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Privacy Policy

Version 2.1. Last modified: Apr 30, 2018

We respect the privacy of every customer; therefore, we follow several integral principles. We are considerate to the personal data you share with us through the operations of our service. We keep your personal information for no longer we really need it or when it is required by law. It is always easy to observe and control what information is shared publicly (or kept private), indexed by search engines, and permanently deleted. The process of gathering, using, and sharing your personal information is totally transparent. Our Privacy Policy below incorporates and clarifies the mentioned principles. If you have any unresolved privacy or data use concern, please contact us dpo@brainrouter.com

Who We Are and What This Privacy Policy Covers

We are the folks behind this website. We are the company BrainRouter LTD.

This Privacy Policy applies to information that we collect about you when you use:

  • Our website – csadepts.com;
  • Our mobile applications (either for Android and iOS);
  • Other products and services that are available on or through our websites.

Throughout this Privacy Policy we’ll refer to our website, mobile applications and other products and services collectively as “Services.”

We are committed to protect and respect your privacy. This Privacy Policy sets out how we may use, process and store your personal information. If such personal information can directly or indirectly refer to you as a natural person, such information consists your “Personal Data” and shall be protected by us with a strict accuracy. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

If you have any questions about this Privacy Policy, please contact us.

How We Can Receive Your Information

We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. Your permission and consent can be collected by us directly, or we may receive your personal information from third parties whom you have given consent to pass this information on to us.

Information we collect about you

If you visit our website or member communities, we may automatically collect information about you, for example:

  • Technical information
  • IP addresses
  • Information about what type of device you use to connect to our website
  • How you interact with our website.

For more information read our Cookie Policy.

Here you can find the types of the Personal Data we collect and the purposes of its processing.

#
Personal information types
Purposes we collect your information for
1
User’s Country
  • verification of the User
  • prevention of fraudulent use and resale of User’s accounts
  • tax implications, VAT purposes
2
User’s email
  • the main contact of communication with User
  • to provide you with marketing and promotional materials

Privacy disclaimer: We do NOT store our customer's financial information: nor credit card details, nor any other sensitive payment data.

Why do we collect Personal Data?

We collect information for the some or all of following reasons:

  • To provide services to you after you have ordered one of our services through the website;
  • To provide information about products or services you have shown interest in purchasing within a reasonable time afterwards, if you are already an existing customer;
  • To provide information to you about products or services you have purchased from us, or related products or services;
  • To provide services to you under contract;
  • For legal reasons, for example, if you have entered into a contract with us;
  • To provide information to you about our products and services if you have consented to receive it.

Grounds of collecting information from you

We may collect information from you when we have a legal reason (allowed by law or under contract) to collect the information, or when you have consented for us to do so for a specific purpose (e.g. services provision or newsletters).

Legal basis we have for processing your personal data

We may process your personal data because:

  • We have a contract with you;
  • You have given us permission to do so;
  • We must provide services to you because you have ordered them;
  • You have asked us to do so;
  • To comply with the law.

All of these reasons are reasons we may legally process the information we have about you.

Ways of giving information

You may give us information about you with your consent, for example:

  • By filling in a form or sending us an e-mail;
  • By posting an order at the website;
  • Posting reviews and feedbacks at the website;

This information may be personal, financial, educational, or related to your order.

You may give us information for legal reasons, such as to enter into a contract with us, when you are buying services from us.

Information we receive from other sources

We may receive information about you if you use any of the other websites we operate, any other services we provide, or from our business partners entitled to collect information on our behalf.

We also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, background checking agencies) and may receive information about you from them as part of the service we provide you, or for other legal reasons.

Files. We may collect and store the files you upload, download, or access with the Website. Please do not share with us the files you are not permitted to use. Please do not upload or share with us the files that contain your personal information or personal information of third parties without permission. We may not guarantee that such personal information will be secured.

Who might we share your information with?

