Legal
Bragi Privacy Statement
When does this Privacy Statement Apply?
Bragi is an analytics and brand campaign management platform for users of X and LinkedIn, which tracks impressions, engagement, followers, best posting times and top posts across one or more accounts. Users link Bragi with their X account and provide the context of their brand campaign, Bragi generates posts and replies which users can post. Alternatively, users can also give their permission for Bragi to auto-post generated content on their behalf under the X account they choose to link with Bragi.
This Privacy Statement applies to the processing of personal data in the context of:
- Accessing and using the Bragi web application (“Bragi”/ the App) and creating or updating user (“you”/“your”/user) profile.
- Your interactions with MIH AI BV in the context of support and deployment of Bragi
Please note that Bragi cannot be used by individuals under 18 years of age. By using Bragi, you explicitly confirm that you are above the age of 18. We reserve the right to conduct further checks and analysis to confirm that users are above the age of 18.
Who Is Responsible for Your Personal Data?
MIH AI BV, a company of the Prosus Group, is the controller responsible for processing your personal data. This Privacy Statement provides you with the information on what personal data we may collect, for which purposes and under which legal grounds, as well as who may have access to your personal data.
We may collect your personal data:
Directly from you - You remain in control of the information you share with us:
- When you create a Bragi account. This may include your name, email address and profile settings.
- If you decided to link your X/LinkedIn account, or an account of which you are an authorized representative, with Bragi.
- Data you choose to provide while setting up your account onboarding and during your use of Bragi.
- Provide feedback, contact support, or report errors.
We also collect your personal data indirectly (automatically) as a result of your interactions with the Bragi app:
Before you connect, Bragi uses the handle you enter and your public display name and bio to start setting up your Bragi account. We may also collect personal data indirectly and automatically during your interactions with Bragi, including:
- Data collected by Bragi when scanning your X or LinkedIn account
- Log data and usage history.
- Device type information and device identifiers.
- Time zone.
- Session data.
Please note, your personal data will not be used for the purposes of training or otherwise improving any AI models.
For which purposes do we process your personal data?
To operate Bragi
When you create an account and interact with Bragi, we will process your personal data for the purpose of operating the App. This primarily refers to any personal data processed during onboarding and while setting up a campaign through Bragi, including providing users with analytics.
On what legal grounds do we process personal data for this purpose?
We process your personal data for this purpose to fulfil the contract with you under the Bragi Terms of Service (ToS).
Which personal data do we use for such purposes:
- Account information – your name, e-mail, X account handle and/or LinkedIn public account as determined by you. We may also process the account information of additional users you wish to view and manage your campaign on Bragi.
- Campaign information – as determined by the user while setting up their campaign. This includes information such as user X/LinkedIn account description, positioning and intended audience for a user’s campaign
- Generated content – in accordance with the parameters and conditions set by the user, Bragi can generate posts and replies to comments as decided by the user
To personalize your marketing/branding campaign on Bragi
To enhance, customize and personalize your Bragi marketing/branding campaign as per a user’s requirements.
On what legal grounds do we process personal data for this purpose?
Depending on the nature of your engagement with Bragi, we process your personal data to fulfill the contract with you under our ToS.
Which personal data we use for such purposes:
You may choose to provide Bragi with the following information:
- voice/tone and style of posts and replies generated by Bragi
- guidelines and topics that a user wants Bragi to adhere to while generating content
- examples of your own posts/content for Bragi to learn from
Users may also choose to allow Bragi to automatically post on their behalf (posts and replies, as decided by the user) on X under the handle linked to a user’s Bragi account. This can be disabled at any time. When a user chooses to enable this feature, they can also choose to provide Bragi with information regarding the frequency of such posts (posting window, time).
For the technical and functional management of Bragi
When you use Bragi, we process your personal data to enable your access, or to detect potential misuse. This processing may be done via automated systems without the use of human review. Please note that no automated decision-making as referred to in Article 22 of the European General Data Protection Regulation (GDPR) takes place.
We also process your personal data for troubleshooting, and to analyse and evaluate usage of Bragi to measure its efficiencies and impact. We may also process your personal data to improve Bragi; this relates specifically to enabling the context-awareness of the product to improve the quality of generated content in future interactions.
On what legal grounds do we process personal data for this purpose?
