Updated: July 1st, 2017
- “Personal Information” means information that allows someone to identify or contact you, including for example your name, address, telephone number, and email address.
Information That We Collect About You
Information About You That We Collect From You
- When you register for our newsletter, we ask you for and collect your name and email address.
- When you register for one of our Apps, we ask you for and collect your name, e-mail address, and password for your Account.
- If you choose to register for one of our Apps with Facebook, we will collect your name and email address from Facebook, and any other information provided or disclosed to you during the Facebook registration process.
- Specific Apps may ask you for and collect additional information, such as your date of birth, your insurance policy number, or your driver's license number.
- If you choose to add information to your user profile, we will collect that information, such as your date of birth or your geographical location.
- If you choose to use our “invite a friend” service, we will ask you for your friend's name and email address. We may offer you the option of logging into and using a third party service, such as Facebook, to provide your friends’ names and email addresses. We will automatically send your friend a one-time email inviting him or her to visit or use our Apps. We store the information about your friend for the purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.
- If you choose to participate in a survey, we may ask for and collect other requested information, such as your opinion of BrainHQ or your phone number.
- If you choose to contact us by sending us an e-mail, fax, or letter, we collect your e-mail address, fax number, or mailing address, and any information contained in the e-mail, fax, or letter you send us.
- When you pay for one of our Apps, we collect your complete credit card or other payment method information.
Information About You That We Collect From Organizations That Provide You With Our Apps
We work with certain organizations that provide our Apps to their members as part of the service they offer to their members. In some cases, you can register for one of our Apps with that organization, and that organization will, as a result of your action, pass Personal Information about you to us so that we can register you for one of our Apps. The information passed to us will be disclosed to you by that organization when you register for one of our Apps through that organization.
Information About You That Is Created When You Use Our Apps
- When you use our Apps, we record certain information automatically, for example your Internet protocol (“IP”) address, browser type and plugins, operating systems, screen size and resolution, the time and date at which you access our Apps, and an estimate of your geographical location.
- When you use our Apps, we record actions you have taken in our Apps, for example what buttons you click; events that occur, for example when you start a training exercise; and your usage, progress, and performance data.
How We Get and Store Information About You
- Our emails to you use email beacons or tracking pixels. Email beacons and tracking pixels are small electronic images that tell us if an email has been opened and acted upon.
- Our Apps on mobile phones and tablets store information about you on your mobile phone or tablet.
- Our Apps store information about you on computer servers and databases managed by us and hosted by several third party companies.
How We Use Information About You
- We use your Personal Information to provide our service to you, to personalize your experience with our Apps, to improve our Apps, and to secure your Account.
- We may use your Personal Information to send you transactional emails (such as a password reset), informational emails (such as a newsletter), and promotional emails (such as a special offer).
- We may create Anonymous Information from your Personal Information, for example by making a copy of your Training Data that is not linked to your Personal Information. We reserve the right to use and disclose Anonymous Information at our discretion.
- We may use Anonymous Information to conduct scientific studies, and we may publish the results, for example at scientific conferences or in research journals. We do not use Personal Information in such work, nor do we disclose Personal Information in the conduct of such work.
How We Disclose Information About You
We Disclose Information About You To Organizations That Provide You With Our Apps
- We work with certain organizations ("Groups"), such as hospitals, sports teams, retirement communities, and scientific organizations who provide our Apps to and directly supervise the use of our Apps by their members, such as patients, team members, residents, and research study participants. If your access to our Apps has been provided by a Group, or if at your request we added you to a Group, then your personal information may be shared with that Group so that they can offer their services to you. The privacy policies of these Groups may apply to the use and disclosure of your Personal Information that we collect and disclose to such Groups. Because we do not control the privacy practices of Groups, you should read and understand their privacy policies. You can contact us at email@example.com to identify any Groups that you are a member of, and who, as a result, has access to your Personal Information. At your request, we will remove you from any Group that you are a member of; however this may mean that you will no longer have access to our Apps as a result of your membership in the Group and that if you wish to continue to have access to our Apps you will need to purchase a personal subscription.
- We work with certain organizations ("Incentive Partners"), such as insurance companies, who provide our Apps to their members and provide an incentive, such as an insurance discount, to their members who complete specific goals within our Apps, for example a target amount of brain training. If your access to BrainHQ has been provided by an Incentive Partner, or if at your request we added you to an Incentive Partner, then we may share the specific Personal Information with the Incentive Partner required to offer the incentive to you, such as your name, your insurance policy number, and the date on which you have completed the target amount of brain training to offer you an insurance discount. We will not share Personal Information with the Incentive Partner that is not required to offer the incentive to you; and specifically we will not share your performance on the brain training program with your Incentive Partner. The privacy policies of these Incentive Partners may apply to the use and disclosure of your Personal Information that we collect and disclose to such Incentive Partners. Because we do not control the privacy practices of Incentive Partners, you should read and understand their privacy policies. You can contact us at firstname.lastname@example.org to identify any Incentive Partners that you are a member of, and who as a result has access to your Personal Information. At your request, we will remove you from any Incentive Partners that you are a member of; however this may mean that you will no longer have access to our Apps or be eligible for certain incentives as a result of your membership in the Incentive Partners and that if you wish to continue to have access to our Apps you will need to purchase a personal subscription.
