Privacy Statement

Effective Date:  June 15, 2018

The Whole Brain Group strives to keep your personal information confidential. Please take a moment to make yourself aware of and understand this “Privacy Policy.”

This Privacy Policy explains our online information practices and the choices you can make about the way Your Information is used at our Site (defined below).  This Privacy Policy governs the manner in which The Whole Brain Group collects, uses, maintains and discloses information that it collects from the Site.  The Whole Brain Group’s Terms of Use available at https://thewholebraingroup.com/terms-of-use/ (the “Terms of Use”) are incorporated and made a part of this Privacy Policy.

SECTION 1 – DEFINITIONS

  • “You” and “your” mean the individual or entity visiting or using our Website(s).
  • “WBG”, “we,” “us” and “our” means The Whole Brain Group.
  • “Website” refers to WBG’s website, www.thewholebraingroup.com, and other associated websites, blogs, domains and mobile sites maintained by WBG.
  • “Personal information” means personally identifiable information, which is non-public information we receive from your use of the Website that can be used, alone or in combination with other information in our possession, to identify a particular individual.  It may include information such as name, address, telephone number and other personal information you provide to us.

SECTION 2- INFORMATION COLLECTED AND CONSENT

You do not have to provide any personal information to browse the Site.

We may collect personal information from you in a variety of ways, including when you visit the Site, register on the Site when you provide personal information in connection with other activities, services, features or resources we make available on the Site, or when you complete a transaction on the Site.  We may collect your name, mailing address, billing address, phone number, payment information, and email address. We may also collect additional information from you depending on the nature of the transaction.

WBG also collects information about you automatically when you visit the Site.   We automatically receive certain information from your browser or mobile devices, such as your browser type, the operating system of your device, the URL of the site from which you came and the URL of the site you visit when leaving the Site.  We also receive your IP address and the name of your ISP or your mobile carrier. Depending on your device’s settings, we may also receive location data and other types of information sent from third-party services or GPS-enabled devices. As you use the Site, we may also collect information about such usage and your actions on the Site, such as pages you viewed, access times, and how long you spent on a page.  We may use cookies to collect such information, as described in more detail below.

This information is considered Non-Personal Information, which we can use for any purpose, including to help us improve the Site and to enhance your and other users’ experience.  However, we will treat as personal information any item that, either alone or together with other information, we could use to identify an individual. Except as described below in this section, Section 11 and Section 12 below, we will not share with third-parties the link between your IP address and your personal information without your permission.

By providing your personal information to us, you explicitly agree to our collection and use of such information as described in this Privacy Policy.  By browsing or using the Site, you consent to this Privacy Policy.

SECTION 3 – PAYMENT INFORMATION

If you choose a direct payment gateway to complete a transaction, then WBG will share Your credit card data with a third-party transaction service. It is encrypted in compliance with the Payment Card Industry Data Security Standard (“PCI-DSS”). Your transaction data is stored only as long as is necessary to complete Your transaction. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, MasterCard, American Express and Discover.

SECTION 4 – WEB BROWSER COOKIES

The Site may send a “cookie” to your computer.  A cookie is a small piece of data sent to your browser from a web server and stored on your computer’s hard drive.  A cookie cannot read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system.  Cookies allow us to recognize you as a user when you return to the Site using the same computer and web browser. We use cookies to identify which areas of the Site you have visited.  We also may use this information to better personalize the content you see on the Site. WBG does not store unencrypted personal information in the cookies. We also do not link Non-Personal Information from cookies to your personal information.

