Privacy Policy

 

  1. Introduction

Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian  Standards Association Model Code for the Protection of Personal Information incorporated by reference into  PIPEDA.

  1. Application

This privacy policy applies to the collection, use, and disclosure of personal information provided to Brain Sensei Inc. and its related companies and business activities, including the Brain Sensei Affiliate Program (“Brain Sensei” or “We”) by customers/affiliates of Brain Sensei (“You”).

In this policy, “customer” includes members of Brain Sensei’s Affiliate Program (“affiliates”).

This Policy is governed by the laws of Ontario, Canada, and the laws of Canada applicable therein.

  1. Personal Information

Personal information is defined in PIPEDA as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card.

  1. Collection of Personal Information

We collect personal information from our customers in the regular course of doing business. This policy is designed to let customers, like you, know exactly how we're protecting the information you entrust to us.

By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.

We may collect some or all of the following information about you:

  • Name
  • Address
  • Postal Code
  • Phone Number
  • Email Address
  • Date of Birth/Age*
  • Gender*
  • Payment card number
  • Payment card expiry date
  • Purchase history
  • Product/service preferences*
  • Customer satisfaction info*
  • Opinions about products and services*
  • Interests and hobbies*

N.B. An asterisk (“*”) denotes optional information disclosed by you.

When you visit our website, certain other types of information may be gathered indirectly:

(a)   Internet Server Provider

Brain Sensei’s website(s) are hosted on servers provided by an Internet Service Provider (“ISP”).  Personal information, collected by the ISP, on Brain Sensei’s behalf, such as server log data, is managed in accordance with this Privacy Policy and is protected by applicable law. 

You should know that certain information about your traffic patterns are passively and automatically collected and linked to your Internet Protocol (“IP”) address. These unique IP addresses are assigned to all web users by the user’s ISP and are automatically logged by internet servers.  Your IP address does not explicitly identify you but, in some circumstances, an IP address can be linked to you, only with the cooperation of your ISP.  This may be linked in the course of an investigation of a security breach, for example, where the police are issued a warrant for such information by a court of competent jurisdiction.

(b)   Server Logs

You should also know that, in establishing internet connections, servers, including ours, automatically log information about visits to our websites.  These logs record statistical information such as your IP address, type of computer operating system, the time and duration of your visit to our website and the specific pages requested/visited.  It also discloses the type of domain, browser type, and geographic location.  This information is provided in aggregate form to use and we use the data to improve our website experience.  We do not link this information to any other data, including your personal information, except in the course of security purposes, as we discussed above in section (a).

(c)    Cookies

Cookies, which are small text files that contain a unique identification number, is deposited on your computer every time you visit our site.  These cookies track information during your time at our website(s) and are stored temporarily in your computer’s memory.  This information is used by us, and your browser, to facilitate and enhance your visits to our websites.  They help you by remembering information, such as username (if you choose), for example, and also helps us by tracking the total number of unique visitors to a website on an ongoing basis and other information such as browser type and computer operating system.  Cookie data is not cross-referenced with other types of personal information that you provide us. 

Cookies are common tools on the internet.  Many browsers are set to automatically accept cookies.  If you do not wish to accept cookies, refer to your internet browser software settings.

We will retain information, including your personal information, for as long as it is needed for the purposes for which it was collected.

How do you use this information?

Some information is required to complete the website registration process and/or to complete a sale or other financial transaction.  This is used by us to verify your identity and process online payment. We also use it to provide customer service to you. 

Additional information, which is optional, is collected for the purposes of marketing and customer service.

We will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law. 

Your personal information may be processed, accessed and/or stored in Canada or another jurisdiction, and will be subject to the laws of that jurisdiction, if applicable. 

Withdrawal of Consent

You may withdraw your consent to Brain Sensei’s collection, use and disclosure of your personal information at any time, subject to legal and/or contractual restrictions and upon reasonable notice. Your withdrawal of consent to Brain Sensei’s collection, use and disclosure of your personal information may impact Brain Sensei’s ability to provide you with services.

You can ask Brain Sensei not to send you marketing communications by following the opt-out instructions in each communication or you may let me know by contacting Brain Sensei at info@BrainSensei.com.

Disclosure of Personal Information

Generally, Brain Sensei does not disclose your personal information to third parties without your consent unless permitted or required by applicable laws or court orders.   It may be disclosed, for example, to recover unpaid accounts.  Non-identifying data may also be shared with Brain Sensei’s partners, marketing firms, and third-party contractors.

If you enter a contest, organized by Brain Sensei, you may be required to consent to further disclosures to Brain Sensei’s partners and contest sponsors.

Accuracy of Your Information

It is important that the information that Brain Sensei has on file be accurate and up-to-date.  We encourage you to keep your personal information on file with Brain Sensei up-to-date using the website’s self-service feature. We may, from time-to-time, ask you whether your personal information is up-to-date.

Safeguards

Brain Sensei makes use of various safeguards to ensure that your personal information is protected against loss, theft, misuse, unauthorized access, disclosure, copying or alteration. These include security software and firewalls to prevent unauthorized computer access or “hacking”; and internal passwords that restrict access to my electronic files.

Access to your Personal Information & Compliance

You have a right to challenge the accuracy and completeness of your personal information and to have it amended, as appropriate. You also have a right to request access to your personal information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal personal information about another individual, your request for access may be limited or denied. If your request for access is denied, Brain Sensei will notify you in writing of the reason for the denial.

Brain Sensei will also respond to inquiries about its policies and practices relating to the handling of your personal information and will investigate all complaints and respond within 30 days of receipt of a written inquiry.

If the complaint is found to be justified, Brain Sensei will take appropriate measures to resolve it, including, if necessary, amending this Policy and Brain Sensei’s procedures.

Privacy Contacts

If you have any questions or complaints about this Policy or the handling of your personal information, if you wish to withdraw your consent to the use of your personal information, or to request access to or update any information on file, please contact:

Chris Stafford

PRIVACY OFFICER

2 Bloor Street East, Suite 3500

Toronto, Ontario

M42 1A8

647.438.8300

chris.stafford@brainsensei.com

 

If any complaint or inquiry is not handled to your complete satisfaction, you may contact:

Privacy Commissioner of Canada

112 Kent Street

Ottawa, Ontario

K1A 1H3

Telephone: 613.995.8210

Toll free: 1.800.282.1376

Changes to this Privacy Policy

We may amend this Policy at any time. We will post the Policy as amended on our website and will available upon request. Please check from time to time to ensure you are aware of our current policy