THE EXTRAORDINARY BRAIN PTY LTD / GILBERTO SPENCER
Thank you for visiting TheFASDBrain.com (hereinafter “Website,” “Site,”), owned by “The Extraordinary Brain Pty Ltd” (hereinafter, “Company,” “we,” “us,” “our”), an Australian based company.
Please see the Company’s contact information at the bottom of this privacy statement should you have any questions.
We respect and value the privacy of everyone who visits our Site and will only collect and use information in a manner consistent with your rights and our obligations under the law.
Please read this statement carefully as it is intended to help you understand the types of information we collect, why we collect it, and the ways you can manage any personal information we may collect about you.
It is important to us that you make a reasonably informed decision as to whether to continue reading the information provided on this website and whether you ultimately choose to share any of your personal information with us.
Unique identifiers can be used for various purposes, including remembering your browsing preferences, your purchase history, directing advertising specifically to you, collecting information about your browsing history, as well as determining whether emails sent to you by us were received and/or opened.
We also use the information we collect from your use of our existing programs and services to help us develop new ones, and at times to send you personalized ads based on your particular interests. However, we do not use sensitive information such as race, sexual orientation, religion, or health, to determine which ads we send you, and we do not collect genetic or biometric data (ex., fingerprints, retina patterns, voice waves).
Unique identifiers are sometimes stored in “cookies” (see below) to help websites display certain content in your browser, and to remember, for example, your preferred language.
WHY WE COLLECT AND STORE INFORMATION FROM YOUR COMPUTER
As indicated above, data regarding your computer hardware and software, including your IP address, browser, dates and times of access, domain names, and websites that referred you here, may be collected by the Site for purposes of improving the quality of the information and services provided; to understand our visitors’ preferences; to make improvements to our visitors’ overall experience of this website; and to personalize this experience where doing so would improve the enjoyment of the Site.
With the data we collect from your computer hardware and software, we are able to learn about the number of visitors to our Site and the types of technology visitors use on our Site. However, we do not track or record information about individuals and their visits (unless they are willingly participating in one of our programs) and we do not share this data with anyone outside the Company unless necessary for law enforcement purposes (see “disclosure exceptions” below). In other words, while we may be tracking what your computer is doing, we are not tracking the various individuals that may be using a particular computer unless they have identified themselves as a participant in one of our programs.
INTERACTING WITH YOU
The information we collect from you, specifically your email address, is used to interact with you directly, however it is a privilege we do not take for granted. While we may use your data for marketing purposes, which may include contacting you by email with information, news and offers about our products and services from time to time, we will not send you any unsolicited marketing materials or spam and promise to take all reasonable steps to ensure that your privacy rights are protected.
If you’re already a client, we use your information to communicate with you directly as a method of providing information about how to use our programs.
You always have the option to unsubscribe from all mailings by clicking the “unsubscribe” link at the bottom of all emails we send. You may also email us directly about your privacy preferences. (See our contact information below.)
PROCESSING YOUR PERSONAL DATA
Your Personal Data will be processed by us only if we have a lawful basis for doing so. “Processing” generally includes actions that can be performed in connection with data such as collection, use, storage and disclosure. Lawful bases for processing data include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
First and last name
Access to content (such as classes, membership, or courses)
Legitimate Interest: We may process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
First and last name
Your activity on the Services, including class usage information and community interaction data
Examples of these legitimate interests include:
Operation and improvement of our business, products and services
Personalization of web content on the Service
Analyzing the use of the Services
Marketing of our products and services
Provision of customer support
Protection from fraud or security threats
Compliance with legal obligations
Completion of corporate transactions
Consent: In most cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
GATHERING PERSONAL DATA WITH YOUR CONSENT
Personal information that uniquely identifies you is only gathered with your explicit authorization and only in exchange for information, products, or services, whether free or paid. Be advised that if you choose not to provide this information you will not be able to receive information, products, or services offered by us to you as we will not have the means to deliver it to you.
We will only process your personal data if at least one of the following applies:
You have given consent to the processing of your personal data;
Processing is necessary for the performance of a contract to which you are a party;
Processing is necessary for compliance with a legal obligation to which we are subject;
Processing is necessary to protect the vital interests of you or of another natural person;
Processing is necessary for the performance of a task carried out in the public interest; and/or
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by one’s privacy rights or where the data subject is a child.
You always have ultimate control over the information you receive from us. Note that some of your information may be shared with third party payment processors and credit card companies in order to process payment transactions and the delivery of our products and/or services to you.