To help us optimize the Site or for marketing purposes, we may allow other authorized third-parties to place or recognize unique cookies on your browser.  Any information provided to third-parties through cookies will be for enhancing your user experience by providing more relevant marketing. Third-party services and tools we use, which may send cookies to users of the Site and may collect information from users, includes:

Google Tag Manager and Google Analytics (collectively referred to as “Google”): Google collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU personal information), Device ID (EU personal information), personal information (name, address, phone number, email address, login, EU- IP address, EU-unique device ID), sensitive (financial information). Aggregate data, anonymous data, personal information data and sensitive data is shared by Google with third-party parties.  We use the information we get from Google only to improve this website and for marketing purposes. Google collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. You can review Google’s privacy policy at https://www.google.com/policies/privacy/.  Although Google plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google.  Google’s ability to use and share information collected by Google about your visits to this website is restricted by the Google Terms of Use and the Google Privacy Policy. You can prevent Google from recognizing you on return visits to the website by disabling cookies on your browser (see below).

Facebook Custom Audience: Facebook Custom Audience, operated by Facebook Business (formerly Facebook Custom Audience), collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU personal information), search history, location-based data, Clickstream Data, personal information (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information).  Facebook Custom Audience’s privacy policy can be found at: https://www.facebook.com/full_data_use_policy.  Facebook Custom Audience shares data with third-parties (specifics are undisclosed).

Facebook for Developers (formerly Facebook Connect): Facebook for Developers operates Facebook Connect, which collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU personal information), search history, location-based data, Clickstream Data, personal information (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information).  Facebook for Developers’ privacy policy can be found at: https://www.facebook.com/about/privacy/. Aggregate data is shared by Facebook for Developers with third-parties. Facebook for Developers also shares anonymous data with third-parties. Facebook for Developers shares personal information data with third-parties. Facebook for Developers also shares sensitive data with third-parties. We do not combine the information collected through Facebook for Developers with personal information.

Analytics, LinkedIn Ads and LinkedIn Marketing Solutions (collectively, “LinkedIn Analytics”):  LinkedIn Analytics collects anonymous data (ad views, analytics, browser information, cookie data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU personal information)), Location Based Data, Device ID (EU personal information), and personal information (name, address, phone number, email address, login). Aggregate and anonymous data is shared by LinkedIn with third-party parties.  LinkedIn’s privacy policy for LinkedIn Ads and LinkedIn Analytics can be found at:  https://www.linkedin.com/legal/privacy-policy.

HubSpot and HubSpot Forms (collectively referred to as “HubSpot”):  HubSpot collects:  anonymous data (browser information, cookie data, date/time, demographic data, hardware/software type, page views and serving domains) and pseudonymous data (IP Address (EU personal information), location-based data, Clickstream Data), personal information (name, address, phone number, email address, login), and sensitive (financial information).  HubSpot’s privacy policy can be found at:  https://legal.hubspot.com/privacy-policy.  We do not know if HubSpot shares the data it collects with third-party parties. We do not combine the information collected through HubSpot with personal information.

Hotjar: Hotjar collects information (analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, page views and interaction data) and pseudonymous data (IP Address (EU personal information), location-based data, Clickstream Data, device ID (EU personal information)), and personal information (EU- IP address, EU- unique device ID).  Hotjar’s privacy policy can be found at: http://www.hotjar.com/privacy. For more information about the information Hotjar may collect, please inquire further at https://www.hotjar.com/contact. We do not combine the information collected through Hotjar with personal information.

ShareThis:  ShareThis collects anonymous data (ad views, analytics, browser information, cookie data, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU personal information)), search history, location-based data, ClickStream data, personal information (personal information collected via 3rd parties, login, EU-IP address), and sensitive (health information).  Aggregate and anonymous data is shared by ShareThis with third-party parties.  ShareThis’ privacy policy can be found at:  http://www.sharethis.com/pri.html.

Some browsers may allow you to manage the storage of cookies on your device.  If supported by your browser, you may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert you when a cookie is set.  However, if you select these settings, you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting to refuse cookies, the Site will issue cookies.  For more information about how to manage your cookies preferences, use the ‘help’ menu of your web browser or explore the customer support sections of your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for your browser for instructions.

Here are links to some browsers’ websites:

Google Chrome: www.google.com

Internet Explorer: support.microsoft.com

Mozilla Firefox: support.mozilla.org

Safari: support.apple.com

Opera: www.opera.com

SECTION 5 – DO NOT TRACK

Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit.  This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation.  At the current time, the Site is not programmed to recognize Do Not Track signals, so the Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.

