Last Modified: May 14, 2019
At Userbrain, we collect personally identifiable information (“PII”) and non-personally identifiable (“Non-PII”) information from you. Personally identifiable information is information that can be used to identify you, personally. Non-personally identifiable information is information that must be combined with other information to identify you personally.
In order to fully use our Platform, we may collect user PII including but not limited to your name, date of birth, email, telephone number, address, country information, IP address, language, payment and billing information, ratings, visual and audio recordings (screen capture, facial recording, recordings of your voice and your actions) , specific interactions with the Platform, transactions, image, username, and gender. Additionally, for purposes of processing payments we may collect additional information such as financial identification information, PayPal information, your tax information, and additional identifying information.
Whenever you use our Platform, we may collect Non-PII from you, such as your broad demographic information, general browsing history, general search history, and registration history, general interactions with the Platform, usage information, location, referring URL, browser, operating system, data usage, data transferred, and Internet service provider.
We will never sell your information without your permission; however you agree that we may use your information in the following ways:
Please be aware that we me may collect and aggregate personally identifiable information from our Platform and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.
You will be able to access any information contained in your account through our Platform. You may edit that information by removing or changing the information listed within your account dashboard. If you have any questions or wish to review, update, edit, or access any of your PII collected by us, please contact us at firstname.lastname@example.org. After you have cancelled your account please be aware that we may keep inaccessible copies of your PII and non-PII subject to our data retention policies.
If you wish to have any of your PII stored within the Userbrain Platform removed, please contact us at email@example.com. With each removal request you must list the PII you wish to have removed exactly as listed. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in processing and removing any PII requested. You may make a removal request by email firstname.lastname@example.org, please label the subject of the email with the following “Removal Request – Your Full Name and Account Name” and provide us with details regarding the PII you wish to have removed.
Please be aware that where required by law or for liability purposes we may retain copies of your PII even after we process a removal request from you.
Although you are entering into an Agreement with Userbrain to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, web hosts, and others to allow you to access the Platform.
If you decide to provide us with your contact information, you agree that we may send you communications via text and emails. However, you may unsubscribe from certain communications by notifying Userbrain that you no longer wish to receive these communications. Where we have received such a notification, we will endeavour to promptly remove you from our contact lists. We currently do not offer functionality for you to opt out through “do not track” listings. If you wish to opt out of certain communications or information collection, please contact us at email@example.com.
Userbrain or other users may post links to third party websites on Platform, which may include information that we have no control over. When accessing a third party site through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites.
We make reasonable attempts to protect your information by using physical and electronic safeguards. However, as this is the Internet, we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls, and other precautions to protect yourself from security and privacy threats.
We intend to fully comply with Austrian and international laws respecting children’s privacy. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 and using our Platform, please stop immediately and do not submit any information to us. In the event that we have inadvertently collected any information from users under the age of 18 please contact us immediately.
In the event that Userbrain is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.
|Legal Rights||Your Rights Under the GDPR|
|The right to be informed||Userbrain wishes to keep you informed as to what we do with your personal information.|
|The right to access||You have the right to access your information at any time.|
|The right to rectification||If the information Userbrain holds about you is inaccurate or not complete, you have the right to ask us to rectify it.|
|The right to erasure||Sometimes called ‘the right to be forgotten’. You have the right to request that Userbrain to erase all your personal data (we may retain your personal data where required by law).|
|The right to restrict processing||You have the right to ask Userbrain to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests.|
|The right to data portability||Userbrain must allow you to port and reuse your personal data for your own purposes across different platforms. This right only applies to personal data that you have provided to us as a data controller.|
|The right to object||You have the right to object to Userbrain processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice.|
|The right to withdraw consent||If you have given us your consent to process your data but change your mind , you have the right to withdraw your consent at any time, and Userbrain must stop processing your data.|
The following are the specific legitimate purposes that we may use your PII for:
Userbrain employs the following legal basis to process your PII:
Userbrain will only retain your PII for as long as required. We will keep your personal information:
Where you have requested modification or deletion of your PII, we may keep just enough of your personal information to ensure that we comply with your requests not use your PII or comply with your right to erasure. If you require additional details regarding the retention of your PII please contact us. Additionally, where required for legal purposes, we may keep some of your PII even after a receipt of a request to delete your information as compelled by governmental authorities.
Your PII is processed in our offices located within Austria and in the locations where our third parties have data processing facilities. Depending on your location, data transfers may occur to other countries outside of your home jurisdiction. To find out more about the place of processing of such transferred PII, please review Section 22 containing details about the processing of Personal Data. Where a transfer of your PII occurs outside of the EEC we shall ensure that such transfer complies with the GDPR principles related to such data transfer and the legal basis for such transfer.
We may share your PII with our clients with whom you have taken a Test, each client is identified prior to your taking of a Test in your account, additionally we share your PII with third parties in accordance with our Third Party Processing and Sharing Policy. Detailed information on the processing of Personal Data
If you have any questions or require additional information related to our information collection practices, please contact us at firstname.lastname@example.org
Data Privacy Officer
8010 Graz, Austria
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