PLEASE READ THIS PRIVACY STATEMENT CAREFULLY IF YOU ARE NOT PREPARED TO CONSENT TO THE USE OF YOUR PERSONAL INFORMATION BY BrainAhead PROGRAM INC. FOR THE PURPOSES SET OUT ON THE BrainAhead WEBSITE OR IN THIS PRIVACY STATEMENT THEN DO NOT CONTINUE USE OF THE WEBSITE OR SHOULD YOU WISH TO REVOKE OR OPT OUT OF CONSENT TO THE USE OF PERSONAL INFORMATION THEN YOU MAY REVOKE OR OPT OUT IN ACCORDANCE WITH THE PROVISIONS OF THIS STATEMENT.

This Privacy Statement and the BrainAhead Program Inc. (“BrainAhead”) Privacy Code sets out how BrainAhead manages your personal information which is personally identifiable information, safeguards your privacy in accordance with Protection of Personal Information (B.C.), the Personal Information Protection and Electronic Documents Act (“PIPEDA”) of Canada and in compliance with Canada’s international obligations for data protection under General Data Protection Regulation (“GDPR”).

PIPA and PIPEDA are built on the following principles of fair information principles: Accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access, challenging compliance. Compliance with PIPA under the authority of BC Privacy Commissioner and PIPEDA is under the authority of the Privacy Commissioner of Canada.

The GDPR applies to organizations that have an established presence in the EU, offer goods and services to individuals in the EU or monitor the behaviour of individuals in the EU. The GDPR applies when personal data is “processed” and defines processing as “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.” The GDPR stipulates that data controllers or processors must also respect the principle of data minimization, meaning that the processing of personal data must be limited to that which is adequate, relevant, and necessary to achieve the specified purpose. Under GDPR personal data must be accurate, kept up to date, kept in a form which permits identification of data subjects for no longer than is necessary, and must be processed in a manner that ensures appropriate security of the personal data.

This Privacy Statement covers the site brain1stprograms.com (the “Website”) including all sub-domains and is compliance with PIPEDA and is also in compliance with GDPR as it does not have an established presence in the EU, does not offer goods and services to individuals in the EU ad when this Website collects or processes personal information of EU persons it does so in accordance with GDPR.

Compliance with Terms and Modifications

BrainAhead through our Website provides information and access to our BrainAhead program package for Educators (“BrainAhead program”) may collect, use and disclose personal information from visitors and users of our BrainAhead program in accordance with this Privacy Statement. Your browsing and use of this Website and BrainAhead program indicates that you accept these privacy terms and conditions and any subsequent modifications and that you are consenting to the collection, use and disclosure of your personal information as set out in PIPA and PIPEDA and for the purposes set out in this Privacy Statement. If you are an EU person by accessing our Website or BrainAhead program, you are freely giving, specific, informed and unambiguous indication of your wish and agreement to the processing of your personal information, namely your email and IP address for the legitimate business purposes of this Website only. If you do not wish to provide such consent, then you should not use this Website or if you have inadvertently visited this Website then you may revoke your consent in accordance with this Privacy Statement.

We may change our Privacy Statement at any time, without notice to you. You are responsible and encouraged to review the Privacy Statement regularly.

Information Gathering and Usage

We collect, use and analyse information on the visitor portion and member portion of our Website for the following purposes:

(a) to provide access to our BrainAhead program through our registration process;
(b) to communicate with you as a member who has a program account including sending relevant emails and communications that may be of interest to you when you have opted in to receive such communications;
(c) to customize the user experience;
(d) to provide user support for our BrainAhead program;
(e) to measure and improve our services and BrainAhead program;
(f) to enforce our agreements, terms conditions and policies;
(g) to investigate a suspected violation of our Terms of Service, fraud or other unlawful activity or as required by law or court order
(h) to allow third party providers to provide features on our behalf; or
(i) to address changes in our company such as reorganization, merger, sale, bankruptcy or other business change.

