Introduction

Your privacy is important to us. This Privacy Policy ('Privacy Policy') describes how Bruno Software, Inc. ('Bruno', 'we', 'us', or 'our') may collect, use, store, disclose, process, and transfer your personal information through your access to or use of Bruno products and services, including those at https://www.usebruno.com as well as any subdomains, website of ours that links to this Privacy Policy, related websites, mobile applications, and other offerings (collectively, the 'Services').

By using the Services or, if required by laws applicable to you, opting into this Privacy Policy, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

Bruno may change this Privacy Policy from time to time by posting changes at https://www.usebruno.com/privacy-policy and may send notification emails regarding such changes. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes, unless additional consent is required.

Privacy Policy Applicability

Bruno offers a local desktop application for users to test and explore application programming interfaces (APIs). Users can make requests, view responses, write tests, and documents APIs through using the Services.

This Privacy Policy applies when you use or access the Services or share information with Bruno. By accessing or using the Services and/or opting into this Privacy Policy (as applicable in your jurisdiction), you consent to this Privacy Policy. Bruno may update this Privacy Policy at any time. If you do not consent to this Privacy Policy for any reason, please do not access or use the Services or share your information with us.

Please note that this Privacy Policy applies only to the Services and not to any other third-party website linked to or from it, or any third-party website in which Bruno's content or functionality is embedded. We do not control the privacy policies or practices of others.

Information We Collect from You

In general, we receive and collect all information you provide via the Services, including through website input fields, advertisements, phone, email (including email campaigns), forums, or other such ways. This includes personal information that can identify or relates to you, including, but not limited to:

Category of Personal InformationExamples of Personal Information We CollectSources from which such Personal Information is CollectedThird Parties to whom we share such Personal Information
Profile or Contact DataFirst and last name, email addressYou, Service providersThird-party vendors
Commercial DataRecords of products or services sold, used, or purchasedYouService providers
Device/IP DataIP address, type of device, information collected automatically through cookies and similar technology, device type, domain names, and access time/logsYou, Service providersData analytics providers, Third-party vendors
Web AnalyticsWeb page interactions, Referring webpage/source through which you accessed the Services, Browsing activity, including the addresses of websites that you visitService providersThird-party vendors
Geolocation DataIP-address-based location informationYou, Service providersData analytics providers, Service providers, Third-party vendors
Professional or Employment-Related DataEmployer, Job titleYou, Service providersService providers
Other Identifying Information that You Voluntarily Decide to ProvideIdentifying information in emails, phone calls, texts, letters, or other communications you send us, Identifying information you post to blogs, competitions, live chats, forums, or message boardsYou, Service providersService providers

You have the choice regarding what information you share and the Services you want to engage. You can choose not to provide information to us, but in general, some information about you is required in order for you to access certain functionalities of the Services.

We may periodically obtain information about you from our partners and other independent third-party sources and will add it to our database of information, including any information that you provide to third parties that are associated with or whose products or services are integrated with the Services.

We may use cookies, device identifiers, advertising identifiers, and similar tracking technologies, including those from third-party service providers like Google Analytics, Google AdWords, HubSpot, PostHog, and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. For example, we may collect your IP address, Web browser details and the address of any referring website. We may also collect information about your online activity, such as pages viewed and interactions with the user interface. This may include collecting geolocation signals from your IP address to determine your general location. By collecting and using this information, we may operate and personalize the Services for you and may also combine this data with other information we have collected about you.

The Services are designed to recognize or respond to 'do not track' signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and your options for opting out of interest-based Google ads at https://adssettings.google.com. You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.

Sensitive Information

Bruno does not collect any sensitive personal information through our Services. Sensitive personal information, as defined by applicable data protection laws, includes information relating to your race, ethnicity, religious beliefs, moral beliefs, philosophical beliefs, sex life, sexual orientation, gender identity, political opinions, trade union membership, citizenship status, national origin, medical information (including mental health), genetic data, biometric data, or financial information (such as account numbers). We also do not collect any information about criminal convictions or offenses.

Cookies

Cookies, also known as tracking cookies or browser cookies, and similar technologies such as web beacons, clear GIFs, pixel tags, and JavaScript (collectively, 'Cookies') are small pieces of data, usually text files, placed on a computer, tablet, phone, or similar device when you use that device to access the Services. We use the following types of Cookies:

Essential Cookies: Essential Cookies are necessary for providing you with the Services and features that you requested. For example, these Cookies allow you to log into and stay logged into secure areas of the Services, save language preferences, and more. These Cookies are required to make the Services available to you, so they cannot be disabled.

Functional Cookies: Functional Cookies are utilized to record your choices and settings, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us personalize our content for you, greet you by name, and remember your preferences.

Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how visitors (like you) use the Services. These Cookies accomplish this by collecting information about the number of visitors to the Services, what pages visitors view the most, and how long visitors view specific pages. These Cookies also help us measure and manage the performance of our advertising campaigns in order to help us improve the campaigns and the Services' content. For example, Google LLC ('Google') uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google's use of Cookies by visiting the Google advertising opt-out page at http://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You have the option to decide through your internet browser's settings whether or not to accept Cookies. Most browsers allow users to choose whether to turn off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the browser) allow you to toggle whether to accept each new Cookie. You can also clear all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit the Services and some functionalities may not work. To explore what Cookie settings are available to you, look in the 'settings', 'preferences' or 'options' section of your browser's menu.

To find out more information about Cookies, including information about how to manage and delete Cookies generally, please visit http://www.allaboutcookies.org/.

How We Use Your Information

We process your personal information with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Bruno as described in this Privacy Policy.

More specifically, we may use your personal information to:

Optimize and improve the Services: We continually try to improve the Services based on the information and feedback we receive from you and our other users, including by optimizing the content on or functionalities of the Services.

Personalize the user experience: We may use your information to measure and optimize engagement with the Services and to understand how you and our other users interact with and use the Services and other resources we provide.

Improve customer service: Your information helps us to more effectively develop the Services and respond to your support needs.

Process transactions: We may use the information you provide to fulfill your requests. We do not share this information with outside parties except to the extent necessary to provide the Services and related activities.

Send periodic communications: The communication methods you provide through our contact forms will be used to send information and updates pertaining to the Services. It may also be used to respond to your inquiries or other requests. If you opt into our mailing list, you may receive emails that include Bruno news, updates, product offerings and service information, and marketing material. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below. Please note that if you unsubscribe from promotional emails, you may still receive communications related to your subscription, your purchase, or other necessary functionalities of the Services.

Carry out other legitimate business interests: We may use the information you provide to carry out other legitimate business purposes, as well as other lawful purposes.

How We Share Your Information

We share your information with our partners, service providers, contractors, agents, and third-party vendors indicted in the 'Information We Collect from You' section as needed to fulfill Services. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, or respond to a request you submit.

Third-party vendors who provide products, services or functions on our behalf may include cloud database providers, data analytics companies, marketing vendors, and security vendors. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

We also may share your information:

In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.

When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our Terms of Service and other agreements with customers of which you may be affiliated.

In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas

When you post a message in a Bruno forum, review, or customer feedback, the information you post may be accessible to other users of the Services and the public. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full risk and responsibility for posting such information and agree that Bruno is not responsible in any way for personal information you choose to post in these public areas.

Aggregated Information

We may use, publish, share, distribute, or disclose personal information that has been aggregated with information from other users and otherwise anonymized and de-identified in a manner that does not allow third parties, including Bruno partners, customers, and vendors, to de-identify the data or identify it as originating from you. Such information may help Bruno identify and analyze training, demographic, and psychographic trends and information and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, or other materials. We may also use such data for research purposes and optimizing the Services' functionality.

How We Store and Secure Your Information

Personal information collected by Bruno may be stored and processed in your region, in the United States, and in any other country where Bruno or its affiliates, subsidiaries, or service providers operate facilities. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Bruno takes technological and organizational measures designed to protect your personal information against loss, theft, and unauthorized access, use, disclosure, or modification. For example:

We transmit data over secured communication channels using SSL Login credentials

All personal information is stored by trusted third party providers (e.g., Amazon Web Services (AWS))

All systems used to provide the Services are password protected

All Services usage is restricted on a per-user basis on the principle of least privilege

All data is encrypted during transfer and while at rest

We rely on AWS' security programs to protect personal information while stored in their respective controlled facilities. For more information on AWS' security practices and processes, please see https://aws.amazon.com/security/.

Bruno complies with applicable data protection laws, including applicable security breach notification requirements.

Data Retention

Bruno will retain your information as long as necessary for the purposes outlined in this Privacy Policy, in a manner consistent with our data retention policy discussed in this section, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes or as permitted by applicable law. Bruno will retain your personal information consistent with the original purpose of collection or as long as necessary to comply with our legal obligations; maintain accurate accounting, financial and other operational records; resolve disputes; and enforce our agreements. We will never retain your information for a period longer than permitted by law.

We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed; the purpose for which it was collected; the potential risk of harm from unauthorized use or disclosure of the personal information; whether we can achieve the purposes of the processing through other means; and applicable legal requirements.

After expiration of the applicable retention periods, your personal information will be deleted. As discussed below, you may have the right to request we delete this information earlier.

Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may:

Have the right to access certain personal information we maintain about you and request details about how we process it

Request certain information regarding our disclosure of personal information to third parties

Request that we update or correct inaccuracies regarding your personal information

Object to our use of your personal information

Ask us to block or delete your personal information from our database

Request to download the information you have shared on the Services

Confirm whether Bruno stores your data in the United States

You may make these requests and any other inquiries about this Privacy Policy by emailing privacy@usebruno.com. Any such requests are subject to the protection of other individuals' rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the requested information.

