BrainBot

SUMMARY

Bigger Brains collects usage information as well as answers or other responses entered during knowledge checks, BrainBot interactions, and forms.
Administrators and/or Teachers for your organization may run reports to view and/or download usage and response information collected.
Bigger Brains does not otherwise share any personally identifiable information with third parties, for marketing or any other purpose, except as required by law.

SCOPE OF THIS POLICY

This Privacy Policy will inform you of how we look after your personal information when you visit our website www.Bigger Brains.ai, engage with us in any other way, how we process our clients’ personal information when we provide our services and tell you about your privacy rights.

We are Bigger Brains (company name TripleTech LLC and referred to as “Bigger Brains”, “we”, “us” or “our” in this Privacy Policy). Bigger Brains is the controller of your personal information and responsible for this website, our registered address is 1520 E. Greenville St, Suite D, Anderson, SC 29621.

PERSONAL INFORMATION

“Personal information” is any information about an individual that can directly or indirectly distinguish or trace an individual’s identity, associate or link an individual to private information, distinguish one person from another, or be used to re-identify anonymous data.

Personal information is also known as Personal information, Private Information, or Personally Identifiable Information. In some instances, organization (business) information is also considered personal information. This information may be stored both electronically and in physical documents. Personal Information may include, but is not limited to, a name, email address, IP address, credit card number, Username, password, cookies and other similar information. Bigger Brains describes the Personal Information we collect in the sections below.

CHILDREN’S PRIVACY AND SENSITIVE DATA

Children:

Bigger Brains does not knowingly collect Personal Information from children under the age of 13 unless their legal representative consent to their use of our website. If we become aware that a user is under the age of 13 and without the legal representative consent, Bigger Brains will terminate any account that user may have with it. If Bigger Brains becomes aware that it has inadvertently received Personal Information from a child under the age of 13, Bigger Brains will delete such information from its records.

Sensitive data:

We do not collect or receive any sensitive categories of personal data.

TYPES OF INFORMATION WE COLLECT

We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate information.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

Identity Data includes username or similar identifier.
Contact Data includes email address.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Social Media Data
Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Bigger Brains does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We use different methods to collect data from and about you including through:

Direct interactions:

You may give us your Identity, Contact, Profile, Transaction, Technical and Usage data.

Automated technologies or interactions:

As you interact with our website or any device application through which you may access our services (including eLearning courses), we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies.

Third parties or publicly available sources:

We may receive personal information about you from various third parties and public sources including, but not limited to:

Companies that introduce you to us.
Analytics providers and advertisers.
Media outlets (including social media outlets).

HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Personal Information:

We primarily use the identification information you voluntarily share with us to:

Customize your learning experiences and to carry out your online requests.
Allow administrators or teachers who use our tools to deliver training or assessments to you, to be able to run reports on usage and scoring for those trainings and assessments.
Tell you about our courses, products, services and other offerings.
Contact you for a variety of reasons, such as providing you promotional or marketing information for our service.
Communicate with you.
In certain instances, we may also share your personally identifiable information with our third-party vendors, such as Microsoft, and marketing partners. Our vendors agree to use this information, and we share information with them, only to carry out our requests.
As for usage tracking data, we primarily use that information to operate and improve our consumer applications, and to further our marketing efforts. You may opt-out from receiving future promotional or marketing information from us, our affiliated companies, and our third-party vendors, or direct that we do not share your information with any affiliated companies or third-party vendors.

Except as provided in this Privacy Policy, our Terms of Use, or as set forth when you submit the information, your personally identifiable information will not be sold to any third parties or used in any manner outside the scope of this Privacy Policy without your prior approval. We further reserve the right to disclose your information under limited circumstances, such as to cooperate with law enforcement or judicial authorities as required by law or legal process, to protect our own legal rights, or to protect the public good.

Non-Personal identifiable information (Non-PII):

We use Non-PII in a variety of ways, including to:

Help analyse site traffic, understand customer needs and trends.
Carry out targeted promotional activities.
Improve our services.

We may use your Non-PII by itself or aggregate it with information we have obtained from others. We may share your Non-PII with our affiliated companies and third parties to achieve these objectives and others but remember that aggregate information is anonymous information that does not personally identify you. Whenever you are online or on our applications, you run the risk that the information you provide will fall into the wrong hands.

Although we implement and maintain commercially reasonable security procedures and practices to safeguard your privacy, we cannot guarantee the security of any information you provide to us. We accept no responsibility or liability for the activities of third parties. By using our consumer applications and applications, you agree to our Terms of Use.

We process your personal information in the United States.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION AND CHANGE OF PURPOSE

If you fail to provide information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, you may not be able to use our services and we will notify you if this is the case at the time.

Change of purpose

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Bigger Brains’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

PROCESSING LOCATION AND THE CUSTOMERS BASED IN THE EUROPEAN UNION

Processing Location

We process your personal information in the United States.

Customers based in the European Union

Whenever we transfer your personal data from data subjects based in the European Union and Switzerland, we ensure a similar a degree of protection similar to the ones granted by the General Data Protection Regulation “GDPR” (a privacy law applicable to consumers residing in the European Economic Area) is afforded by ensuring at least one of the following safeguards is:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

By providing us with your personal data, you expressly consent to our transferring your personal data to countries or jurisdictions which may not provide the same level of data protection as your home country, including without limitation countries or jurisdictions outside the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

In the event that the GDPR is applicable to a specific transaction and/or a specific consumer, any such consumer has the below rights.