We collect personal emails and IP addresses of those who visit our Website or complete the registration process and become a member entitled with a program account to access our BrainAhead program. For visitors to our Website, we collect IP addresses and only store for short periods of time for security purposes only. We also collect email addresses of those individuals who register as members under a program account to access our BrainAhead program. These emails are used as the username to access our BrainAhead program.

We also collect, use and aggregate the following information from individuals who use our registration process to register as members and set up a program account such as: first name, last name, email address, which school they reside in, user type (educator/school or other), “where you hear about use, postal code, organization, where each user is at in the program, any notes users make in the database, anything a user saves on our platform.

If you are an educator and have a program account for the BrainAhead program, we may also collect information regarding class name, grade level and number of students. Note, we do not allow students to register for a program account and therefore we do not collect information concerning students. If you are a parent and choose to register for a program account, we collect your email to send a verification email for the program account and send updates to the BrainAhead Program. Note, we do allow children to access our BrainAhead program through a parent program account. We do not knowingly collect personal information from children, nor do we knowingly request or solicit personal information from children under the age of 13 years. If you purchase other add ons to our BrainAhead program or other services, we will collect your email.

Under GDPR, for EU visitors who register as a member and set up a program account, we function as “data controller” when you access our Website and BrainAhead program through your program account or when we process personal information from our school customers, teachers, parents and other users in order to provide our BrainAhead program to our users. In accordance with our Privacy Code, EU residents, we recognize that you have the following additional rights with respect to the handling of your personal information: (a) you have the right to obtain confirmation from us about whether your personal information/data is processed, the purpose of the processing, what categories of personal information/data is being processed and who the personal information/data is being disclosed to; (b) right to have your personal information/data to be erased under certain circumstances; (c) right to restriction processing of your personal information/data under certain circumstances; (d) right to receive your personal information/data in structured, commonly used, machine readable form and to move it to another entity; (e) right to object to how personal information/data is being processed.

Individuals who register as members on our Website are responsible for setting their own password for use on our Website. We do not collect and save passwords and use “forgot password link” for those who forget their password.

All personal information, we collect on our Website is used for legitimate business and or security purposes to improve the quality of our BrainAhead program and Website and to estimate volume, demographic and traffic to our Website. We do not share with or sell to other organizations for any commercial purposes with the exception for the following purposes: (a) to provide access and payment for our BrainAhead program which you've requested and licensed pursuant to our online license agreement; or (b) when we have your permission; or (c) where it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Use, or as otherwise required by law.

If we use any third party service providers, such as web hosting, there may be a need to provide access to your information with such third party service providers however such access will be limited to access to perform such services for us and for legitimate business purposes. We may also share aggregated and non-personal information with third parties such as schools or school districts to assist in improving our BrainAhead program.

We collect, use and disclose personal information on our Website or through our BrainAhead program in accordance with our privacy code available at http://brainahead.net including for an individual’s personal information collected, used, disclosed or processed by this Website or our BrainAhead program. Our privacy code sets out an individual’s right to be informed, right to access, right to correction of personal information, right to erasure, right to restriction of processing, right to data portability, right to object to data processing activities and right understand the logic behind automated decision making of such processing of personal information.

Cookies, Web Beacons and Log Files

We use our own cookies or third-party cookies from entities we work with on our Website to administer, analyse and customize our BrainAhead program for our users.

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site's computers and stored on your computer's hard drive. We may also use web beacons which are tiny graphics that also act as unique identifier together with cookies.

Our cookies and web beacons allow us to recognize your browser, login information and aggregate visiting information. Our cookies could be sessional meaning the cookie generally last if you use your browser or permanent cookies that stay on your computer or some cookies that are necessary to use our Website. If you disable, the cookies necessary to log on to our BrainAhead program, then you will not be able to use our program.

Disabling or Deleting Cookies

You may disable or delete our cookies or third-party cookies by changing your cookie settings within your browser (Internet Explorer, Google Chrome). If you have any questions or concerns about our cookies or other similar technologies, please email us at support@brain1st.ca.