Data Transfer

Our databases are currently located in the United States. Bruno makes no claim that its Services are appropriate or lawful for use or access outside the United States. If you access the Services from outside the United States, you are consenting to the transfer of your personal information from your location to the United States. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By providing us your information, you further consent to its storage within the United States.

Collection of Data from Children

The Services are not directed to children, and you may not use the Services or provide any personal information to Bruno if you are under the age of 16 (or the lowest age permitted by applicable law) or if you are not old enough to consent to the processing of your personal information in your country. We do not collect or process personal information of individuals under the age of 16 or the lowest age permitted by applicable law unless we receive all necessary consents from the individual's parent or guardian.

California Resident Privacy Rights

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services.

California Consumer Protection Act: Effective January 1, 2020, the CCPA allows California residents twice a year, upon a verifiable consumer request, to request that a business that collects consumers' personal information to give consumers access to their personal information.

European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union ('EU'), United Kingdom ('UK'), Switzerland, Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the 'GDPR') or the Swiss Federal Act on Data Projection ('FADP'), as applicable, with respect to your Personal Data. The following discusses these rights.

For this section, the GDPR definition of 'Personal Data' and 'processing' are used. Generally, 'Personal Data' means information that can be used to individually identify a person, and 'processing' relates to actions that can be performed in connection with collecting, using, storing, and disclosing such data. Bruno is the controller of your Personal Data processed in connection with the Services.

If a conflict exists between this this section and any other provision of this Privacy Policy, the more protective policy or portion shall govern to resolve such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@usebruno.com.

We may also process Personal Data of our customers' end users in connection with our provision of services to our customers. In this case, we are the processor of Personal Data. If you have any questions regarding Personal Data when Bruno is the data processor, please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data Use and Processing Grounds

We will only process your Personal Data as explained in this Privacy Policy and if we have a lawful basis for doing so. The lawful bases include receiving your consent, having a contractual necessity, and furthering our legitimate interests or the legitimate interest of others. The following sections describe these in greater detail.

Consent: We process Personal Data based on the consent you expressly grant to us at the time we collect the data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Contractual Necessity: We may process the Personal Data as a matter of 'contractual necessity'. This means that we need to process the data to perform under our agreement with you and enable us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services.

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties providing products or services in connection with the Services:

Profile or Contact Data

Commercial Data

Device/IP Data

Web Analytics

Geolocation Data

Professional or Employment-Related Data

Other Identifying Information that You Choose to Provide

We may also de-identify and anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above in the 'How We Use Your Information' section):

Providing, customizing, and improving the Services

Marketing the Services

Corresponding with you

Meeting legal requirements and enforcing legal terms

Completing corporate transactions

Other Processing Grounds: Occasionally, we may also need to process Personal Data to comply with legal obligations, to protect the vital interests of you or other data subjects, or to carry out a task necessary for the public's interest.

Sharing Personal Data

The 'How We Share Your Information' section above details how we share your Personal Data with third parties.

Transfers of Personal Data

The 'Data Transfer' information in the 'Additional Privacy Information' section above details how and where we transfer your data. Most significantly, our databases are currently located in the United States, and you are consenting to Bruno transferring your Personal Data to the United States.

EU and UK and Swiss Data Subject Rights

EU and UK and Swiss data subjects have certain rights with respect to Personal Data. This is further set forth below. For more information about these rights or to submit a request, please email us at privacy@usebruno.com. Please note that in some circumstances, Bruno may be unable to fully comply with your request, including if the request is frivolous, extremely impractical, jeopardizes other's rights, or not required by law. In those circumstances, we will still notify you of such a decision. Generally, we may also need you to provide us additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include:

Access: You can request information related to the Personal Data we store about you and request a copy of such Personal Data

Rectification: If you believe that any Personal Data we store about you is incorrect or incomplete, you can request we supplement or correct such Personal Data

Erasure: You can request we erase part or all of your Personal Data from our systems

Withdrawal of Consent: If we are processing your Personal Data based upon your consent (as indicated at the time of collection of such data), you have the right to withdraw consent at any time. However, please note that if you change or withdraw consent, you may have to then provide express consent on a case-by-case basis if use or disclosure is necessary to enable you to use the Services

Portability: You can request for a copy of your Personal Data in a machine-readable format. You can also request we transmit the Personal Data to another controller to the extent such transmission is technically feasible

Objection: You can contact us to object to our further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes, by contacting us as described above

Restriction of Processing: You can request Bruno restrict further processing your Personal Data

Right to File Complaint: You have the right to submit a complaint about Bruno's practices with respect to your Personal Data to the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Transfers of Personal Data

The "Data Transfer" information in the "Additional Privacy Information" section above details how and where we transfer your data. Most significantly, our databases are currently located in the United States, and you are consenting to Bruno transferring your Personal Data to the United States.