Are they still collecting BAT tokens on the internets behalf, without permission, in their opt-out scheme (without even telling them they received anything until they hit a certain threshold and subsequently "recycling" it back into their own funds if it's unclaimed) ?
When they rolled out their donation feature, they were using a UI dark pattern which lead users to believe site owners were registered on the platform, not unlike Facebook shadow accounts, and were accepting donations for users on their behalf. AND they had a policy that only notified said non-users after their accumulated donations they didn't know they had broke a certain threshold. $200 iirc. Here's a thread[1] detailing the issue and you'll see Brave team members trying to explain those shadow accounts away as a "UI bug".