Automatically collected information

Like most standard website servers, we use log files to collect information, for up to 30 days storage of log files in case something goes wrong, such as the registration process or our Mailchimp server goes down. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp and number of clicks to analyze trends, such as times spent on each page, device ID, operating system, where a user navigates or clicks on the Website, to administer the Website or BrainAhead program, track user’s movement in aggregate and gather broad demographic information for aggregate use. However, we do not link IP addresses to personal information.

Information Disclosure

UNDER NO CIRCUMSTANCES DOES BrainAhead PROGRAM INC. RENT OR SELL PERSONAL INFORMATION OF OUR USERS TO THIRD PARTIES.

Commercial Electronic Message {CEMs (SPAM} -Compliance with Canada’s Anti-Spam Legislation (CASL)

We offer a number of online ad electronic communications for members with a program account including email newsletters, feedback or survey forms. However, at no time will we send any CEMs to you without your explicit consent. When you complete our registration process, we will request your consent to sending certain commercial electronic messages to you. If you are no longer interested in receiving e-mail and/or other communications from us after providing consent, please e-mail your request to support@brain1st.ca. Please include your complete name and mailing address (as well as your e-mail address) if you prefer not to receive direct materials or commercial e.

REVOCATION OR OPTING OUT OF CONSENT

If you visit our Website or use our BrainAhead program as teacher, parent, teacher or other users and are an European user, you may revoke consent to use your personal information at any time by emailing support@brain1st.ca. For all other teachers, parents, teachers or users, you have a choice to withdraw your consent to use of your personal information. If you wish to opt out of the use of your personal information, please send an email to support@brain1st.ca. By revoking or opting out of your consent to use your personal information, we will remove your personal information from our system and remove from our database as soon as possible but no later than 30 days from the request.

LINKS, THIRD-PARTY TRACKING AND COMMUNITY OR SOCIAL NETWORK FEATURES

In the event that this Website or BrainAhead program contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Statement applies solely to www.brain1stprogram.com and does not apply to any of the third- party links located on our Website or BrainAhead program.

We use a third-party payment processor, STRIPE, to process program payments but we do not collect your credit card information of individuals as this information is collected by the third-party payment processor. We do not participate in any targeted advertising however as we are an online program, we have no control over the Internet and any advertising networks, online web analytics or social networking platforms that may collect information on your online activities using various tracking technologies.

We may have features on our Website and or BrainAhead program that allow you to read, comment or share information or posts. We have no control or responsibility in the event that you choose to share such information on other social networking sites and whether those social networking sites in turn share this information with associated social networks or third parties. You will be governed by those sites you choose to share such information and their privacy terms.

RETENTION AND SECURITY OF INFORMATION

We only retain your information until the purpose of the collection and use is fulfilled. If you are a member with a program account for BrainAhead program, we only retain information for the period that the program account is active and once the program account becomes inactive, we delete the program account and your information from our system within 12 months of inactivity of any program account. Once a program account has been deleted, this program account cannot be retrieved. We do however retain aggregated non-personal information.

We are committed to the protection and security of your information that is collected and used on our Website or BrainAhead program using commercially reasonable means however as we offer our BrainAhead program through the Internet which is not secure, we cannot guarantee the security of your information and therefore the use of our online BrainAhead program is at your own risk and you acknowledge and accept such risks. We therefore do not warrant or represent the security of the information you disclose or transmit to us. It is your responsibility to protect and safeguard any passwords or related mechanisms associated with your use of our BrainAhead program including maintaining the confidentiality of your password as well as any credentials of any other users using your program account. Please notify us immediately should there be any unauthorized use of your program account at support@brain1st.ca.

Contact Information

If users have any questions, concerns or suggestions regarding our privacy practices, please contact us at:

Email: support@brain1st.ca

Website URL: www.brain1st.ca

Questions

Any questions about this Privacy Statement should be addressed to support@brain1st.ca