Introduction

This privacy policy covers Cerebro’s (“we,” “us,” or “our”) collection, use, and disclosure of personal information through the Cerebro website (the “Site”) and in various services provided by Cerebro to its clients. This privacy policy also describes your rights and choices with respect to your personal information. If you have any questions about this privacy policy, please contact us at hello@thecerebro.net.

Our Site may include links to other websites whose privacy practices may differ from those of Cerebro. If you submit information to any of those third-party websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

For the purposes of data protection laws and regulations, Cerebro may be a controller, joint controller, or co-controller of the Personal Data (as defined below) we hold about you (i.e., Cerebro is responsible for, and controls the processing of your Personal Data) or a processor, depending on the service, data, or how Cerebro is situated with respect to its clients and you.

Information Collection

Under data protection laws and regulations, some of the information processed by Cerebro is defined as “Personal Data”, which means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The categories of information we may collect include:

• Personal information about website visitors and prospective clients or partners. We collect personal information from website visitors and prospective clients or partners who contact us through our Site. In this context, we may collect your first and last name, phone number, email address, and any other information that you voluntarily submit to us through our “Contact Us” form, Cerebro Link Interest Form, or other means of communication.
• Personal information about prospective employees. We collect information about prospective employees when they submit a job application form on our Site. For example, we may collect an applicant’s first and last name, phone number, email address, city and country of residence, and any other personal information that the applicant voluntarily submits to us, such as information contained in a cover letter, resume, or curriculum vitae.
• Other information collected via passive collection and tracking technologies. Like most websites, in addition to the personal information described above, we also gather certain other information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, general location, and/or clickstream data. We and our third-party service providers may collect such information using the following technologies:
  • Server Logs. When you use the Site, we automatically receive and record certain information from your computer (or another device) and your web browser. To collect such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
  • Cookies and similar technologies. Cerebro and our service providers use cookies and similar technologies to analyze trends, administer the Site, track users’ movements around the Site, and gather information about our user base as a whole. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete existing cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

We may partner with certain third parties to collect other information to engage in analytics, auditing, research, and reporting. These third parties may use server logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for analytics purposes.

We may also embed videos or other media hosted by a third party on our Site. The third party may use cookies, pixel tags, or similar technologies in order to provide you advertising based upon your browsing activities over time and across unaffiliated websites, as well as your inferred commercial interests.

We may combine the information that we collect with additional information that we or third parties collect in other contexts, such as our communications with you via email or phone, or your customer service records. In those circumstances, we will treat the combined information in accordance with this privacy policy.

Information Use

Cerebro uses the information that it collects for a variety of purposes, including to:

• Contact our clients and partners or prospective clients and partners, respond to requests for information about Cerebro, and send marketing emails, which include clear and conspicuous instructions to unsubscribe from future marketing emails;
• Administer the Site, conduct internal auditing, and troubleshoot technical or user issues on the Site;
• Count and recognize visitors and users of the Site and analyze how individuals use our services;
• Improve our existing products and services or create new products and services.
• Prevent and detect fraud and other activities that may violate Cerebro’s policies in order to protect the security of Cerebro, our property or the property or physical safety of any person or third party;
• Generate and analyze trends in the aggregate; and
• Comply with legal and/or regulatory requirements.

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

We may aggregate any of the personal information we collect (so that it does not directly identify you).

Information Disclosure

Cerebro may disclose the information that it collects to third parties for a variety of purposes, such as:

• Affiliates. We may share personal information with our corporate affiliates for the purposes described in this privacy policy.
• Third-party service providers. We may use third-party service providers to help us provide our services, such as managing and maintaining our information systems. These service providers may collect and/or use your personal information to assist us in carrying out the purposes discussed in this privacy policy. Transfers to subsequent third parties are covered by the provisions in this privacy policy regarding notice and choice and the service agreements with our clients. For the avoidance of doubt, Cerebro does not share information about the original or current provider of your telephone number with any recipients.
• Third-party plugins. Our Site may integrate certain third-party plug-ins (such as a Facebook “Like” button and Twitter “Follow” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.
• Legal purposes. We may use or disclose your personal information to third parties when we believe, in our sole discretion, that doing so is necessary:
  • To comply with applicable laws or a court order, request from government or law enforcement, or other legal process;
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • To establish, protect, or exercise our legal rights or defend against legal claims; or
• De-identified or aggregated information. Cerebro also may share de-identified and/or aggregated information about users of our services, such as by publishing a report on trends in the usage of the Sites.

Your Rights and Choices

You may have the following rights in respect of your personal information that we hold:

1. Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.
2. Right of access. The right to obtain access to your personal information.
3. Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
4. Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
5. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
6. Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organization to another.

For your protection, we might only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request.

Data Retention and Access

Cerebro will retain information for as long as reasonably necessary to accomplish the purposes described in this privacy policy. Cerebro also will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Security

The security of your personal information is important to us. We use commercially reasonable physical, technical, and administrative safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal Information.

Children’s Privacy

The Site is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If you are under the age of 16, please do not use the Site or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on this Site prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.

Contact Us

If you have questions regarding our privacy policies, please contact us at hello@thecerebro.net.