Brainio Privacy Statement<p>Effective date: <b>July 1, 2019</b>
</p>
<p>Thanks for entrusting Brainio with your private content, and your personal information.
Holding onto your private information is a serious responsibility, and we want you to know how we're handling it.</p>The short version<p>We only collect the information you choose to give us, and we process it with your consent, or on another legal basis.
we only require the minimum amount of personal information that is necessary to fulfill the purpose of your interaction with us.
we don't sell it to third parties.
and we only use it as this Privacy Statement describes.
We are compliant with the General Data Protection Regulation (GDPR).
No matter where you are, where you live, or what your citizenship is, we provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location.
Of course, the short version doesn't tell you everything, so please read on for more details!</p>SummarySectionWhat can you find there?What information Brainio collects and whyBrainio collects basic information from visitors to our website, and some personal information from our users.
We only require the minimum amount of personal information necessary from you.
This section gives details.What information Brainio does not collectWe don’t collect sensitive data.
This section gives details.How we share the information we collectWe share information to provide the service to you, to comply with your requests, or with our vendors.
We do not host advertising on Brainio and we do not sell your personal information.How you can access and control the information we collectWe provide ways for you to access, alter, or delete your profile information.
You can also contact Support for more help.Our use of cookies and trackingWe use cookies for the overall functionality of our website, and we use a small number of tracking and analytics services on a few parts of our site.How Brainio secures your informationWe take all measures reasonably necessary to protect the confidentiality, integrity, and availability of your personal information on Brainio and to protect the resilience of our servers as they host your information.Brainio's global privacy practicesBrainio complies with both the EU-US Privacy Shield Framework and the General Data Protection Regulation.
Please see this section for more specific information.How we respond to compelled disclosureWe may share your information in response to a warrant, subpoena, or other court action, or if disclosure is necessary to protect our rights or the rights of the public at large.
We strive for transparency, and will notify you when possible.How we, and others, communicate with youWe communicate with you by email.
You can control the way we contact you in your account settings.Changes to our Privacy StatementWe will notify you of material changes to this Privacy Statement 30 days in advance of any such changes becoming effective.
Contacting BrainioPlease feel free to contact us if you have questions about our Privacy Statement.What information Brainio collects and whyInformation from website browsers<p>If you're just browsing the website, we collect the same basic information that most websites collect.
We use common internet technologies, such as cookies and web server logs.
This is stuff we collect from everybody, whether they have an account or not.</p>
<p>The information we collect about all visitors to our website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request.
We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.</p>Why we collect this information<p>We collect this information to better understand how our website visitors use Brainio, and to monitor and protect the security of the website.</p>Information from users with accounts<p>If you create an account, we require some basic information at the time of account creation.
You will create your own user name and password, and we will ask you for a valid email address.
You also have the option to give us more information if you want to, and this may include "User Personal Information."</p>
<p>"User Personal Information" is any information about one of our users which could, alone or together with other information, personally identify him or her.
Information such as a user name and password, an email address, a real name, and a photograph are examples of “User Personal Information.” User Personal Information includes Personal Data as defined in the General Data Protection Regulation.</p>
<p>User Personal Information does not include aggregated, non-personally identifying information.
We may use aggregated, non-personally identifying information to operate, improve, and optimize our website and service.</p>Why we collect this information<ul>
<li>We need your User Personal Information to create your account, and to provide the services you request, including to provide the Brainio service or to respond to support requests.</li>
<li>We use your User Personal Information, specifically your user name, to identify you on Brainio.</li>
<li>We use it to fill out your profile and share that profile with other users if you ask us to.</li>
<li>We will use your email address to communicate with you, if you've said that's okay, and only for the reasons you’ve said that’s okay.</li>
<li>We use User Personal Information and other data to make recommendations for you.
For example, from your public behavior on Brainio, such as the topics you are interested in we determine your interests, and we recommend similar topics for you.
These recommendations are automated decisions, but they have no legal impact on your rights.</li>
<li>We use your User Personal Information for internal purposes, such as to maintain logs for security reasons, for training purposes, and for legal documentation.</li>
<li>We limit our use of your User Personal Information to the purposes listed in this Privacy Statement.
If we need to use your User Personal Information for other purposes, we will ask your permission first.</li>
</ul>Our legal basis for processing information<p>Under certain international laws (including GDPR), Brainio is required to notify you about the legal basis on which we process User Personal Information.
Brainio processes User Personal Information on the following legal bases:</p>
<ul>
<li>When you create a Brainio account, you provide your user name and an email address.
We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract.
We also process your user name and email address on other bases.
If you have paid account with us, there will be other data elements we must collect and process on the basis of performing that contract.
Brainio does not collect or process a credit card number, but our third-party payment processor does.</li>
<li>When you fill out the information in your user profile, you have the option to provide User Personal Information such as your full name, an avatar which may include a photograph, your biography, your location, your company, and a URL to a third party website.
We process this information on the basis of consent.
You have the ability to access, modify, and delete it at any time with some exception (for exmaple email address).</li>
<li>Generally, the remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interests.
For example, for security purposes, we must keep logs of IP addresses that access Brainio, and in order to respond to legal process.</li>
<li>If you would like to request erasure of data we process on the basis of consent or object to our processing of personal information, please contact us.</li>
</ul>What information Brainio does not collect<p>We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information.
Although Brainio does not request or intentionally collect any sensitive personal information, we realize that you might store this kind of information in your account, such as in your private content or in your public profile.
If you store any sensitive personal information on our servers, you are responsible for complying with any regulatory controls regarding that data.</p>
<p>We do not intentionally collect User Personal Information that is stored in your private content.
Information in your private content belongs to you, and you are responsible for it, as well as for making sure that your content complies with our Terms of Service.
Any personal information within a user's private content is the responsibility of the content owner.</p>Repository contents<p>Brainio employees do not access private content unless required to for security reasons, to assist the content owner with a support matter, or to maintain the integrity of the service.
Our Terms of Service provides more details.</p>
<p>If your content is public, anyone (including us and unaffiliated third parties) may view its contents.
If you have included private or sensitive information in your public content, such as email addresses or passwords, that information may be indexed by search engines or used by third parties.
In addition, while we do not generally search for content, we may scan our servers for certain tokens or security signatures, or for known active malware.</p>How we share the information we collect<p>We do share User Personal Information with your permission, so we can perform services you have requested or communicate on your behalf.
You may indicate, through your actions on Brainio, that you are willing to share your User Personal Information.</p>
<p>We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes, except where you have specifically told us to.</p>
<p>We do not host advertising on Brainio.
We may occasionally embed content from third party sites, such as YouTube, and that content may include ads.
While we try to minimize the amount of ads our embedded content contains, we can't always control what third parties show.</p>
<p>We do not disclose User Personal Information outside Brainio, except in the situations listed in this section or in the section below on Compelled Disclosure.</p>
<p>We do share certain aggregated, non-personally identifying information with others about how our users, collectively, use Brainio.
However, we do not sell this information to advertisers or marketers.</p>
<p>We do share User Personal Information with a limited number of third party vendors who process it on our behalf to provide or improve our service.
Our vendors perform services such as payment processing, customer support ticketing, network data transmission, and other similar services.</p>
<p>We do share aggregated, non-personally identifying information with third parties.
For example, we may share the number of times a particular file was accessed.</p>
<p>We may share User Personal Information if we are involved in a merger, sale, or acquisition.
If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our website or by email before any transfer of your User Personal Information.
The organization receiving any User Personal Information will have to honor any promises we have made in our Privacy Statement or in our Terms of Service.</p>Public information on Brainio<p>If your content is public-facing, third parties may access and use it in compliance with our Terms of Service, such as by viewing your profile or notes or pulling data via our API.
We do not sell that content.
it is yours.
However, we do allow third parties, to compile public-facing Brainio information.
</p>Third party applications<p>We will share your User Personal Information to third parties when you ask us to.
however, you are responsible for your use of the third party Developer Product.</p>Brainio applications<p>You also have the option of adding applications from Brainio, such as our Desktop app.
All Brainio applications are subject to this Privacy Statement, and we will always collect the minimum amount of User Personal Information necessary, and use it only for the purpose for which you have given it to us.</p>How you can access and control the information we collect<p>If you're already a Brainio user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting Brainio Support.</p>Data portability<p>As a Brainio User, you can always take your data with you.
You can download all of the private content you have stored with us.</p>Data retention and deletion of data<p>Generally, Brainio will retain User Personal Information for as long as your account is active or as needed to provide you services.</p>
<p>We may retain certain User Personal Information indefinitely, unless you delete it or request its deletion.
For example, we don’t automatically delete inactive user accounts, so unless you choose to delete your account, we will retain your account information indefinitely.</p>
<p>If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile.
We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 90 days.
You may contact Brainio Support to request the erasure of the data we process on the basis of consent within 30 days.</p>
<p>After an account has been deleted, certain data, such as contributions to others' notes and comments, will remain.
However, we will delete or deidentify your personal information, including your user name and email address.</p>Our use of cookies and trackingCookies<p>Brainio uses cookies to make interactions with our service easy and meaningful.
We use cookies (and similar technologies, like HTML5 localStorage) to keep you logged in, remember your preferences, and provide information for future development of Brainio.
We also use cookies to identify a device, for security reasons.
By using our website, you agree that we can place these types of cookies on your computer or device.
If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use Brainio’s services.</p>Tracking and analytics<p>We use a number of third party analytics and service providers to help us evaluate our users' use of Brainio.
compile statistical reports on activity.
and improve our content and website performance.
We only use these third party analytics providers on certain areas of our website.
We do not track your online browsing activity on other online services over time.</p>How Brainio secures your information<p>Brainio takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction.
maintain data accuracy.
and help ensure the appropriate use of User Personal Information.</p>
<p>In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.</p>
<p>Transmission of data on Brainio is encrypted using SSH, HTTPS, and SSL/TLS, while our data is not encrypted at rest.
When data is stored with a third party storage provider, it is encrypted.</p>Brainio's global privacy practices<p>We understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs.</p>
<p>We provide the same standard of privacy protection — as described in this Privacy Statement — to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide.
If our vendors or affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.</p>
<p>In particular:</p>
<ul>
<li>Brainio provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data using consent as a basis.</li>
<li>We collect only the minimum amount of personal data necessary for our purposes, unless you choose to provide more.
We encourage you to only give us the amount of data you are comfortable sharing.</li>
<li>We offer you simple methods of accessing, correcting, or deleting the User Personal Information we have collected.</li>
<li>We provide our users notice, choice, accountability, security, and access, and we limit the purpose for processing.
We also provide our users a method of recourse and enforcement.
These are the Privacy Shield Principles, but they are also just good practices.</li>
</ul>How we respond to compelled disclosure<p>Brainio may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.</p>
<p>In complying with court orders and similar legal processes, Brainio strives for transparency.
When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.</p>How we, and others, communicate with you<p>We will use your email address to communicate with you.
For example, if you contact our Support team with a request, we will respond to you via email.
You have a lot of control over how your email address is used and shared on and through Brainio.</p>
<p>Depending on your email settings, Brainio may occasionally send notification emails about comments, new features, requests for feedback, important policy changes, or offer customer support.
We also send marketing emails, but only with your consent, if you opt in to our list.
There's an unsubscribe link located at the bottom of each of the marketing emails we send you.
Please note that you can not opt out of receiving important communications from us, such as mails from our Support team or system emails.</p>Resolving complaints<p>If you have concerns about the way Brainio is handling your User Personal Information, please let us know immediately.
We want to help.
You may contact us via email with the subject line "Privacy Concerns." We will respond promptly.</p>Changes to our Privacy Statement<p>Although most changes are likely to be minor, Brainio may change our Privacy Statement from time to time.
We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your Brainio account.</p>Contacting Brainio<p>Questions regarding Brainio's Privacy Statement or information practices should be directed to us via email.</p>