Privacy Policy — Bravely Free Tools

This policy covers bravely.dev/tools and each tool under it, the tools themselves at link.bravely.dev, qr.bravely.dev and color.bravely.dev, the public link pages served at bravely.link, and the Bravely Color Picker menu-bar app for Mac. The free tools are separate from our paid apps, which each have their own policy at bravely.dev/privacy. Signing in uses a Bravely Account, covered at bravely.dev/privacy/bravely-account.

The three small converters (HEX to RGB, HEX to HSL and the color contrast checker) work without an account. The QR code generator, the color picker and the link-page builder need a free Bravely Account. Generating a QR code, picking colors, and building a palette all happen in your browser. We do not upload the URL, text, or Wi-Fi details you put into the QR generator, and we do not upload the colors or images you sample in the color picker.

The first time you open a tool while signed in, we offer a one-time claim for free lifetime access to it. Claiming records your Bravely Account identifier, which tool you claimed, and when — that is the whole record. It is free, it is not a trial, and there is no payment step anywhere in the free tools. The claim card includes a marketing-email checkbox; where local law requires it the box starts unticked, and if you leave it unticked we do not add you to any list.

The link-page builder publishes a public page. Anything you put on it is visible to anyone with the link, and search engines are asked not to index it but we cannot guarantee no one shares it. • Page content — your handle, display name, bio, links and their subtitles, theme, and link style are stored on our servers so the page can be served. • Images — if you upload a profile photo, or an image for one of your links, we store the cropped image in our own file storage and serve it as part of your public page. Do not upload an image you would not want seen publicly. • Click analytics — we count clicks on the links on your page so you can see what is being used. We record the click event, which link, and the time. We do not build visitor profiles, and we do not sell or share this data. • Removal — you can unpublish or delete your page at any time from the editor, which stops it being served and removes its content. We may suspend a page that breaks our terms.

Bravely Color Picker is a menu-bar app for Mac. Picking a color uses the system color sampler, and the colors you pick and your recents list stay on your Mac. The app signs in with your Bravely Account to record the free claim, and checks for its own updates. It does not read your screen contents beyond the single pixel you sample, and it does not upload the colors you pick.

We record aggregate product analytics on the tools — page views, which tool, whether an export or publish succeeded — so we can see which tools are worth keeping and fix what breaks. These events are keyed to an anonymous identifier, and to your Bravely Account where you are signed in. We do not use them for advertising.

We are honest about this: the free tools exist partly to introduce people to Bravely Studios, and the account requirement is how that works. Signing in gives us your email address and lets us tell you about our paid apps if — and only if — you opt in to marketing. You can use every tool without an account up to the export or publish step, you can decline marketing and keep full use of the tools, and you can delete your account at any time.

A link page, its content and its click counts are kept until you delete the page or your account. Deleting a page also removes the profile photo and link images you uploaded for it, unless another of your pages still shows them. An image you uploaded and then replaced, or never put on a page, is kept until you delete your account. An API key works until you revoke it; our record of a key (its name, and when it was made and last used, never the key itself) is kept until you delete your account. Deleting your Bravely Account removes your link pages, published or not, with their links and click counts, your API keys and our records of them, and every profile photo and link image our records show you uploaded, including one that someone else has put on their own page. This happens when the account’s 30-day grace period ends, as the Bravely Account policy describes; from then your pages are no longer shown and your keys stop working. One exception: an image uploaded before we began recording who uploaded each image, and no longer on any page by then, is not linked to an account, so deleting your account does not remove it; email privacy@bravely.dev and we will. Some things are kept. The addresses your pages hold when your account is deleted (their handles) are held and are not given to anyone else; an address you gave up earlier, by deleting or renaming a page, was released at that time. If one of your pages was suspended, we keep the record of that suspension (the page’s address, and when and why it was suspended) under your account identifier, without the page’s content. Reports that other people sent us about your pages are kept. Your free-claim record and the usage events recorded for your account are kept under your account identifier, as the Bravely Account policy describes.

The free tools are intended for adults. We do not knowingly collect personal information from children under 13, or under 16 in places where 16 is the relevant age for information-society services. If you believe a child has published a link page, email privacy@bravely.dev and we will remove it.

