Privacy & Security Statement

This statement was last updated on April 30, 2021.

BrainWare Learning Company (BLC) is committed to maintaining the confidentiality, integrity and security of any personal information we receive from you.  This Privacy & Security Statement explains how we use the personal information provided through our sites in connection with the services we provide.

Definitions

“BLC” means BrainWare Learning Company, PO Box 409037, Chicago, IL  60640.

“BrainWare Analytics” means research and analytical activities performed by BLC on user data.  These activities may include improving our services and/or offering new products and services and performing quality control activities.  In addition, we may use aggregated data, without revealing any individual level information, in analyses performed with the intent to publish educational or scientific articles.

“Services” mean BLC’s products, software, services, and website as accessed from time to time by the user.

Data Collected

BLC collects and stores the following types of Personal Information:

• “Registration Information” is the information you provide about yourself when registering for and/or purchasing our Services (e.g., name, address, email, address, phone number, company/organization and title and payment information).
• “Usage Information” is the information generated through the use of our programs by you and/or your students or children.
• “Self-Reported Information” is all information we receive from you about you, your students or children in the course of providing the Services. Self-Reported Information is included in BrainWare Analytics.

• “Site Behavior Information” is information on how you use our website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.

Cookies

BLC may use cookies to remember user inputs during a user session.  For example, a “shopping cart” application records purchases up until the user reaches checkout.  Personalization features also use cookies to identify groups of users and deliver appropriate content and services.  You can set your browser not to accept cookies or to notify you when you receive cookies.  You can also clear cookies from your browser later.  If you decline to accept cookies, some of our website features may not function.

How we use your Personal Information:

• BLC collects Personal Information from you for all purposes necessary to ensure the regular operation of your account and/or availability of our Services. These include, among other things, providing you with our Services; improving our Services and/or offering new products or services to you; informing you about events; contacting you to obtain testimonials or for other promotional purposes; performing quality control activities; and conducting BrainWare Analytics.
• We use Registration Information to enable your purchase, inform you when your account and reports generated within your account are available, provide you with customer service, manage our Services, and authenticate your website visits and usage.
• We may disclose to third parties, and/or use in our Services, Aggregated Usage and Self-Reported Information, which is Usage and Self-Reported Information that has been stripped of Registration Information and combined with data from a number of other users sufficient to minimize the possibility of exposing individual-level information while still providing scientific evidence. Your individual-level Usage and/or Self-Reported Information will not be shared or otherwise accessed by any third parties for commercial use.
• We will never release your individual-level Usage and/or Self-Reported Information to a third party unless required by law.
• We use Site Behavior Information to track and monitor aggregate usage of our website, for quality control, to improve our Services, and/or to target advertising for our products and services

Information Disclosure

We will not disclose your individual-level Personal Information to any third party, except under the following circumstances:

• to analyze site usage and improve the Services;
• to deliver to you any administrative notices, alerts and communications relevant to your use of the Services;
• to fulfill your requests for certain products and services;
• for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
• to third-party contractors that provide services to BLC and are bound by these same privacy restrictions;
• to enforce BLC’s Terms of Use or as otherwise set forth in this Privacy & Security Statement; and
• as we are required to do so by law or we do so in coordination with regulatory authorities (see the section below titled “Information Disclosure Required By Law”).

Your Choices

• Contribution of Personal Information other than Registration Information is voluntary and permission-based.
• Providing Self-Reported Information through surveys, forms, or features is voluntary.
• At your written request we will close your account. As a result, all Usage Information will be removed from the account and will no longer be accessible. BLC will not use your Usage Information in new research that starts thirty (30) days or more after account closure. We cannot remove Usage Information that has previously been used for published research or shared with external collaborators before account closure. (See the section below titled “Account Closure and Correction of Personal Information”.)
• You may request copies of your personal data.  We may charge you a small fee for this service.
• You have the right to request that we correct any information you believe is inaccurate and to complete information you believe is incomplete.

How to Contact Us

Questions about this Security & Privacy Statement, or about BLC’s handling of your Personal Information may be sent to BrainWare@mybrainware.com or sent to:

Privacy & Security Administrator
BrainWare Learning Company
PO Box 409037
Chicago, IL  60640

Information Disclosure Required by Law

Under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. You acknowledge and agree that BLC is free to preserve and disclose any and all Personal Information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that BLC may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the BrainWare Terms of Service; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of BLC, its employees, its users, its clients, and the public. In the event we are required by law to make a disclosure, we will notify you through the contact information you have provided to us in advance, unless doing so would violate the law or a court order.

Account Closure

If you no longer wish to participate in our Services, you may close your account by sending a request to BrainWare@mybrainware.com.  When you request us to delete your account for the Service, any personally identifiable data will be permanently expunged from our primary production servers and further access to your account will not be possible. We retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes. However, portions of your data, consisting of aggregate data derived from your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. BLC keeps these backups to ensure our continued ability to provide the Service to you in the event of malfunction or damage to our primary production servers. We also reserve the right to use any aggregated or anonymous data derived from or incorporating your Personal Information.

If your Personal Information changes, you may correct or update your Registration Information by contacting us at BrainWare@mybrainware.com.

Newsletter and Email Communications

We provide our clients with periodic updates and email alerts. We also allow users to subscribe to email newsletters and webinar invitations and from time to time may transmit emails promoting BLC or third-party goods or services. Subscribers have the ability to opt-out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

Security

BLC takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, BLC uses a range of reasonable physical, technical, and administrative measures to safeguard your Personal Information, in accordance with current technological and industry standards. In particular, all connections to and from our website are encrypted from the time you submit your Login ID and Password. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.

We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect client accounts and systems from unauthorized access.

When you register for the Service, BLC requires a password from you for your privacy and security.

Our servers are in a secure facility. Access requires multiple levels of authentication, including biometrics recognition procedures. Security personnel monitor the system 7 days a week, 24 hours a day.

Our databases are protected from general employee access both physically and logically. All backup drives and tapes also are encrypted.

Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify BLC of any unauthorized use of your password. BLC cannot secure Personal Information that you release on your own or that you request us to release.

However, it is important to understand that these precautions apply only to our Site and systems. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites.

Children

BLC does not knowingly collect personal data directly from children under the age of 13.  If you are under 13, please do not give us any personal data.  If you have reason to believe that a child under 13 has provided personal data to BLC, please contact us, and we will try to delete that information from our databases.

We do collect and store personal data regarding children under the age of 13 when that data is provided by a parent, a clinician or a school in order for them to have access to our programs and for services to be provided to such children. The data is only used for that purpose.

Links to Other Sites

This Privacy and Security Statement applies only to BLC’s websites.  BLC’s websites may contain hyperlinks to websites that are not operated by BLC.  These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators.  BLC does not control these websites and is not responsible for their data practices.  We urge you to review the privacy policy posted on any website you visit before using the site or providing any personal data about yourself.

Business Transitions

In the event that BLC goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy & Security Statement.

Contact Information

If you have a security or privacy related concern or questions about this Statement, please email us at BrainWare@MyBrainWare.com. We will work closely with you to ensure a rapid and personal response to your concerns. You can also contact us at this address if you have a question about our handling of your information:

Privacy & Security Administrator
BrainWare Learning Company
PO Box 409037
Chicago, IL  60640

This Privacy & Security Statement was last updated April 30, 2021. Whenever this Privacy & Security Statement is changed in a material way, a notice will be posted as part of this Statement.  In addition, all customers will receive an email with notification of the changes.