Right of access:

You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is processed, and, to request access to the Personal Information.
Right to correct or update:

You have the right to correct or update inaccurate Personal Information about you.
Right to restrict processing:

Under certain circumstances, you have the right to restrict the processing of your Personal Information. In such instances, your Personal Information may only be processed by us for limited purposes.
Right to object:

Under certain circumstances, you have the right to object to the use or processing of your Personal Information where we no longer have a legitimate or legal need to process it; to object to your Personal Information being processed for direct marketing purposes; and object to automated decision making (including profiling) where the decision would have a legal or similarly significant impact on you.
Right to data portability:

Under certain circumstances, you have a right to receive a copy of your Personal Information, which you have provided to us, in a machine-readable format and the right to transmit that Personal Information for use in another party’s service.
Right to be forgotten:

Under certain circumstances, you have the right to request that your Personal Information be erased. Some Personal Information may be in backup archives and/or must be retained for legal or compliance reasons.

We may require that you verify your identity to the exercise of any of these rights. Under certain circumstances, and in the event of a data breach involving your Personal Information that is likely to result in a risk to your rights and freedoms, we are required to notify the applicable supervisory authority within 72 hours after becoming aware of such a breach.

Please note that Bigger Brains may be acting as data controller if a third-party corporate client or teacher, which are deemed “Data Controllers” under GDPR, have referred our Company to you. The Data Controller is responsible for telling our company how your Personal Information should be used or processed in those specific transactions.

SECURITY MEASURES AND RETENTION

Security:

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will store all the personal information you provide on our secure (password- and firewall-protected) servers or on the Microsoft Azure platform.

And we have implemented physical access restrictions for our data centres and authorization controls for data access as part of our information security management system.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

Bigger Brains practices data minimization, meaning our intention is only to collect personal information essential for provision and improvement of our services. Further, our retention and destruction practices keep Personal Information only as long as needed.

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data Retention:

For customers with active accounts on the BrainBot platform, all data is retained indefinitely unless removal is requested in conjunction with Bigger Brains' privacy policies.

For inactive customers, data is retained for a period of 6 months following the account deactivation, after which it may be removed.

Any customer data may be removed at any time if requested by a customer, user, or legal authority as descrived in our removal policy. We maintain a retention procedure which we apply to records in our care. In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Storage:

The BrainBot data storage policy is designed to ensure the secure and responsible storage of all user data. The app will store user data in a centralized, secure location, with restricted access to authorized personnel only. User data will be stored using encryption and other security measures to protect against unauthorized access, data breaches, and other potential security risks.

The app will also implement a data backup and disaster recovery plan, including regular backups of all user data and testing of disaster recovery procedures. Data backups will be stored in a secure location separate from the primary data storage, with appropriate redundancy and off-site storage measures in place to protect against data loss.

BrainBot will regularly review and assess the storage and security measures in place to ensure they are up-to-date and effective. Users will be notified in a timely manner in the event of any data breaches or other security incidents, and appropriate measures will be taken to mitigate the impact of such incidents.

Finally, BrainBot will comply with all relevant laws and regulations governing data storage and security, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Users will have the right to access, correct, and delete their data in accordance with these regulations using the form here: https://getbiggerbrains.com/privacy-policy/

Data archival / removal policy:

BrainBot will retain user data for as long as it is necessary to provide the services and functionality of the app, after which it will be securely deleted. However, some data, such as user progress and achievements, will be retained indefinitely to enable users to access and track their learning history. In addition, BrainBot will maintain an archive of user data for a period of three years after deletion, to comply with legal obligations and potential future audits. The app will take reasonable measures to protect the confidentiality, integrity, and availability of all user data, including limiting access to authorized personnel only, using encryption and secure storage, and regularly testing and updating security measures.

Users can request removal of any Personal Identifiable Information (PII) in compliance with GDPR and similar standards at any time by using the form available at https://getbiggerbrains.com/privacy-policy/

SHARING YOUR PERSONAL INFORMATION

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, sub-processors, agents and suppliers insofar as reasonably necessary for the purposes set out in this notice.

We may need to disclose certain personal information to our Agents or Contractors to enable Bigger Brains to process transactions or communicate with you. Where we do so it will be on the basis that these agents/contractors are required to keep the information confidential and secure, and will not use the information for any other purpose than to carry out the services they are performing for Bigger Brains.

While we will not voluntarily disclose your personal information we may disclose such information if we are required to do so by a law enforcement bodies, regulators or third parties under a legal requirement or valid court order, if we are lawfully requested by government or law enforcement authorities, if we are required to do so pursuant to other legal processes, or if it becomes necessary to protect the rights or property of Bigger Brains.

We may need to disclose certain personal information to our Agents or Contractors to enable Bigger Brains to process transactions or communicate with you. Where we do so it will be on the basis that these agents/contractors are required to keep the information confidential and secure, and will not use the information for any other purpose than to carry out the services they are performing for Bigger Brains.

We may also employ the services of third-party service providers to help us in certain areas, such as website hosting, physical security, marketing and market research. Where third party service providers receive your information, we will remain responsible for the use of your personal information. We take appropriate steps to ensure that such third parties treat your Personal Information with the same consideration that we do.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this website Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Before sharing your personal data with third-parties, Bigger Brains

THIRD-PARTY LINKS

This Privacy Policy applies only to Bigger Brains products, services and information collected by our website; however, our website may contain links to third-party websites, plug-ins and applications such us Twitter, YouTube, Facebook, Slack, and Microsoft.

Please be aware that clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

CHANGES TO THIS PRIVACY POLICY

We keep our Privacy Policy under regular review and may make updates and changes from time to time.

You should check this page occasionally to ensure you are happy with any changes to this notice.

CONTACT US

If you have any questions regarding the policies of this site, including privacy removal requests, please send an email message to: support@bigger-brains.com

For communication via mail or phone: Triple Tech LLC dba Bigger Brains, 1520 E. Greenville St, Suite D, Anderson, SC 29621 USA. +1 864-421-6950

This Privacy Policy was last updated on April 11, 2023