Effective: Thursday, 31 December, 2020

Thank you for using BrainCiti. This Privacy Policy describes the Personal Information (defined below) we may collect, use, protect, store, disclose, and otherwise process through our products or services, including our online educational programs (each, a “Course”), our website(s) (including www.BrainCiti.com) (collectively, the “Site”), and related applications (including any mobile and TV device apps) and features across all devices and platforms (e.g., computer, mobile phone, tablet, etc.), all of which are collectively referred to in this Privacy Policy as the “Service.” References to “we,” “us,” and “our” refer to BrainCiti.com

By using our Service, you are confirming that you understand English well enough to understand this Policy.

1. EXCLUSIONS

This Privacy Policy does NOT apply to Personal Information we collect offline or you provide to or is collected by any third party (except as otherwise provided below). For example, the Service may contain links to third party websites that collect and use your Personal Information in accordance with their own privacy policies, which you should read. We have no control over, and are not responsible for, the privacy practices or content of these third parties.

Let’s get real:

This Privacy Policy does not apply to what third parties do with your Personal Information. 

2. CHILDREN

No one under 18 years of age is authorized to use the Service, and we do not intentionally collect, use, store, disclose, or otherwise process Personal Information from anyone under the age of 18. If you are a parent or guardian of a person under the age of 16 who has submitted Personal Information, please contact us at support@BrainCiti.com. 

Let’s get real:

You must be 18 to use our Service.

3. PERSONAL INFORMATION COLLECTED

We may collect different types of information from you depending on how you use our Service, including Personal Information. “Personal Information” means information that relates to an identified or identifiable natural person. The categories of Personal Information we 

may collect are listed below. Certain types of Personal Information may fall under more than one category.

• Identifiers: We may collect your first and last name, email address, username, social media usernames, mailing address, telephone number, Internet Protocol address, software, hardware, and device identifiers, and online identifiers.
• Commercial information: We may collect your payment information and transaction history (e.g., your subscriptions).  
• Internet or other similar network activity: We may collect information about your interaction with the Service (e.g., your internet service provider, referral pages, the content you view on the Service, the dates you access that content, and the length of time you view that content).
• Protected classification characteristics under California or federal law: We may collect your age and date of birth.
• Geolocation data: We may collect your location. 
• Sensory data: We may collect your voice, appearance, likeness, video, profile picture, and other images you upload to the Service or share from your social media platforms.  
• Other categories: We may collect information from the content that you share publicly in the Service through its public functions (e.g., your biographical information, the links you share on the Service to your personal website(s), your comments, posts, and reviews on the Service’s forum, blog, Course review, and other social media pages) or share with us through direct communications. We may also collect your friends and contacts list through your social media platforms. 

We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business purpose under applicable law. 

4. SOURCES OF PERSONAL INFORMATION 

Directly From You

We may collect your Personal Information when you provide it to us directly. For example:

• When you create or update your account, we may collect your name and email address. 
• When you purchase a Course or subscription, we may collect your payment information and a record of your transaction history.
• When you use the public functions in the Service such as your user profile, we may collect the information you choose to disclose (e.g., your biographical information, the links you share on the Service to your personal website(s), your comments, posts, and reviews on the Service’s forum, blog, Course review, and other social media pages). 
• When you register or login into the Service using certain third party social media platforms, such as Facebook Connect or Google (each, an “Authentication Service”), we may collect your username, profile picture, age, date of birth, email address, and friends and contacts list. 
• When you contact us or report a problem with the Service, we may collect records and copies of your correspondence. 
• When you submit a copyright infringement claim, our copyright agent may collect your signature, mailing address, telephone number, and email address. 
• When you respond to a survey or questionnaire, we may collect the information provided.

Automatically From You

We may collect your Personal Information automatically as you use our Service. For example, we may collect your Personal Information as you browse our Site. For more information about our use of cookies and similar technologies and certain choices we offer you with respect to them, please see Section 5 below.

From Third Parties                                                                                                                                                 

We may receive your Personal Information from or through third parties that help us provide or facilitate your access to the Service. For example, we may receive your Personal Information from social media platforms, advertising partners, payment processors, and customer support partners. 