SECTION 6 – EXEMPTIONS FROM THE PRIVACY POLICY

Our Privacy Policy does not apply to any information you may send to WBG by email or instant messaging programs (e.g., AOL, Yahoo, etc.), or through social media networks, even if you open such programs or services by clicking a link displayed on the Site.  Email, social media, and instant messages are not recognized as secure communication forms. Please do not send any information you consider private to us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings.

SECTION 7 – NOTICE TO NON-US RESIDENTS

WBG is headquartered in the United States of America.  Your data is stored or accessed by us in the United States through WBG’s data storage, databases, the WBG application, and third-party hosting applications.  On all of these platforms, your data is on a secure server behind a firewall. Thus, Personally Identifiable Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world.  By providing us with personal information, you consent to this transfer. We will protect the privacy and security of personal information according to our Privacy Policy, regardless of where it is processed or stored.

SECTION 8 – THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.  However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them to process payments made by you to us.

For these providers, we recommend that you read such third-party privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

When you click on links on the Site, the links may direct you away from the Site. You also may be automatically directed from the Site to another website.  Once you leave the Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or the Terms of Use. We are not responsible for the privacy practices of other third-party sites and encourage you to read their respective privacy statements.

SECTION 9 – SECURITY

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information through the Site, the information is encrypted using secure socket layer technology (SSL) and stored with encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements.

SECTION 10 – AGE OF CONSENT

WBG takes special care to protect the privacy needs of children under the age of 13 and we encourage parents to be an active participant in their child’s online activities.  WBG abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The Site does not target and is not intended for children under the age of 13, and WBG will not knowingly collect personal information from them.  If WBG discovers personal data from a child gathered through the Site, WBG will eliminate that data. This Site is only intended for persons 18 years of age or older. If you are under 18 you must ask a parent or legal guardian for permission prior to submitting any information to this Site.

If you have knowledge that a child 13 years of age or younger has submitted personal information to us, please contact us and we will delete the personal information collected belonging to that child.  You may contact us via email or by writing to us at the address below. Parents and guardians can also telephone us at 734-275-3753, but before any information is disclosed, the parent will be required to provide the parent’s name and email address for verification. We will only send the information to the parent email address in the registration file.

We will never require the disclosure of a Minor’s personal information.

SECTION 11 – HOW WE USE YOUR INFORMATION AND WHAT WE SHARE WITH THIRD-PARTIES

We collect only as much personal information as we need for specific, declared purposes, and as set forth in this Privacy Policy.  We will not use it for other purposes without obtaining your consent.

WBG uses and shares personal information necessary to fulfill its obligations under a transaction or for us to provide you with a requested product or service.  Specifically, WBG may also use personal information for the following purposes:

  • To improve customer service
  • Your information helps us to more effectively respond to your customer service requests and support needs.
  • To integrate social media with the Site
  • To personalize user experience
  • We may use information in the aggregate to understand how our users as a group use the services and resources provided on the Site.
  • To improve the Site
  • We continually strive to improve our website offerings based on the information and feedback we receive from you.
  • Manage WBG everyday business needs, such as Site administration, communication, management, analytics, Terms of Use
  • To process transactions
  • We may use the information that you provide about yourself when placing or fulfilling an order for products or services. We do not share this information with outside parties except to the extent necessary to provide the product or service.
  • To send periodic emails and newsletters
  • The email address you provide for order processing will only be used to send you information and updates pertaining to products or services you request. It may also be used to respond to your inquiries, and/or other requests or questions.
  • To develop new products or services

We use your personal information and Non-Personal Information for research and commercial purposes.  The information we collect may be used to develop new products or services. We may use your personal information and Non-Personal Information internally or, among other things, to offer our own or third-party products and services.  Only WBG, its subsidiaries, its suppliers and contractors involved in distributing or providing the new product or service will have access to Your personal information. Our subsidiaries, suppliers, and contractors will be required to use any personal information we provide to them only for that intended purpose.