We process your personal data whilst using Bragi (i) based on our legitimate interest to improve Bragi and monitor its performance and efficiency, (ii) to comply with applicable legal obligations and/or enforceable governmental requests. Where we process your personal data based on our legitimate interest, we have conducted a legitimate interests assessment to ensure that our legitimate interests are not overridden by your interests or rights and freedoms.
Which personal data do we process for this purpose?
We process the following categories of personal data in the context of your use of Bragi:
- Account information – your name, e-mail
- Bragi log and usage data
- Feedback and details of support queries
Who Has Access to Your Personal Data?
Access to your personal data within Prosus Group
As a global company, data we collect may be transferred internationally. Your personal data may be exchanged with the parent company of MIH AI BV, the Prosus Group located in the Netherlands.
Employees in the group are authorized to access your personal data only to the extent necessary to serve the purposes described above and perform their jobs.
Access to your personal data by suppliers
If the nature of services provided by our suppliers requires access to your personal data, we will take appropriate contractual, technical, and organizational measures to ensure that your personal data is securely processed only to the extent necessary for the provision of those services.
If such third parties act under our instructions as data processors, we enter into an agreement with those processors and include obligations to ensure that personal data is processed solely to provide products or services to us. In particular, the following categories of third parties may have access to your personal data:
- Technology and hosting providers.
- Large language model providers.
- Cybersecurity solution providers.
- Auditors, consultants, and law firms.
Access By Other Third Parties
We may share personal data if required by applicable law or agreement, legal process, or a binding governmental request, or where disclosure is otherwise appropriate due to safety or similar concerns.
This may include sharing data in connection with, or during negotiations of, any merger, sale of company assets, consolidation, restructuring, financing, or acquisition of all or part of our business by or into another company.
Where any data sharing outlined under this section involves an international data transfer outside the European Economic Area, the transfer will take place in accordance with applicable data privacy requirements. When transferred to a non-adequate country, this includes use of the European Commission Standard Contractual Clauses (SCCs).
How is your personal data secured?
We have taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical, and organizational measures to protect personal data against accidental or unlawful destruction, accidental loss, damage, alteration, unauthorized disclosure or access, and other forms of unlawful processing, including unnecessary collection or further processing.
Your Rights
Under applicable data protection and privacy laws, you may have the right to:
Access your personal data
You may ask us what personal data we process about you and ask us to provide a copy of that personal data where required by applicable data protection laws.
Correct and delete your personal data
You may request that we correct inaccurate personal data we process about you. You may also ask us to delete personal data that relates to you if it is no longer necessary for the purposes for which we processed it, if you have withdrawn consent and we have no other legal ground for processing it, if it has been unlawfully processed, or if it must be erased under applicable EU or EU Member State law. You may also delete your personal data by using the delete campaign or delete account functionality in Bragi.
Object to processing your personal data
You may object to our processing of your personal data based on legitimate interest. We will no longer process your personal data for that purpose unless we have an overriding legitimate interest. You may also ask us to erase your personal data unless there is an overriding legitimate interest for the processing.
Data Portability
Where applicable, you may request receipt or transmission to another organization, in a machine-readable form, of personal data you have provided to us.
Lodge a complaint with the appropriate Data Protection Authority
If you feel that we do not comply with applicable data protection and privacy laws, you have the right to lodge a complaint with your local supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens.
Restrict the processing of your personal data
You may request restriction of the processing of your personal data where you contest its accuracy, where the processing is unlawful but you oppose erasure, where you require the data for legal claims, or where you have objected to processing based on our legitimate interest pending our verification.
How To Exercise Your Data Protection Rights
If you would like to exercise any of your data protection rights, please contact us through authorized channels. Your request should describe the personal data you want to access and the right you want to exercise. You will need to provide information that allows us to authenticate your identity, as appropriate.
Retention Of Personal Data
Your personal data will be retained only for as long as we need to provide Bragi’s services to you, comply with legal obligations to retain data under applicable law, or serve other legitimate business purposes such as safety, fraud prevention, and adherence to Bragi’s Terms of Service. Retention periods depend on the type of data, how we use it, and your settings. Upon deletion of your account, personal data will be deleted within 30 days unless retention is required on one of the grounds described above.
Contact Information and Changes to This Privacy Statement
If you have questions about the processing of your personal data, or if you want to exercise any of your individual rights, please contact us through authorized channels
This Privacy Statement may change over time. The most up-to-date Privacy Statement will be available in Bragi with information on the last date of update.
Contact
Questions about this statement, or a request about your personal data, go to support@bragi-ai.com.