- We work with certain organizations ("Distribution Partners"), such as libraries and cell phone providers who provide our Apps to their members, such as library patrons or cell phone subscribers. We also work with Distribution Partners that recommend our Apps to their members but do not provide our Apps to their members. We do not disclose Personal Information to Distribution Partners. We may disclose aggregated Anonymous Information to such organizations, such as the number of people from a Distribution Partner who have registered for our Apps.
Situations Where We Disclose Personal Information About You With Specific Protections For You To Ensure Our Apps Work And You Can Use Them
- We may provide your Personal Information to third party service providers who work on behalf of or with us to provide functionality to our Apps, such as email services and web analytics services. These service providers are obligated to use your Personal Information only to provide services to us and not to disclose your Personal Information (except pursuant to a legal requirement such as a subpoena or warrant).
- If you choose to use features of our Apps with other users of our Apps, for example by "friending" another user, we will share your Personal Information with other users as described by that feature.
- If you use our Apps in a language that is not English, we may work with certain organizations ("Localization Partners") to provide technical support to you in that language. We may share your Personal Information with the Localization Partner so that they can provide technical support to you. These Localization Partners are obligated to use your Personal Information only to provide technical support to you and not to disclose your Personal Information (except pursuant to a legal requirement such as a subpoena or warrant). You can contact us at email@example.com to identify any Localization Partners that provide support to you, and who as a result has access to your Personal Information. At your request, we will change the language in which you use our Apps to remove you from any Localization Partners; however this may mean that you will no longer have access to our Apps in your preferred language.
Changes In Our Organization That May Require Us To Disclose Your Personal Information
Situations Where We Are Required To Disclose Your Personal Information
Your Choices Regarding Your Personal Information
We offer you choices regarding the collection, use, and sharing of your Personal Information.
- You may change the information you submitted for your Account either in the Apps or by contacting us at firstname.lastname@example.org. You may request deletion of your Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request, only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database, but may remain in our archives. When we delete your Personal Information, we will retain your Training Data as Anonymous Information that is no longer linked to your deleted Personal Information
- We acknowledge the right of all individuals to access the personal data we hold about them.
Our accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at email@example.com.
We have further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles or the Swiss-U.S. Privacy Shield Principles to the Better Business Bureau. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visitwww.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
As further explained in the Privacy Shield Principles, a binding arbitration option before the Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Our Apps are not directed to individuals under 13 and we do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information immediately.
Do Not Track Compliance
We do track your use of the Apps over time because such tracking is required for us to track your progress through the brain training exercises and provide you with brain exercises that are tailored to you. Therefore our Apps do not respond to Do Not Track (“DNT”) signals. We do not track the users of our Apps across third party websites to provide targeted advertising directly to those websites. We do use advertising networks to present ads on third party sites, and those advertising networks and those third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. (For more information, see the section entitled “How We Get and Store Information About You”, above.) If you are visiting such advertising networks or third party sites, your browser allows you to set the DNT signal so those groups (particularly advertisers) know you do not want to be tracked. You can find out more about your browser’s tracking capabilities and procedures for asking not to be tracked by contacting the developer or distributer of your particular browser.
Third Party Websites, Products, Services, Content, and Links.
We make reasonable efforts to protect your Personal Information, but no company, including Posit Science, can fully eliminate security risks connected to handling information on the internet.
YOU ACKNOWLEDGE THAT SECURITY SAFEGUARDS, BY THEIR NATURE, ARE CAPABLE OF CIRCUMVENTION AND POSIT SCIENCE DOES NOT AND CANNOT GUARANTEE THAT YOUR PERSONAL INFORMATION WILL NOT BE ACCESSED BY UNAUTHORIZED PERSONS CAPABLE OF OVERCOMING SUCH SAFEGUARDS. IN PARTICULAR, OUR APPS MAY BE USED TO ACCESS AND TRANSFER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, OVER THE INTERNET. YOU ACKNOWLEDGE AND AGREE THAT POSIT SCIENCE DOES NOT OPERATE OR CONTROL THE INTERNET AND THAT UNAUTHORIZED USERS (SUCH AS HACKERS) MAY USE VIRUSES, WORMS, TROJAN HORSES, AND OTHER UNDESIRABLE DATA AND SOFTWARE TO OBTAIN ACCESS TO OR DAMAGE OUR SITES, APPS, OR YOUR PERSONAL INFORMATION.
Furthermore, we cannot be responsible for any of your Personal Information that you release on your own, or that you request or authorize us to release.
Protected Health Information
Our Contact Information.