Date 26 june 2018
Welcome to the web site (the "Site") of BrainGymmer. This Site is operated by Dezzel Media B.V. and has been created to provide information about our company and the BrainGymmer brain training services, whether accessible to you via web, mobile app or other platform (our services, together with the Site, are the "Services") by visitors and users of the Services ("you" and/or "your").
We are Dezzel Media BV, located Wisselweg 33, 1314 CB Almere, The Netherlands. We will refer to our company as "BrainGymmer", "we", "us" and/or "our".
BrainGymmer is the data controller under the United Kingdom's Data Protection Act 1998 and applicable EU legislation including the Data Protection Directive and the Privacy and Electronic Communications Directive. We comply with the U.S. - E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set out by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services, which typically can include your name, telephone number; email address; home address; your payment details; your IP address; and any other personal information which you give us in connection with the Services.
When you interact with BrainGymmer through the Services, we receive and store certain information which does not identify you personally (referred to as personally non-identifiable information in the USA and non-personal data in the European Union). Such information is collected passively using various technologies.
i. Technical or other details about any device which you use to access the Services, including: Internet and/or network connection; your Media Access Control (MAC); any device Unique Device Identifier (UDID) or equivalent; your operating system, browser type or other software; your hardware or mobile device details (including your mobile device type and number and mobile carrier details), if applicable; or other technical details. This is technical data about our users and their actions and patterns, which we do not believe identifies any individual;
ii. Details of your use of our Services including, but not limited to: metrics information about when and how you use the Services; traffic data; and your geographical location data.
BrainGymmer may store such information itself or such information may be included in databases owned and maintained by BrainGymmer's affiliates, agents or service providers.
The Services may use such information and pool it with other information on an anonymised and generalised basis to track, for example, the total number of users of our Services, the number of visitors to each page of our Site and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.
In operating the Services, we may use a technology called "cookies."
By providing us with the information about you mentioned above, you give your consent to us to use that information in the following ways:
to share your Personal Data with BrainGymmer professionals in order to carry out Services;
to ensure that content from our Services is presented in the most effective manner for you and for your computer or other device from which you access the Services;
to provide you with information, products or services that you request from us or which we feel may interest you;
to carry out our obligations arising from any contracts between you and us;
to allow you to participate in interactive features of our Services, when you choose to do so;
to notify you about changes to our Services;
to improve or modify the Services, for example based on how you use our Services;
to calculate conversion rates and other elements of Services' performance;
for marketing purposes (which we discuss further below).
BrainGymmer is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties, as set out below:
Scientists: We may share anonymised training data with scientists to advance the research of cognitive functions.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Legal Requirements: BrainGymmer may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of BrainGymmer, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Marketing and advertising: BrainGymmer and its affiliates may use Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
We do not disclose personal information about identifiable individuals to advertisers, but we may provide them with aggregate and/or anonymised information about our users to help advertisers reach the kind of audience they want to target. We may make use of the information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
You can access the website without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain BrainGymmer Services.
You are responsible for any public publishing of information including Personal Data (for example on a discussion forum). Please remember that this may mean third parties gaining access to that information, for which you will be responsible.
BrainGymmer takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free; any transmission is at your own risk. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to BrainGymmer via the Internet. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Registered BrainGymmer users will have an account name and password which enables you to access certain parts of our Services. You are responsible for keeping them confidential. Please don't share them with anyone.
In the European Union
If you are a European Union citizen, you have the right to ask us not to process your personal information for marketing purposes by contacting us at firstname.lastname@example.org. EU data protection legislation gives EU citizens the right to access information held about you. Any access request may be subject to a small administrative fee to meet our costs in providing you with details of the information we hold about you. You may also email us at email@example.com to request that we delete your personal information from our database. We will use reasonable efforts to honour your request. We may retain an archived copy of your records as required by law or for legitimate business purposes (and if so we will explain this to you at the time).
Under California law, California residents who have an established business relationship with us may choose to opt out of disclosure of personal information about them to third parties for direct marketing purposes. If you choose to opt-out at any time after granting approval, email firstname.lastname@example.org.
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
You may contact us as follows:
Dezzel Media BV
1314 CB Almere