We keep backups so that we can recover our customers' data if it is ever lost. Each night we copy the databases that hold accounts, purchases and the content our apps and services keep for their users, including sign-in records and the protected form of passwords, and we copy the files stored with us, such as documents, screenshots and attachments. Unless a section above says otherwise, the account, purchase and content records this policy describes, and the files you store with us, are in these backups. Where backups are kept Backups are kept in two places, both in the United States: on storage equipment that we own, and in Amazon S3, a storage service run by Amazon Web Services. Every copy of a database or of sign-in records is encrypted, with a key that only we hold, before it is stored in either place. The copies of stored files that we keep in Amazon S3 are also encrypted with a key that only we hold, file names included; the copy of those files on our own equipment is not separately encrypted. Amazon does not have our keys, so it cannot read your data in the backups. How long backups are kept Each night's copy of our databases and sign-in records is deleted after 90 days and fully purged within 30 days after that, so it is kept for about four months at most. One copy each month is kept for up to 12 months instead, and fully purged within 30 days after that, so it is kept for about 13 months at most. The backup of stored files keeps each file for as long as it is stored with us; when a file is deleted or replaced, the backup keeps the earlier version for 90 days and then deletes it. Separately, Cloudflare, which runs most of our databases, keeps a recovery history of each of them for 30 days. How backups are used We use backups and that recovery history only to restore data after it has been lost, for example in an outage, through a mistake or in an attack, and we also use backups to test that restoring works. Deleting something, or deleting your account, does not remove it from backups made before the deletion or from the recovery history: those copies stay until they are deleted on the schedules above. If we restore data from a backup or from the recovery history, we re-apply the deletions made after the point we restore to, including account deletions, so that the restore does not bring back data that had been deleted.

Depending on where you live, you have rights over the personal data we hold about you. We honor these rights for everyone who asks, regardless of where you live. • Access — ask what personal data we hold about you and get a copy. • Correction — ask us to fix data that is wrong or incomplete. • Deletion — ask us to delete your personal data by emailing privacy@bravely.dev from the address on your account. Where a product has a built-in Delete Account control you can use that instead; bravely.dev/delete-account explains what applies to each product. • Portability — ask for your data in a portable, machine-readable format. • Objection and restriction — ask us to stop or limit certain processing. • Withdraw consent — where we rely on consent (for example, marketing email), you can withdraw it at any time without affecting processing that already happened. • Non-discrimination — we will not degrade your service or charge you more for exercising any of these rights. EEA and UK residents also have the right to lodge a complaint with your local supervisory authority. California residents may use an authorized agent; we may verify the agent's authority and confirm the request with you first. Other US states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others as they take effect) have equivalent rights, including a right to appeal a denied request — reply to our decision email with "Appeal" and we will respond in writing within the period the law requires. Canadian residents have access, correction, and consent-withdrawal rights under PIPEDA; Australian residents have access and correction rights under the Australian Privacy Principles. To exercise any right, email privacy@bravely.dev. We respond within the timeframe the applicable law requires — generally 30 days under GDPR and 45 days under the CCPA, with an extension where the law permits one. We may need to verify your identity before acting, usually by confirming control of the email address on the account.

If you are in the EEA or UK, we rely on these lawful bases under the GDPR and UK GDPR: • Performance of a contract — creating and securing your account, delivering the features you paid for, syncing your content, processing purchases, and providing support. • Legitimate interests — keeping the service secure and reliable, preventing fraud and abuse, understanding how our products are used through usage events tied to an installation or to your account, and improving the product. We balance these against your rights and do not use them to justify intrusive tracking. Where an app lets you turn its usage analytics off, doing so is one way to object. • Consent — marketing email, and anything else we ask your permission for before we collect it. You can withdraw consent at any time. • Legal obligation — keeping tax, accounting, and consent records, and responding to lawful requests.

Bravely Studios LLC is a US company. We and our sub-processors process data in the United States and in other countries where they operate. For personal data originating in the EEA, UK, or Switzerland, we rely on appropriate transfer safeguards in our processor agreements — such as the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum — where those safeguards are required. Email privacy@bravely.dev if you want more detail about the safeguards that apply to you.

For California residents, the categories of personal information we collect for this product are: • Identifiers — your Bravely Account identifier, email address, and device or installation identifiers. • Commercial information — records of purchases, subscriptions, entitlements, trials, and refunds. • Internet or other electronic network activity — usage events, which carry an installation or browser identifier, your Bravely Account identifier, an identifier for a single request or purchase, or only a shared identifier for the app and platform; app version and platform; crash and error reports. • Coarse geolocation — a country-level signal derived from your network connection, used for consent rules and tax. • Your content — only the content the product is built to store or sync for you, described in the sections above. We collect this from you, your device, and our own systems, and we use it to run the product, honor what you have bought, keep the service secure, and support you. We disclose it to the service providers listed under "Sub-processors," each for a business purpose under a written contract. We do not sell your personal information and we do not share it for cross-context behavioral advertising, as those terms are defined by the CCPA and CPRA, and we have not done so in the preceding 12 months. We do not use or disclose sensitive personal information for any purpose that would trigger the right to limit. If that ever changes we will update this policy and provide the required opt-out before the practice begins. Retention is described under "Data Retention" and "Backups" above and, for account-level data, in the Bravely Account privacy policy.

