Effective Date 8/1/2020
WHAT TYPES OF INFORMATION DOES FOURTHBRAIN COLLECT?
Personal Information means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. It does not include data where the identifier has been removed. We may collect, process, store and transfer different types of information about users. Certain types of data that we collect constitute Personal Information only when combined with personal identifiers.
Identity & Demographic Data: This includes information that we use to identify or communicate with you as a user of the Services. This may include first & last name, gender, date of birth, user credentials and passwords and other similar data. Under certain circumstances, we may request and collect sensitive Personal Information like social security number and demographic information like gender, age and ethnicity where required for certain aspects of the Services.
Contact Information: This includes mailing or billing addresses, email address, telephone number and mobile phone number and social media handles or screen names.
Technical Usage Data: Includes information specifying the internet protocol (IP) address used to access the Services, data about your computer, web-browser, operating system, physical location, and other technical data about the devices you use to access the Services.
Payment Data: We use third-party payment processors for most financial transactions, however we may collect payment information for processing of payments under specific circumstances.
Performance Data: Academic performance and progress-tracking data collected to assess your performance in FourthBrain’s educational programs.
Marketing and Communications Data: Includes information about your interests, preferences, website browsing history, demographic information such as age, gender, education level, feedback and survey responses and your marketing and communications preferences.
HOW DOES FOURTHBRAIN COLLECT PERSONAL INFORMATION?
We directly collect Personal Information from you when you:
Contact us directly to request information about the Services;
Create an account on the Website or register to use the Services;
Apply to attend educational programs or any other Services on the Website or third-party websites;
Register for events or workshops offered by us or any third-party organizations that we partner with.
Provide information in response to surveys, promotional messaging and event solicitations;
Submit inquiries regarding the Services, speaking or communicating with our admissions or enrollment team members, or requesting access information from us, including newsletters or other marketing materials;
Engage with us on various social media channels such as Reddit, LinkedIn, Facebook and Twitter.
FOR WHAT PURPOSES DOES FOURTHBRAIN USE MY PERSONAL INFORMATION?
We have listed below the different ways that we may use your Personal Information, along with the lawful basis for processing and the legitimate business interests that require processing. We will only use your Personal Information for the purposes for which we collected it. In some instances, we may have several lawful purposes for processing your Personal Information. Feel free to contact us at firstname.lastname@example.org if you would like additional information about our processing of your Personal Information.
|In order for FourthBrain to do the following||We may process the following types of Data||This is the lawful basis for our processing of that Data|
|Provide you with access to the Websites; creating and maintaining an online account for you to register and use the Services.||Demographic Data, Identity Data||Data processing is necessary for us to enter into a contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interest in providing you with the Services.|
|To deliver the Services to you.||Demographic Data, Identity Data, Performance Data||Data processing is necessary for us to perform under the terms of a contract with you, for us to comply with our legal and regulatory obligations, and our legitimate interest in delivering the Services.|
|To facilitate, collect and process your payments, fees and charges for the Services.||Identity & Demographic Data, Contact Information, Payment Data||Data processing is necessary for us to enter into or perform under the terms of a contract with you; for us to comply with our legal and regulatory obligations, and for our legitimate interest in providing you with the Services.|
|To improve the Services and to provide high-levels of customer service.||Contact Information, Technical & Usage Data, Anonymized Data||Data processing is necessary for the performance of our contract with you and for our legitimate business interests in: assuring proper technical functionality, high-levels of customer service and usability to meet the needs and demands of our customers.|
|To recommend additional Services to you and provide updates to existing Services||Contact Information, Identity & Demographic Data, Marketing & Communications Data, Technical & Usage Data, Anonymized Data, Performance Data||Data processing is necessary for us to perform under the terms of our contract with you and for our legitimate interest in delivering high levels of customer service.|
|Properly administer and protect the Services through data integrity testing, system analysis and troubleshooting.||Contact Information, Identity & Demographic Data, Marketing & Communications Data, Technical Usage Data||Data processing is necessary for the performance of our contract with you; for us to comply with our legal and regulatory obligations, and in support of our legitimate interests in providing network security in connection with the Services, improved functionality and customer service.|
|To service you as a customer, including responding to inquiries, providing relevant information about the Services, promotions or other opportunities that you request or agree to receive, through electronic means or other marketing channels.||Contact Information, Identity & Demographic Data, Marketing & Communications Data, Technical & Usage Data, Anonymized Data, Performance Data||Data processing is necessary for us to enter into a contract with you and for the continued provision of the Services, and our legitimate business interests in offering better Services to you and in continuing to cultivate our customer relationships.|
HOW DOES FOURTHBRAIN SHARE YOUR INFORMATION?
We do not share user information, including Personal Information, with third-parties except in the following situations.
Government, Regulatory and Law Enforcement: FourthBrain may share your Personal Information to comply with any court order, law or legal process, including to respond to any law enforcement or requests from regulators. Additionally, we may share your Personal Information as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FourthBrain, our customers or others.
