BrainGears.app Privacy Policy
Type of website: Online Counseling and digital courses
Effective date: 7th day of June, 2024
BrainGears.app (the "Site") is owned and operated by Dr. L B M Filion. Dr. L B M Filion is the
data controller and can be contacted at:
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Purpose
The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the
following:
1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected;
4. The rights of Site users; and
5. The Site's cookie policy.
This Privacy Policy applies in addition to the terms and conditions of our Site.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European
Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation
(the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data
Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of
controllers and processors required to appoint a Data Protection Officer under Article 37 of the
GDPR.
Consent
By using our Site users agree that they consent to:
1. The conditions set out in this Privacy Policy.
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Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for
doing so under Article 6 of the GDPR.
We rely on the following legal basis to collect and process the personal data of users in the EU:
1. Processing of user personal data is necessary for us to take, at the request of a user, steps
before entering a contract or for the performance of a contract to which a user is a party. If a
user does not provide the the personal data necessary to perform a contract the consequences
are as follows: Cannot proceed.
Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not
collect any additional data beyond the data listed below without notifying you first.
If you choose not to provide us with the personal data listed below, or if we are unable to collect
that data, we may not be able to provide you with certain services or information, or may not be able
to carry out an activity you have requested.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
1. First and last name;
2. Email address; and
3. Payment information.
This data may be collected using the following methods:
1. Creating an account.
How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or
indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in
this Privacy Policy.
The data we collect when the user performs certain functions may be used for the following
purposes:
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1. To process the order.
Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user
data to achieve the purposes set out in this Privacy Policy.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:
1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protect our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for
and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.
You will be notified if your data is kept for longer than this period.
How We Protect Your Personal Data
To protect your security, we use the strongest browser encryption and store all of our data on
servers in secure facilities. All data is only accessible to our employees, who are bound by strict
confidentiality agreements. A breach of this agreement would result in the employee's termination.
While we take all reasonable precautions to ensure that user data is secure and that users are
protected, there always remains the risk of harm. The Internet as a whole can be insecure at times
and therefore we are unable to guarantee the security of user data beyond what is reasonably
practical.
For questions and concerns, please email at [email protected]. Thank you.