We use the following service providers to run this product. They receive only what they need to perform their service for us, and each is bound by the data-processing terms that apply to our use of their service. Where a provider is not yet covered by a written data-processing agreement with us, its entry below says so. If you need a data-processing agreement in place before you use this product, email privacy@bravely.dev: • Cloudflare, Inc.: hosting, the Workers runtime, D1 databases, R2 object storage, and bot protection for bravely.dev and our app subdomains. See cloudflare.com/privacypolicy. • Google LLC: Firebase Authentication, which backs Bravely Account sign-in (including Sign in with Google). See policies.google.com/privacy. • Apple Inc.: Sign in with Apple, and App Store purchase and receipt handling for our Apple platform apps. See apple.com/legal/privacy. • Paddle.com Market Ltd: our merchant of record for purchases made on the web or in our desktop apps. Paddle handles checkout, payment processing, invoicing, and sales tax/VAT. When you open a checkout while signed in, we give it your email address; otherwise you enter it on Paddle's checkout page. Each purchase carries the app it is for, any campaign tags on the link that brought you to checkout, and either your Bravely Account identifier or, for a purchase made before you had signed in, a temporary identifier that we link to your account when you claim the purchase. As the seller of record, Paddle keeps its own records of your purchases. See paddle.com/legal/privacy. • RevenueCat, Inc.: keeps the purchase record for each Bravely Account. It validates App Store and Google Play purchases and reports subscription changes, and we also record trials and web and desktop purchases with it, so we can unlock what you bought on every platform. We identify you to it by your Bravely Account identifier. The first time you sign in with Apple or Google, and on some other sign-ins, we also send it your email address, your name (when the sign-in provides one), your country and the app you signed in from. Some apps also record with it the name of the device you use, and a few older parts of our service identify you to it by your email address instead. See revenuecat.com/privacy. • PostHog Inc.: product analytics. Our apps, some of our websites and our account service send it usage events, such as which features are used and the steps of signing in, starting a trial and buying, and our websites and web apps also send it recordings of how their pages are used. An event carries an identifier for the installation or browser it came from, your Bravely Account identifier, or both (most apps add your account identifier once you have signed in); a few events, such as a failed sign-in or a purchase made before you had signed in, carry an identifier for that one request or purchase instead, and some copies of app events that reach it through our account service carry only a shared identifier for the app and platform. PostHog receives the network address each event was sent from. A few apps also send it your email address, and a few older parts of our service identify you to it by your email address instead. The Bravely Account policy describes this under "Usage and Purchase Analytics". See posthog.com/privacy. • Resend Inc.: sends our transactional email (sign-in codes, receipts, password resets, support replies). See resend.com/legal/privacy-policy. • Amazon Web Services, Inc.: Amazon S3, which stores our backups in the United States, as described under "Backups". The copies of your data that we keep there are encrypted, with a key that only we hold, before they leave our systems, so Amazon cannot read them. See aws.amazon.com/privacy. If we add or change a sub-processor in a way that materially changes how your data is processed, we will update this policy and give additional notice where the law or our data-processing commitments require it.

We protect your data with authenticated accounts, encryption in transit, access controls on our backend systems, and a deliberately small number of people who can reach production. No system is perfectly secure, and we do not claim guarantees we have not built and verified. Where a product makes a specific security claim, that claim appears in the app-specific sections above and is limited to what we have actually shipped. If we become aware of a breach affecting your personal data, we will notify you and the relevant regulators as required by law.

We may update this Privacy Policy from time to time. If we make a material change — a new category of data, a new sub-processor, a new purpose, or a new legal basis — we will update the "Last updated" and "Effective" dates and give additional notice where the law requires it. Where a change requires fresh consent under the GDPR, UK GDPR, CASL, or a similar regime, we will ask for it before relying on the new purpose. Non-material changes (typos, clarifications, link fixes) are reflected by updating the "Last updated" date.

Bravely Studios LLC Privacy and data rights: privacy@bravely.dev Product support: support@bravely.dev Website: https://bravely.dev Postal address: available on request to privacy@bravely.dev.