• If you login to the Service using an Authentication Service or use an image from your Facebook, Twitter, or other social media accounts as your profile picture on the Service, we may collect your account information and profile picture from those social media platforms. To control the settings on the information you share with us through these social media platforms, please refer to the applicable third party Authentication Service.

We abide by this Privacy Policy when we use Personal Information provided to us by third parties. However, we do not control the Personal Information that third parties collect or how they use that Personal Information. You should review the third parties’ privacy policies for more information about how they collect, use, and share the Personal Information they obtain and use.

Let’s get real:

We collect your Personal Information directly from you, automatically through cookies and other similar technologies, and from third parties such as social media platforms.

Let’s get real:

5. COOKIES AND SIMILAR TECHNOLOGIES  

Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allow us and third parties to recognize your browser or mobile device and transfer information about you and your use of our Service.

Our Cookies and Similar Technologies 

We may use cookies on the Service (or similar technologies such as web beacons), for example, to collect Personal Information regarding your use of the Site (e.g., your Internet Protocol address, software, hardware, and device identifiers, location, internet service provider, referral pages, the content you view on the Service, the dates you access that content, and the length of time you view that content).

Third Party Cookies

We may allow advertisements to be displayed on the Service, in which case the advertisements and the third parties responsible for the advertisements may also use cookies and similar technologies to collect your Personal Information. 

This Privacy Policy applies to the use of cookies by us and does not apply to the use of cookies or similar technologies by such advertisers or any other third party. 

Browser Settings and Choices about Cookies

The Help portion of the toolbar on most browsers will tell you how to restrict cookies or disable them altogether. However, restricting or disabling cookies may prevent you from using some of the features of the Service. 

Please note that we do not respond to a “Do Not Track” signal from your browser or mobile application due to lack of standardization regarding how that signal is to be interpreted.

Let’s get real:

We and third parties use cookies or similar technologies to collect Personal Information from you automatically, but you can restrict or disable those cookies. 

6. PURPOSES OF COLLECTION

• To provide or improve the Service– We may use your Personal Information to process your requests to access the Service and to generally provide and improve the Service. For example, we may use your Personal Information to improve a Course.  

• To administer the Service– We may use your Personal Information for any lawful business purpose in connection with administering the Service. For example, if you reach out to us with a customer service inquiry, we may use your Personal Information to respond to you or to troubleshoot an issue you reported having with the Service. By way of another example, we may use your Personal Information to collect applicable fees related to the Service.   

• To market the Service– We may use your Personal Information to market the Service to you. For example, we may send you news and updates about the Service if you do not opt-out of such communications (described in Section 9 below). By way of another example, we may use your Personal Information to enhance and personalize your shopping experiences and for other promotional purposes.
• In furtherance of legal, health, and safety objectives– We may access, use, and share with others your Personal Information for purposes of health, safety, and other matters in the public interest. We may also provide access to your Personal Information to cooperate with official investigations or legal proceedings (e.g., in response to subpoenas, search warrants, court orders, or other legal processes). We may also provide access to protect our rights and property and those of our agents, users, and others including to enforce our agreements, policies, and our Terms of Use. 
• In connection with a sale or other transfer of our business – In the event all or some of our assets are sold, assigned, or transferred to or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy, or otherwise, your  Personal Information may be among the transferred assets.
• As may be described to you when collecting your Personal Information. 

Let’s get real:

We may use your Personal Information that you give us to customize our communications with you and your experience on the Site.

7. DISCLOSURE OF PERSONAL INFORMATION  

Third Party Service Providers

We may disclose your Personal Information to a third party such as a service provider for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract with that service provider that describes the purpose and requires the service provider to both keep that Personal Information confidential and not use it for any purpose except performing the contract. These service providers include certain advertising partners and our partner network. 

Others

We offer you the ability to share your activities on the Service with your friends and other third parties such as through third party social media platforms (e.g., Facebook). If you choose to share information about your activities in this manner, you are permitting us to share such Personal Information with these third parties.

