Last Revised: November 9 2016
BrainMarc Ltd. (“BrainMarc“, “Company” “we” or “us“) respects the privacy of the visitors and/or users of its Site (available at www.BrainMarc.com) and App (“User” or “you”), and is committed to protect the personal information that its Users share with it. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or App.
1. Your Consent (PLEASE READ CAREFULLY!)
2. Which information we may collect on our Users?
We may collect two types of data and information from our Users:
a. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the Site and/or App and/or installs the App. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site and/or App, type of operating system, type of the User’s mobile device and its operating system and version, User’s ‘click-stream’ on the Site and/or App, type of browser and keyboard language, the hardware specifications of such device (including screen resolution), time spent on various screens of the App, User demographics and biomechanical data, traffic patterns, etc.
b. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.
· Users of the Site and/or App may automatically provide their IP address (or Mac Address, as applicable) and/or advertiser identifier (when available on a device) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below. We note that BrainMarc may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.
· In addition, Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User. The Personal Information is collected from the details the User provides when opening an Account and signs up to the Service via his/her existing third party Google account, which uses a single sign-on mechanism (“Google Account”). Upon registration to the Service through his/her existing Google Account, Google provides us with access to certain information about such User as is stored in the Google Account, namely, any information which is detailed and displayed to the User in the notice which appears during the integration process with the Google Account [(for example, the User’s name, email address and other information the User make publicly available via the applicable third party platform). Please read carefully such notice in order to understand what information is available to BrainMarc via the Goggle Account. We may collect your login information and other relevant information necessary to enable us to access your Google Account (such as, User access token) in order to collect and/or store, to the extent legally permissible the abovementioned data contained within your Google Account which you provided us access to. BrainMarc may store the above-mentioned information (or any part of it), in order to achieve the purposes set forth herein. Please remember that the manner in which the Google Account uses, stores and discloses your information is governed solely by its policies and BrainMarc shall have no liability or responsibility for the privacy practices or other actions of Google that may be available within our App and/or Site. You hereby agree that such information will be stored even after the linkage to your Google Account expires, for any reason.
· We collect data that is transmitted from the Device to our servers via the App (e.g., electrical activity signals). We also collect information regarding your mental state while you are using the APP, in several ways. This information may include questions about stress and concentration levels, as well as detailed information regarding specific disease or disorder events and interventions methods you may have used. We make no use of any of such Personal Information other than storing it in connection with the provision of the Services and the purposes set forth below. We may, however, anonymize Personal Information we collect and use it for the purposes stated below with respect to Non-Personal-Information and share such anonymous information with third parties in an aggregated manner which will not enable such third parties to deduct any Personal Information about a particular User.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
3. How Do We Collect Information on Our Users?
There are two main methods we use:
a. We collect information through your entry, connection, installation, access and/or use of the App, Device and/or Site. In other words, when you are using the Service we are aware of it and may gather, collect and store the information relating to such usage.
b. We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account by registering through your Google Account. When registering through your Social Network Account, you agree to grant us access to Personal Information stored in your Social Network Account, as detailed above. We also collect information that is transmitted from the Device to our servers via the App and information regarding your mental state in several forms and questions that are presented while using the App.
We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.
4. What are the Purposes of the Collection of Information?
We collect Non-personal Information and Personal Information in order to provide the Site and/or Service.
Non-personal Information is collected in order to:
- Use it for statistical and research purposes and for customization and improvement of our Service.
- Provide and improve the Service for our commercial purposes.
- Improve the quality of the Service by formulating, customizing and enhancing the User’s experience.
Personal Information is collected in order to:
- Provide and improve the Service.
- Improve the quality of the Service by formulating, customizing and enhancing the User’s experience.
- Allow us to contact Users with proposals and tailored information regarding new products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc.
- Send push notifications to the User’s device after the User has agreed to accept push notifications from BrainMarc. Users can deactivate push notification by changing their settings within our Service.
- Verify the User’s identity when he/she signs in to the Service, as well as verifying User’s identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our Service.
- Be able to contact Users for the purpose of providing them with technical assistance and support.
- Determine general geo-location information (i.e., country) from which the User’s computer is connected to the Internet in order for us to know the general location of our Site’s and Service’s Users as well as in order to safeguard our Site and/or Service.
5. Sharing Information with Third Parties
For avoidance of doubt, BrainMarc has the unrestricted right to use Non-personal Information for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion.
6. Deletion or Modification of Personal Information
If for any reason you wish to delete your Account and/or change your e-mail address please send us an e-mail with adequate detail of your request to: firstname.lastname@example.org, and we will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws. Note that unless you instruct us otherwise we may retain and use your Personal Information after termination of your Account, for as long as reasonably required for the purposes of which such Personal Information was collected, including without limitation, for future analytics and analysis, in order to comply with our legal or business requirements or obligations, to resolve disputes, to enforce our Terms and/or to enable the User to reinstate his/her Account, all as permitted under any applicable privacy laws.
Aggregate and/or anonymous information derived from your Account and/or use of the Service may remain on BrainMarc servers indefinitely.
The site and/or App are intended for Users over the age of eighteen (18). Therefore, BrainMarc does not intend and does not knowingly collect Personal Information from minors under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. Please contact BrainMarc at email@example.com if you have reasons to suspect that BrainMarc collected Personal Information from minors under the age of eighteen (18) and we will delete that information as quickly as possible.
We take reasonable measures to maintain the security and integrity of our Site and/or App and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
9. Third Party Service Providers
10. International Data Transfer
We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.
11. Links to Third Party Websites
12. Cookies and Other Tracking Technologies
All the information contained in such advertisements and commercials belongs solely to the advertisers and the Company makes no warranties or representations in respect of such, whether or not the Company has control over such advertisements or commercials and these are provided on an “AS IS” basis. In any event, the Company will not be liable for any damage or loss incurred to you as a result of or in connection with such advertisements or commercials. The Company, advertisers and/or related third-parties may be entitled to certain shares of the earnings for such advertisements and/or commercials. You agree, acknowledge and consent that no right, title or interest is or shall be granted to you in any way with respect to any revenue share whatsoever in relation thereto.
14. Direct Marketing
You hereby agree that we may use your contact details for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you other materials to the e-mail address provided by your Google Account in the registration process. You may withdraw your consent via sending a written notice to BrainMarc by e-mail to the following e-mail address: firstname.lastname@example.org or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.
16. Got any Questions?