We will never intentionally disclose any information regarding your personal identification to any third party without your consent. If you choose to provide us with such information, you agree to receive information, products, or services from this website.
If at any time you wish to opt-out, or unsubscribe, you may do so by clicking “unsubscribe” at the bottom of any email you receive from us, or by notifying the Company directly. See our contact information below. Rest assured that you always have the ability to manage your contact information.
NOTE: We may share information that does not include a unique identifier and would not reasonably be considered “personal data” in that it does not include information that would allow anyone to identify you as an individual. For example, advertisers or outside services may use non-personal data to enhance the experience of a visitor to their websites.
THIRD PARTY ANALYTICS SERVICE PROVIDERS
As indicated above, this Website may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of the Website and viewing of content on the Site.
We use Google Analytics to gather data that allows us to understand how our website and the services we offer are being used, and to improve both our website visitor and client experiences.
OPTING OUT OF GOOGLE ANALYTICS TRACKING
You can install the Google Analytics Opt-out Browser Add-on by clicking here.
We strictly abide by Facebook’s Data Use Restrictions when advertising on Facebook.
DATA COLLECTION TECHNOLOGIES WE USE
We may use various technologies to collect and store information, including cookies, (text files placed on your hard drive by our server to store information about the way you use our Site so that it can recall that information in order to personalize your next visit).
Certain features of our Site may depend on cookies to function. These Cookies are deemed to be “strictly necessary” under the most stringent privacy laws, including the European Union’s GDPR (see below).
You may also choose to delete cookies at any time however you will likely lose any information that enables you to access our Site more quickly and efficiently.
DATA OBTAINED FROM THIRD PARTIES
We follow what are considered generally accepted industry standards to protect the personal data submitted to us, however no method of transmission or electronic storage can ever be 100% secure. For this reason we cannot guarantee the absolute security of such data.
The Company may obtain data indirectly from third parties such as social networks and other public sources, including public databases.
The transmission of any sensitive information (such as credit card number) you provide to us on order forms that are hosted by third party service providers is encrypted using secure socket layer technology (SSL).
RETENTION AND STORAGE OF YOUR PERSONAL INFORMATION
The Company retains your personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, as well as to comply with applicable laws. You may make a request to remove any and all data collected by us. See our contact information below.
We take appropriate technical and organizational measures to ensure a level of security appropriate to the level of risk.
This website will disclose your personal information, without notice, but only if:
It is required to do so by law;
As required by service of process;
To defend our rights and property;
To protect the personal safety of visitors to this website.
IN THE EVENT OF A PERSONAL DATA BREACH
Should there be a breach of personal data, the Company shall notify you and all competent supervisory authorities without undue delay and, where feasible, not later than 72 hours after having become aware of such a breach.
DATA PROTECTION LAWS
Data protection laws differ from country to country, with some having greater protections than others. We strive to maintain the highest level of privacy for anyone who shares information with us, regardless of where they reside.
EUROPEAN UNION PERSONAL DATA
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (“GDPR”) with respect to your personal data so as to ensure that it is processed lawfully, fairly, and transparently, without adversely affecting your rights.
Upon request, we agree to provide you with information regarding any of your personal data that we have processed. You always have the right to withdraw your consent, request erasure of any personal information we hold, and/or object to further processing of such information. Please email us at the contact email provided below and put “Attention Privacy Protection Officer” in the subject line. Upon receipt of your email we will cease processing your personal data.
The California Online Privacy Protection Act (CalOPPA) requires California companies to provide an opportunity for California residents to opt-out or unsubscribe from having personal information used by third parties (such as advertisers or affiliated companies) for direct marketing purposes.
This Company is not a California based business and therefore does not honor behavioral advertising opt-out or “do not track” mechanisms. This includes general web browser “Do Not Track” settings and signals.
However, if you are a California resident you may contact us using the contact information below to exercise your disclosure choice options.
CHILDREN: MINIMUM AGE REQUIREMENT
This website complies with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the Internet.
This website is intended for persons eighteen (18) years of age or older. However, per COPPA rules, anyone under the age of thirteen (13) must seek the permission of a parent or guardian before using this website.
Furthermore, this website will not knowingly contact or collect personal information from anyone under 13, and does not intend to solicit information of any kind from persons under the age of 13.
CORRECTING OR UPDATING YOUR INFORMATION
You are invited to help us keep your personal data up to date by notifying us of any changes to your personal information. You may contact us to correct or update your personal information.
HOW TO CONTACT THE COMPANY
Please put “ATTN Privacy Protection Officer” in the subject line.
UPDATED: May 22, 2020