  • For marketing

WBG may use Your personal information and Non-Personal Information to enhance its networking, marketing, social, and recruiting activities, and for other similar business purposes.  We may also use Personally Identifiable Information to provide you information regarding new products or services we believe may be of interest to you. Such Personally Identifiable Information is not shared with entities outside of WBG other than service providers who assist us in carrying out these business functions.

  • Compliance with applicable law

We may disclose your personal information as we may in our sole discretion determine is necessary or reasonably required to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use, or to protect our rights, property or safety, or the rights, property or safety of others.

  • To contact you by phone or email when requested to, authorized to or under obligation to.
  • Change in the Site Ownership

If ownership of the Site changes, whether in whole or in part, information collected through the Site about you may be transferred to the new owner so the Site and any service provided through or related to the Site can continue.  In that case, your user information would remain subject to the terms and conditions of the applicable version of the Privacy Policy.

SECTION 12 – WHEN WE MAY SHARE OR DISCLOSE YOUR INFORMATION

WBG will not disclose your Personal Information to third parties without your explicit consent, except as specified in this Privacy Policy. WBG may share and disclose information, including personal information, as set forth below:

  •      Affiliates and Agents. We may share information with our affiliates or any business partners or agents acting on our behalf.
  •      Service Providers. We may share information with our service providers, agents, vendors and other third parties we use to support our business. We share personal information with such third parties to the extent necessary to provide services to us, and pursuant to binding contractual obligations.  Also see Section 8 above.
  •      Advertising and Marketing. To the extent permitted by applicable law, we may share information with third parties for marketing, advertising, promotions, contests, or other similar purposes.
  •      Mergers, Acquisitions, Divestitures. We may share, disclose or transfer information to a buyer, investor, new affiliate, or other successors in the event WBG, or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, joint venture, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of WBG or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).
  •      Law Enforcement and National Security. We may share information with legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, government request, regulatory request, law enforcement or national security investigation, or as otherwise required or authorized by law.
  •      Protection of Rights, Property or Safety. We may also share information if in our sole discretion, we believe disclosure is necessary or appropriate to protect the rights, property or safety of any person, or if we suspect fraud or other illegal activity,

If you do not want us to share your information with our service providers, as described above, you can direct us not to share that information via email or by writing to us at the address below.  An opt-out of information sharing will not apply to information sharing arrangements described in the above sub-sections titled, “Law Enforcement and National Security” or “Protection of Rights, Property or Safety.”

Finally, WBG may provide content and services to you through websites other than our own.  Any information you disclose on such sites is NOT subject to this Privacy Policy, but is, instead, subject to that third-party website’s privacy policy.

SECTION 13 – TRANSFER OF OWNERSHIP

If ownership of the Site changes, whether in whole or in part, information collected through the Site about you may be transferred to the new owner so the Site and any service provided through or related to the Site can continue.  In that case, your user information would remain subject to the terms and conditions of our then-current Privacy Policy.

 

SECTION 14 – NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE OF THE UNITED STATES OF AMERICA

WBG is headquartered in the United States of America.  Personally Identifiable Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world.  By providing us with Personally Identifiable Information, you consent to this transfer. We will protect the privacy and security of Personally Identifiable Information according to our Privacy Policy, regardless of where it is processed or stored.

 

SECTION 15 – CALIFORNIA PRIVACY RIGHTS

Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship.  That information is about the Personally Identifiable Information those companies have shared with third-parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of Personally Identifiable Information shared with third-parties, the names and addresses of those third-parties, and examples of the services or products marketed by those third-parties.  Although WBG does not consider the California Civil Code to control its use of information collected on or through the Site and WBG disputes any assertion that the California courts have jurisdiction over it, WBG will nonetheless provide the foregoing information shared upon request by contacting us at the email address or street address provided below.