Sharing on Social Media & Messaging: By using the Services, you may choose to share Personal Information on message boards, chat-applications, profile pages, blogs and other similar services including, without limitation, our Social Media. Please note that any information you post or disclose through these services may become public and may be available to other users and/or the general public. The use or processing of the Personal Information by such services will be governed by their privacy policies.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information, including Personal Information, may transfer as part of such a transaction as one of the transferred assets as permitted by law and/or contract.
HOW CAN I CHANGE MY MARKETING PREFERENCES?
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message or by contacting us by email at email@example.com. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing- related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
HOW DOES FOURTHBRAIN PROTECT YOUR INFORMATION?
We have implemented appropriate physical, technical and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Payment transactions are conducted through our PCI compliant secure payment solutions providers. We cannot and do not guarantee the security of any information transmitted over the Internet. Once we receive your Personal Information, we take steps that we believe are commercially reasonable to limit access to your Personal Information to only those employees and service providers whom we determine need access to the Personal Information to provide the requested products, services, offers or opportunities that may be of interest to you. However, even after we receive your Personal Information, we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed as a result of a breach of our commercially reasonable efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your Personal Information is completely secure and safe from such risks. Where you’ve created a password to access the Services, you are responsible for keeping this password confidential. Please do not share your password with anyone. Any transmission of Personal Information is at your own risk. If you have reason to believe that any interaction you have with us is no longer secure, please immediately inform us by emailing us at firstname.lastname@example.org.
HOW LONG DOES FOURTHBRAIN RETAIN PERSONAL INFORMATION?
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
The circumstances under which we enter into an ongoing relationship with you and provide the Services to you;
The length of time we have an ongoing relationship with you and provide you with the Services;
The potential risk of harm from unauthorized use or disclosure of your Personal Information;
Whether there is a jurisdictional legal obligation to which we are subject (for example, certain laws require us to retain enrollment records for a certain period of time); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Additional information about data retention policies is available on request by emailing us at email@example.com
NOTICE TO EU CITIZENS
Users located in the EU have certain rights under the GDPR. These rights include the right under certain circumstances to receive, correct, restrict or object to the processing of your Personal Information, including the right to object to marketing. Where the basis of the processing of your Personal Information is based on consent you have the right to withdraw that consent at any time. You may also request that we delete your Personal Information; however, we may only do so if permitted by applicable law.
NOTICE TO CALIFORNIA AND NEVADA RESIDENTS
We do not rent, sell or share Personal Information about you with third parties who are not our partners or affiliates for their own direct marketing purposes unless you have opted-in to such a disclosure or were offered the opportunity to opt-out of such a disclosure at the time you provided your Personal Information and elected not to opt-out. California or Nevada residents may, at any time, request disclosure or erasure of the categories and specific pieces of their personal information we have collected, as well as opt out of the selling of their information to third parties, by contacting us at [US tel] or email to firstname.lastname@example.org. We will do our best to process your request expeditiously, but we may require up to forty-five (45) days. Additionally, we may need to request specific information from you to confirm your identity and location before processing your request.
Our Services are not intended for children under sixteen (16) years of age. If you are under the age of sixteen, please do not use the Services or provide to us any Personal Information via a Website or App, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under sixteen without verification of parental consent, we will delete that information.
UPDATES TO YOUR INFORMATION
We want to ensure that the Personal Information we hold about you is accurate and up to date. We ask that you keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information that you have provided to us through your use of the Services. If you require assistance or have questions about unsubscribing from email or other communications, please email us at email@example.com.
CHANGES TO THIS POLICY
FourthBrain, 195 Page Mill Road, Suite 115, Palo Alto, CA 94306.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Effective Date 8/1/2020
WHAT ARE COOKIES?
Cookies are tiny files that are downloaded to your computer, to improve your experience while browsing the internet or using web-based services. This Policy describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the Services functionality.
THE COOKIES WE USE (FIRST PARTY COOKIES)
Email newsletters related cookies: The Website offers email subscription services. Certain cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
Forms related cookies: When you submit data to us through a form such as those found on contact pages or feedback forms, cookies may be set to remember your user details for future correspondence.
Site preferences cookies: In order to provide you with the best experience using the Services, and in order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
THIRD PARTY COOKIES
Our Services use third-party analytics, including Google Analytics, which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the Services and ways that we can improve your experience. These cookies may anonymously track things like how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
Google and other third-parties may serve ads across other websites that you visit based upon your past visits to our Website and may also serve our advertisements on other websites. Site visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ad Settings found at https://www.google.com/settings/u/0/ads. You can also opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on found at https://tools.google.com/dlpage/gaoptout/.
We permit the use of marketing cookies designed to ensure that we provide you with the most relevant content possible by anonymously tracking your interests and presenting content that aligns with your interests.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the social media sites will set cookies on our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Most devices and web browsers automatically accept cookies. In most cases, you are able to configure your browser to notify you each time a cookie is set or to block, delete or disable. We’ve provided instructions below allowing you to review or disable cookies on the most popular web browsers: