If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through braintrain.com. You may provide us information in user content you post to braintrain.com.
We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize and improve our services, in some cases to allow you to set up a user account and profile, to contact you and to allow other users to contact you, to fulfill your requests for certain products and services, to provide and improve our Services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
We are not responsible for the practices of sites linked to from the Services, and you are advised to review their rules and policies before interacting with any of these sites or providing them with any private information.
Information We Collect About You and How We Collect It
We collect several types of information from and about users, including Personal Information that is about you but individually does not identify you, such as, time and date of visits to our Website, etc.; and/or, about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
Information You Provide to Us. The information we collect on or through our Website may include:
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that any User Content you provide will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information on how to opt-out of advertiser tracking mechanisms, please visit www.networkadvertising.org/managing/opt_out.asp.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to:
The technologies we use for this automatic data collection may include cookies, flash cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.
PHI Data and Software Applications
All test data is stored locally and BrainTrain has no access to the database records. The testing database is encrypted and password protected by default, so that only local application access to the data is possible. The customer can elect to change the default database password to a unique password of their own choosing and then even local application level access will require the password each time. Additionally, the test software enables users to set up separate user accounts (1 administrator and up to 3 limited users) that monitors all use, logs user actions, and has built-in tampering controls. The test system can also be enabled to lock out access after a specified number of failed password attempts for a specified time limit. Only the Administrator who has logged in with their own unique password can change the test database password and this password can never be removed once set. The Administrator can change this password, but to do so they must enter the current password. By utilizing any combination of these features you can institute a multi-tiered password policy to access the data (local PC login, individual IVA User logins, and/or unique database password) and prevent access to PHI data.
No identifying Personal Health Information (PHI) is stored on the Remote Test Devices or in the Cloud database used by any BrainTrain application. All data is encrypted and coded using a random identifier to provide the utmost in data security that meets HIPAA requirements.
In the event that you may need to share a record or database with an outside party, there are procedures built-in to the system whereby you can export a completely de-identified and randomized record ID to a separate database. This can be used to share a record with another clinician, BrainTrain or as part of a research group without the chance that the Name, Test ID or Date of Birth can be traced back to a specific individual. This procedure can be done for single records, groups of test records or the entire database at once.
Further security is also possible by entering unique code names for all individual persons tested that are mapped outside of the test system. For example, Test100319 (date) as first name and last name can be Time1310 (1:10PM). The DOB can be set to any value that generates their correct age based on the testing date using any month/day/year that is not their true birthday. In this way the test database will not contain ANY PHI information. Reports can be exported in Word format and then edited as necessary to enter the person’s real name and DOB. Thus, anyone viewing the test data will not know who it is or be able to figure that out in any way as the test database will not have any PHI data in it. A separate record needs to be entered in the person’s chart documenting their code name. In this case, if anyone able to get access to the test database it would not provide any PHI information as all data stored in can not be used to identify any person.
These combined methods together will meet all their security needs and prevent any PHI data breach from occurring via test database access by anyone. In addition, only connecting the PC to the internet for updates periodically as necessary will minimize risk of unauthorized access to PHI data.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Financial information connected to payments may be collected or stored by a third-party payment processor and payment is subject to their terms and policies.
How We Use Your Information
By providing us your email address (including by “following,” “liking,” linking your account to our Website, etc., on a third party website or network), you consent to our using the email address to send you Website-related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on our Website to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages, such as newsletters, changes to features of our Website, or other information. If you do not want to receive such email messages, you may opt out by emailing firstname.lastname@example.org or clicking Unsubscribe on any email message you receive from BrainTrain. [gdpr_privacy_tools]
Following termination or deactivation of your account with us, we may retain your profile information and user content for a reasonable time for archival purposes. Furthermore, we may retain and continue to use indefinitely all information (including user content) contained in your communications to other users or posted to public or semi-public areas of our Website after termination or deactivation of your account.
We reserve the right, but have no obligation, to monitor the user content you post on our Website. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or to protect or defend our rights or property or those of any third party. We also reserve the right to remove information upon the request of any third party. We reserve the right to remove any of this type of information without notifying you or providing any specific reasons.
We use information that we collect about you or that you provide to us, including any Personal Information:
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at email@example.com or adjust your user preferences in your account profile, if you have created a user account for Services, Products, or Apps.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Social Media Plugins
We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site (“SMS”) login.
For example, when you visit our Website or platform, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website or platform with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website or platform to your Facebook profile. This allows Facebook to assign your visit to our Website or platform to your user account. Please note that as provider of the Website or platform, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website or platform to your Facebook user account, please log out of your Facebook user account.
Retention of Your Information
How We Share Your Information
Any personal information or user content that you voluntarily disclose for posting to braintrain.com or on our social media forums, such as Facebook, becomes available to the public, as controlled by any applicable privacy or website customization settings. If you remove information that you posted to braintrain.com, copies may remain viewable in cached and archived pages, or if other users have copied or saved that information.
Personal Information: We will never rent or sell your Personal Information to others, other than as noted below under “Disclosure/Assignment of Your Personal Information”. We may share your Personal Information with third parties for the purpose of providing or improving the Service to you. If we do this, such third parties’ use of your Personal Information will be bound by obligations of confidentiality. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting providers). Any Personal Information or content that you voluntarily disclose for posting to the Service becomes available to the public, as controlled by any applicable privacy or website customization settings. To change your privacy settings on the Service, you may visit your account settings page (if you created an account) or email us at firstname.lastname@example.org. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information.
From time to time, we may run contests, special offers, or other events or activities (“Events”) on the Service together with a third party partner. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these Events.
De-Identified Personal Information: We may share De-Identified Personal Information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.
Your Consent to Our Disclosure/Assignment of Your Personal Information
You consent to our disclosure of your Personal Information and other information to a potential buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred. You agree to and do hereby consent to our assignment, conveyance, or transfer (whether by contract, merger or operation of law) of rights to your Personal Information and other information, with or without notice to you and without your further consent.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to us is stored on our secure servers (or those of our service providers) behind firewalls. We may store, retrieve, access, and transmit your personal information in the US or in other countries. Any payment transactions will be performed using our third party payment processors, who will use appropriate security procedures.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access your account, our products, Apps or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. The information you share in public areas may be viewed by other users.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do try to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.
What You Can Access
Not all users will need an online accessible account to be setup. However, if you do create an online web account, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
The information that you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and to being provided contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: firstname.lastname@example.org.
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to the Services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your request at email@example.com. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service or security related emails.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at firstname.lastname@example.org.
Individuals under the Age of 
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Additional Information for non-US Residents
If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.