Where permissible by law, we may use certain limited Personal Information about you, such as your email address, hash it, and share it with social media platforms (e.g., Facebook) to drive traffic to our Site or otherwise promote the Service. These processing activities are based on our legitimate interest in marketing activities related to our Service that may be of interest to you.

We may also disclose your Personal Information:

• To our subsidiaries and affiliates;
• To our lawyers, consultants, accountants, business advisors, and similar third parties who owe us duties of confidentiality;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other 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 pertaining to the users of our Service is among the assets transferred;
• To comply with any court order, law, or legal process, such as responding to a government or regulatory request;
• To enforce any contract we may have in effect with you; 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our users, or others; and 
• If you have consented to such a disclosure. 

Let’s get real:

If you want to share something about your BrainCiti experience on Facebook through us, you give us permission to do that.

8. PROTECTIVE MEASURES

Our Retention, Purpose Limitation, and Security Policies

We protect your Personal Information through a combination of collection, security, and retention policies.

• Limited retention.We only keep your Personal Information for as long as we need it for business and operational needs or to comply with any statutory, regulatory, or legal obligations. For example, we may retain Personal Information collected from you to support customer service inquiries and prevent repeated violations or suspected violations of our Terms of Use if your account has been banned or your access to the Service has been disabled for any reason. 

• Purpose limitation.We will use your Personal Information only for the Service you choose to access and for the purposes for which you choose to share it. We will respect your requests to start or stop processing your Personal Information for marketing purposes, as well as the types of marketing messages you may wish to receive.
• Security measures.We use appropriate measures to ensure a level of security appropriate to the risk involved and have implemented contractual, technical, administrative, and physical security measures designed to protect Personal Information from unauthorized access, disclosure, use, and modification. As part of our privacy compliance processes, we review these security procedures on an ongoing basis to consider new technology and methods as necessary. However, please understand that our implementation of security measures as described in this Privacy Policy does not guarantee the security of your Personal Information.

• In the event of a security breach, no longer than 72 hours after we become aware of such a breach, we will notify the proper regulatory authorities and any affected users of the breach.

Your Practices and Activities

Your practices and activities are likewise very important for the protection your own Personal Information. You can take certain steps to help protect your Personal Information, such as being mindful of what you share publicly in the Service. For example, if you do not want your Personal Information to be visible to other users of the Service, please do not upload that information to your user profile or other public portions of the Service such as Galleries (defined in our Terms of Use).

Users should also not pick a password that is easy to guess and should not share their password.  

Please remember that we have no control over what third parties do with the content of your communications and have no responsibility or obligation regarding third parties.

Let’s get real:

We work very hard to protect your Personal Information, but we cannot guarantee 100% protection.

9. YOUR PREFERENCES AND OPTIONS 

Modifying Your Personal Information. You can modify your account information at any time by logging into your account, clicking on “My Account”, and then the “Edit Contact Information” link. In addition, you may modify any Personal Information in your user profile at any time. We may keep a copy of the prior version of this information for our records. If you have questions about how to modify or remove your account information, please email us at support@BrainCiti.com.

If you have chosen to connect your BrainCiti account to a third party social media platform (e.g., Facebook), you may modify permissions by changing your account settings in that third party platform.

Opting-Out of Marketing Communications. If you no longer wish to receive email advertisements, you may opt-out at any time by: (i) clicking the opt-out/unsubscribe option contained in each commercial email; (ii) going to your account information and changing your communication preference settings; or (iii) emailing at us at support@BrainCiti.com. Please note that it may take up to 48 hours for the system to fully update your preferences. Opting out of these communications will not impact emails or other communications we send you regarding your use of the Service (orders, policies, updates, etc.).

Deletion of Your Personal Information. Subject to the additional notices provided to EU and California residents in Sections 10 and 11, if you no longer want us to provide the Service to you, you may request that we delete your Personal Information and close your BrainCiti account. If you request the deletion of your Personal Information: (a) your information will be deleted from our databases; (b) we may retain some of your information as necessary to improve safety and legal compliance such as fraud detection and prevention and enhancing safety (for example, if we suspend a BrainCiti account for fraud or safety reasons, we may retain certain information from that BrainCiti account to prevent that user from opening a new BrainCiti account in the future); (c) we may retain and use your information to the extent necessary to comply with the law (for example, BrainCiti may keep some of your information for tax, legal, and auditing obligations); and (d) information you have shared with others (e.g., comments made during a Course or on a Course page) may continue to be publicly visible on the Service, even after your BrainCiti account is deleted.