SECTION 16 – ACCESS

If you are an individual you may have certain rights under applicable data protection legislation, to know what personal information of theirs is stored by us and to ensure that such personal information is accurate and relevant for the purposes for which we collected it. Unless you reside in California or another jurisdiction that requires us to provide the information without charge, we may charge You a fee to receive a copy of this data.  For a copy of or reasonable access to your personal data please contact us via email or by writing to us at the address below. WBG will make its best effort to allow individuals access to view their own data, as well as to correct, to alter or to delete such data.

However, where such access is unreasonable, requires a disproportionate effort, jeopardizes the privacy of other WBG users, or contravenes the law, our policies, or reasonable business practice, requests to access data may be declined. User identification is required to access data for these reasons, and the process and procedures for various types of access may differ. Please contact us for further information.

SECTION 17 – CHOICES RELATING TO USE OF YOUR PERSONAL INFORMATION

We’ll give you choices about the ways we use and share your personal information, and we’ll respect the choices you make. Although signing up for some or all of our services may require you to submit personal information, we will ask for your consent if we intend to use that information for any purpose other than which it was provided to us.  You may object, restrict or withdraw consent for us to use your personal information at any time.

In the case of us wishing to use your private information for any purpose different than the purpose it was provided and set forth in this Privacy Policy, we will request your consent to use your personal information and will only use it if you affirmatively give us consent to do so through an opt-in process.

You may choose to decline to submit any personal information for any of our products or services. Please note that this may result in our being unable to provide said service.

SECTION 18 – DATA PORTABILITY

If required by applicable law, WBG will comply with your request to obtain a copy of the information you have shared through our services.  If provided for by applicable law, you have rights to obtain a copy of some of the personal information that we hold on you and reuse or share it for your own purposes (“right to data portability”).

The above-stated right to data portability only applies:

  • to personal information you have provided to us (i.e. not any other information);
  • where we are processing your personal information because you have provided your consent for us to do so, or under a contract with you; and
  • when processing is carried out by automated means.

‍We can refuse your data portability request if the processing does not satisfy the above criteria.  Also, if the personal information concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.

SECTION 18 – DATA RETENTION–LENGTH OF TIME WE RETAIN YOUR PERSONAL INFORMATION

WBG retains personal information for as long as necessary to fulfill the business purpose for which you provided it to us and any other legitimate business purpose, including without limitation, for the purposes of satisfying any legal, accounting, or reporting requirements.  We may also retain offline archival copies of data for the applicable statutory periods. If you would like more details about our data retention policies, please contact us.

We periodically review our collection, storage and processing procedures and policies to ensure that it is in compliance with applicable law.

SECTION 19 – CAN-SPAM COMPLIANCE NOTICE

WBG fully complies with the federal CAN-SPAM Act.  You can always opt out of receipt of further email correspondence from us by clicking on the link at the bottom of any marketing emails or contacting us via email or by writing to us at the address below.

SECTION 20 – YOUR CONSENT

By using the Site, you consent to our collection and use of your personal information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our Web site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

SECTION 21 – ENFORCEMENT AND INDEPENDENT DISPUTE RESOLUTION

For EU residents:  To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:

The Whole Brain Group
Attn:  Privacy Compliance Officer
315 East Eisenhower Parkway, Suite 304
Ann Arbor, MI 48108
(734) 929-0431
privacy@thewholebraingroup.com
www.thewholebraingroup.com

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.  The following is the contact information for the supervisory authorities in each member state: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

SECTION 22 – CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on our website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

SECTION 23 – INCORPORATION OF TERMS OF USE

Please also visit our Terms of Use establishing the use, disclaimers, and limitations of liability governing the Site, which are incorporated into this Privacy Policy by reference.

SECTION 24 – QUESTIONS AND CONTACT INFORMATION

If you have a privacy question about the Site, please contact us at:

The Whole Brain Group
Attn:  Privacy Compliance Officer
315 East Eisenhower Parkway, Suite 304
Ann Arbor, MI 48108
(734) 929-0431
privacy@thewholebraingroup.com
www.thewholebraingroup.com

Effective Date:  June 15, 2018