may be retained for up to 24 months. DMG reserves the right to retain data as needed to prevent fraud, as required by law or court order, or if doing so is critical to our business. We securely delete data at the conclusion of the applicable retention period.

2.5 Your Personal Data Controls.

We provide you with a variety of methods to directly control how we collect and use your Personal Data:

2.5.1. Your Account.

You have the option to access, update, or delete your Personal Data through your account settings.

2.5.2. Emails.

DMG may use your contact information to communicate with you about your use of our Services. For example, we may send you service or support communications by email, phone, text, mail, or other means. You understand that you receive these communications as part of your use of the Services. You can opt- out at any time by following the Unsubscribe link at the bottom of our emails, but if you are a User we may still need to contact you with service announcements related to your account.

2.5.3. Revoke consent.

If you wish to revoke a consent already given to us, please contact mike@dicemediagroup.com.

2.5.4. Text/SMS.

By providing us with your wireless phone number, you consent to DMG sending you informational text messages related to the products, Services, or information you have requested from us. The number of texts that we send to you will be based on your circumstances and requests. You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.

2.5.5. Marketing Communications.

We may send you marketing communications by email, mail, or other means in compliance with applicable law. You can opt-out anytime by following the Unsubscribe link in any of our emails or by contacting mike@dicemediagroup.com.

2.5.6. Privacy Requests.

If you wish to exercise your rights under the privacy laws that apply to you, or if you want to express concerns, revoke your consent, lodge a complaint, or request information, please contact mike@dicemediagroup.com or reach out through our Help Center. DMG will respond and fulfill your request as required by applicable law.

2.5.7. Please note that DMG can only assist with or fulfill a privacy request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Data, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We endeavor to respond to privacy requests in accordance with the requirements of the law applicable to your jurisdiction. If we do not fulfill your request within the legally required timeline, you can appeal our response by contacting mike@dicemediagroup.com.

3. Notice of Privacy Rights.

Depending on where you live or are located, you may have certain rights over your Personal Data that we collect and retain. DMG will facilitate your exercise of those rights as described in this section.

3.1. United States Consumer Privacy Rights.

In the United States, consumer privacy rights are provided under state laws and federal laws provide protections relative to certain industries or data uses. This section provides informational notices for under privacy laws for states like California, Colorado, Connecticut, Nevada, Utah, Virginia, and other states that require companies to inform consumers about their privacy rights and provide a method to exercise those rights. Residents of states offering privacy protections (each a “Consumer”) may be entitled to some or all of the privacy rights listed below:

3.1.1. Right to Correct.

You have the right to request that we correct inaccurate Personal Data about you on our systems. If you become aware that the Personal Data that we hold about you is incorrect, or if your information changes, please inform us and we will update our records.

3.1.2. Right to Deletion.

You have the right to request that we delete your Personal Data that we collected and retained, with certain exceptions. DMG may permanently delete, deidentify, or aggregate the Personal Data in response to a request for deletion.

3.1.3. Right to Access.

You have the right to request confirmation that we have collected Personal Data about you and that we provide you with access to that Personal Data. If you submit an access request, we will provide you with copies of the requested pieces of Personal Data in a portable and readily usable format. Please note that DMG may be prohibited by law from disclosing certain pieces of Personal Data, and we may be limited in the number or frequency of requests we must fulfill.

3.1.4. Right to Disclosure.

You may request that we disclose information to you about our collection and use of your Personal Data, such as: (a) the categories of Personal Data we have collected about you; (b) the categories of sources for the Personal Data we have collected about you; (c) our business purpose for collecting, using, processing, sharing or selling that Personal Data, as applicable; (d) the categories of third parties with whom we share that Personal Data; and (e) if we sold or shared your Personal Data under the CCPA, two separate lists stating: (i) sales or sharing, identifying the Personal Data categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. Certain laws may limit the number or frequency of requests we must fulfill.

3.1.5. Limited Use and Disclosure of Sensitive Personal Data.

You have the right to opt- out or limit our use of your sensitive Personal Data. DMG does not seek to collect sensitive Personal Data about any individual, and in no case do we disclose any sensitive Personal Data for the purpose of inferring characteristics about you or otherwise use your sensitive Personal Data without your consent. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to opt-out or limit our use and disclosure of sensitive Personal Data.

3.1.6. No Selling and Sharing.

Some states entitle consumers to opt-out of the sale or sharing of Personal Data or targeted advertising practices. DMG does not sell your Personal Data or share your Personal Data with third parties for cross- contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.

3.1.7. No Profiling.

You have the right to opt-out of automated profiling. DMG does not process your Personal Data to evaluate, analyze, or predict your interests and preferences or otherwise use automated profiling to produce significant effects that concern you. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.

3.1.8. Right to Nondiscrimination.

We will not discriminate against you for exercising your privacy rights. For example, unless permitted by law we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services; (c) provide you a different level or quality of goods or services; (d) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (e) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under applicable privacy laws.