Withdrawing Your Consent. Where you have provided your consent to the processing of your Personal Information by us, you may withdraw your consent at any time by changing your account settings or by emailing us at support@BrainCiti.com specifically identifying the consent being withdrawn.

Let’s get real:

We’ll get social from time to time. You have choices. You can modify your account information and opt-out of emails or communications. We won’t take it personally.

10. ADDITIONAL NOTICE FOR EU RESIDENTS

The following applies to EU residents pursuant to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation):

Place of Business

We may store or process your Personal Information outside of the country where we collect it or which you reside. The Company has its primary place of business in the United States of America. You should understand that we may transfer some or all of your Personal Information to the United States of America to carry out certain operational and processing needs as described in this Privacy Policy.

Transfer Mechanisms

When transferring Personal Information out of the EU, we implement technical, organizational, and physical safeguards to protect your Personal Information. We use European Commission approved standard contractual clauses and implement related measures required by applicable law. Please contact us if you have questions related to the relevant transfer mechanism for your Personal Information.

Lawful Basis

We only collect, use, or store your Personal Information if:

• You voluntarily provide it to us with your specific and informed consent; 
• It is necessary to provide you a Service that you have requested (for example, providing you access to a Course);
• We have a legitimate business interest that is not outweighed by your privacy rights (for example, to provide customer service). 
• It is necessary to protect your vital interests or the vital interests of others (for example, we may collect or share Personal Information where necessary to resolve an urgent medical situation or protect the health or safety of one of our users or someone else). 

Right to Access, Correct, Delete, or Restrict Processing

Subject to any limitations and exceptions under applicable law, you have the right to request access to your Personal Information and exercise a number of rights: 

• You have the right to correct or update certain types of Personal Information. In many cases, you can review or update your account information by accessing your account online. 
• You have the right to request deletion of your Personal Information. If you choose to have your Personal Information removed from our Service, we will carry out your request within 30 days of account verification, subject to extension, and will only retain minimal Personal Information to document your request and the actions we took to carry out your request. 
• You have the right to restrict certain processing of your Personal Information, and the right to object to some types of processing of your Personal Information.  
• You have the right to withdraw your consent at any time, including objecting to your Personal Information being used for marketing or advertising purposes. 

We will comply with your requests in accordance with, and subject to, applicable law. For example, we are not required to delete your Personal Information if it has an overriding legitimate ground for retaining that information such as to prevent fraud. Please note that we are legally prohibited from carrying out requested actions in some instances, including (a) when we are unable to confirm your identity; (b) where the request is considered excessive; and (c) where doing so would adversely affect the rights or freedoms of other individuals.

We Are Here to Help

Please email us at support@BrainCiti.com with the subject line “GDPR” if you would like to exercise any of the rights described above or if you have questions regarding your rights. 

Right to Complain

You have the right to lodge a complaint regarding our collection, storage, or processing of your Personal Information with a data protection supervisory authority in the country where you live or work.

Verifiable Consumer Requests

To exercise your rights described above, please email us at support@BrainCiti.com with the subject line “CCPA”. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 30 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

12. CHANGES

We may amend this Privacy Policy at any time by posting the modified Privacy Policy on the Service consistent with applicable law. The modifications will be effective upon such posting (unless a later date is specified in the posting, in which case that date shall be deemed the effective date of the modifications). Please review the Privacy Policy prior to submitting Personal Information on or through the Service.

Let’s get real:

The Privacy Policy can change and any changes will be posted here. Please review the Privacy Policy and any changes made.  

13. CONTACT

If you have any questions or comments about this Privacy Policy, please contact us at: in5 Tech, Cordoba Club House (Next To Al Sufuoh Tram Station), Dubai Knowledge Park, Dubai, United Arab Emirates

+971 4 390 1122

faisal@brainciti.com