Privacy Notice

Personal Data Processing Notice

1. Data controller

Braqon LLC, with registered office at 30 N Gould St, STE R, Sheridan, WY 82801, USA (“Braqon”), is the controller of the personal data collected through this website. For any data-related matter you may write to [email protected].

2. Representative in the Union (Art. 27 GDPR)

Braqon is established outside the European Union and may process the data of individuals located in the Union under Art. 3(2) of Regulation (EU) 2016/679 (GDPR). Art. 27(2)(a) GDPR provides that the obligation to designate a representative in the Union does not apply to processing which is occasional, does not include, on a large scale, special categories of data (Art. 9) or data relating to criminal convictions and offences (Art. 10), and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing.

The processing carried out through this website consists of the occasional collection of contact details voluntarily provided by those requesting information; it does not involve large-scale processing of special categories or criminal-offence data and is unlikely to result in a high risk to data subjects. On this basis, and consistently with Recital 80 GDPR, Braqon has assessed that it is not required to designate a representative in the Union under Art. 27(2)(a) GDPR. Should the collection of Union data subjects' data become regular or large-scale, Braqon will designate a representative and update this notice.

3. Data Protection Officer (DPO, Art. 37 GDPR)

The processing described is not carried out by a public authority, does not have as its core activity the regular and systematic monitoring of data subjects on a large scale, nor the large-scale processing of special categories of data or data relating to criminal offences. The designation of a Data Protection Officer is therefore not mandatory under Art. 37 GDPR. Braqon nevertheless provides a contact point for privacy matters: [email protected].

4. Data processed

Identification and contact data (name, email address, telephone number), any company and sector of interest, the message or request submitted, and technical data (IP address, browser user-agent, page of origin, date and time) collected to handle the request and to document consent.

5. Purposes and legal bases

The data are processed for the purposes below, each with its legal basis under Art. 6 GDPR:

• a) Handling the request. To respond to the request for information, contact or a quote and provide what the data subject asked for. Legal basis: performance of pre-contractual measures taken at the data subject's request (Art. 6(1)(b)) and/or consent (Art. 6(1)(a)).
• b) Relationship management and contact. To contact the data subject by email or telephone regarding their request and manage related communications. Legal basis: consent (Art. 6(1)(a)) and the controller's legitimate interest in responding to the requests received (Art. 6(1)(f)).
• c) Commercial and marketing communications. Sending Braqon's offers, updates and promotional material by email, telephone or SMS. Legal basis: specific, optional consent (Art. 6(1)(a)), separate from the consent to handle the request and revocable at any time without affecting the other processing.
• d) Security and abuse prevention. Protecting the website and form from automated submissions, spam and misuse, through technical logs, IP address and anti-bot systems. Legal basis: the controller's legitimate interest in the security of its systems (Art. 6(1)(f)).
• e) Proof of consent and accountability. Recording consent metadata (date and time, IP address, user-agent, notice version) to demonstrate compliance. Legal basis: the obligation to demonstrate consent (Art. 7(1)) and legitimate interest in the establishment or defence of legal claims (Art. 6(1)(f)).
• f) Legal obligations. Compliance with legal obligations and responses to legitimate requests from authorities. Legal basis: compliance with a legal obligation (Art. 6(1)(c)).
• g) Establishment or defence of legal claims. Where necessary, to establish, exercise or defend a legal claim. Legal basis: the controller's legitimate interest (Art. 6(1)(f)).

Providing consent to marketing (point c) is optional: refusing or later withdrawing it does not affect the handling of the request. The processing does not involve automated decision-making or profiling producing legal effects or similarly significantly affecting the data subject within the meaning of Art. 22 GDPR.

6. Transfer of data to third countries (United States)

Braqon is established in the United States, a third country with respect to the European Economic Area (EEA). The collected data are therefore transferred to and processed in the United States by Braqon and by the providers acting on its behalf as processors (in particular the contact-management/CRM platform provider). The transfer relies on the safeguards under Chapter V GDPR, in the following order of application:

• Adequacy decision (Art. 45 GDPR). Where Braqon or the U.S. provider adhere to the EU-US Data Privacy Framework, the transfer is covered by the European Commission's adequacy decision of 10 July 2023 and requires no further safeguards.
• Standard Contractual Clauses (Art. 46(2)(c) GDPR). In the absence of an applicable adequacy decision, the transfer relies on the Standard Contractual Clauses (SCCs) adopted by the European Commission with Implementing Decision (EU) 2021/914 of 4 June 2021 (the module appropriate to the parties' relationship). Following the Court of Justice of the European Union judgment in Case C-311/18 (Schrems II) and the EDPB Recommendations 01/2020, the SCCs are complemented by an assessment of the legal framework of the destination country and by supplementary measures of a technical, organisational and contractual nature (e.g. data minimisation, encryption of data in transit and access limitation).
• Explicit consent (Art. 49(1)(a) GDPR). For occasional transfers, and in the absence of the foregoing safeguards, the transfer may rely on the data subject's explicit consent, given after being informed of the possible risks arising from the absence of an adequacy decision and appropriate safeguards.

The data subject has the right to be informed of the safeguards applied and to obtain a copy of the Standard Contractual Clauses, or an indication of where they have been made available, by request to [email protected] (Art. 13(1)(f) and 13(2)(f) GDPR).

7. Retention

The data are kept for 24 months from the last contact, unless a longer period is required by law, and are then deleted or anonymised.

8. Data subject rights

The data subject may exercise the rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent (Art. 15-22 GDPR) by writing to [email protected]. They also have the right to lodge a complaint with the competent supervisory authority in the EU/EEA Member State of their residence or where the alleged infringement occurred.

9. Nature of the provision of data

Providing the data marked as mandatory is necessary to handle the request; refusal makes it impossible to contact the data subject. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

Privacy Notice (United States)

1. Who we are

Braqon LLC, with registered office at 30 N Gould St, STE R, Sheridan, WY 82801, USA (“Braqon”, “we”), is the business responsible for the personal information collected through this website. Contact: [email protected].

2. Categories of personal information we collect

• Identifiers: name, email address, phone number.
• Commercial / inquiry information: company, sector of interest, and the message or request you submit.
• Internet or network activity: IP address, browser/user-agent, page of origin, date and time.

3. How we use it

To respond to your request and provide the requested information or quote; to contact you about your request by email and phone; and, only if you opted in, to send marketing communications.

4. Sharing your information

We share personal information with service providers acting on our behalf under contract, and as required by law. We do not sell your personal information. To opt out of any “sharing” for cross-context behavioral advertising, contact us at [email protected] (Do Not Sell or Share My Personal Information).

5. Text messaging and calls (TCPA)

If you provide consent, you may receive recurring marketing calls and/or text messages, including through automated technology. Consent is not a condition of any purchase. Message and data rates may apply; message frequency varies. Reply STOP to opt out, HELP for help. We honor opt-out requests promptly.

6. Your California privacy rights (CCPA/CPRA)

You have the right to know, access, correct, and delete your personal information, to opt out of the sale or sharing of your personal information, to limit the use of sensitive personal information, and not to be discriminated against for exercising your rights. To exercise these rights, contact [email protected].

7. Retention

We keep your personal information for 24 months from the last contact, unless a longer period is required by law, and then delete or de-identify it.