We may share your personal data with third parties, either because you have consented to allow us to do so or for other legal reasons. For example, we may share your personal information with:

  • Our marketing staff to provide you with promotional materials after you have registered at our website;
  • Our group companies, which means our subsidiaries, or our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
  • Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you;
  • With third parties because you have given consent;
  • With third parties who provide us services because you have purchased goods or services.

Other reasons we may share your personal information with a third party

If BrainRouter LTD or substantially all its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets of the company.

In addition, we will share your personal data with third parties for the following reasons:

  • If we must comply with a legal obligation;
  • If it is legally requested by government agency;
  • To enforce or apply our Website Terms of Use or other agreements;
  • To protect the rights, property, or safety of BrainRouter LTD, our customers or others;
  • If exchange information with third parties aimed to prevent fraud or to reduce our credit risks.

Aggregated or anonymized data

We may, from time to time, provide third parties with data that has been aggregated or anonymized.

This means that your personal information that could be used to identify you have been removed from the data. Data provided to third parties in this way is not personal data and is only statistics or similar data; however, you do keep your right to object.

Where we store and process your personal data

We primarily store and process your personal data in the EU/European Economic Area or USA (“EEA”). By accepting this Privacy Policy you give us the right to store your personal data in other states if we have servers or storages outside the EEA. We assure you that all your data is encrypted in secure way and no unauthorized persons may access them.

Some examples of reasons your data may be processed outside of the EEA include:

  • Order fulfilment;
  • Payment processing;
  • Technical support services.

If your personal data cannot be processed within the EEA, we will:

  • Comply with all data protection principles;
  • Where possible, choose a country that is on the list of the EU Commissions’ countries that provide adequate protection for the rights and freedoms of data subjects;
  • If the transfer is to the United States of America, we will use reasonable endeavors to make sure they participate in the Privacy Shield program;
  • Make sure we have assessed the adequacy of protections in all other cases.

Access to your personal data via password

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Transmission and storage of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data as it is transmitted and stored, however we shall use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data.

How long will we keep your personal data?

We will not retain your Personal Data for longer than required.

We will keep your personal information:

  • For as long as required by law
  • Until we no longer have a valid reason for keeping it
  • Until you request us to stop using it or delete it.

We may keep just enough of your Personal Data to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer, or for tax purposes etc.

If you have questions about our Data Retention Policy, we can provide you a copy. Please contact: dpo@brainrouter.com

If you chose not to give your personal information to us

If the Personal Data is necessary in order to provide services to you under a contract between you and BrainRouter LTD, we will have to refuse entering into that contract or providing the services before you give us your personal information.

Your Rights

We will respect your legal rights to your Personal Data.

Below are the rights that you have under law, and what we do to protect those rights:

Legal right What we do to protect your rights
The right to be informed
We are publishing this Privacy Policy to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data. We will also answer all your questions regarding this Policy send to the dpo@brainrouter.com
The right to access
You have the right to access your information. Please contact our Data Protection Officer at dpo@brainrouter.com if you wish to access the personal information we hold about you.
The right to rectification
If the information we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information:  dpo@brainrouter.com
The right to erasure
This is sometimes called ‘the right to be forgotten’. If you want us to erase all your personal data and we do not have any legal reason to continue to process and hold it, please contact our Data Protection Officer: dpo@brainrouter.com
The right to restrict processing
You have the right to ask us to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact our Data Protection Officer: dpo@brainrouter.com
The right to data portability
We must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. Please contact our Data Protection Officer if you want information how to port your data elsewhere: dpo@brainrouter.com This right only applies to personal data that you have provided to us as the Data Controller. The data must be held by us by consent or for the performance of a contract.
The right to object
You have the right to object to us processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless statistics. If you wish to object, please contact our Data Protection Officer: dpo@brainrouter.com
The right to withdraw consent
If you have given us your consent to process your data but have changed your mind later, you have the right to withdraw your consent at any time, and we must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: dpo@brainrouter.com
The right to complain to a Supervisory Authority
You have the right to complain to the ICO if you feel that we have not responded to your requests to solve a problem. You can find their contact details here: https://ico.org.uk/concerns/

Links to Other Websites

From time to time, our website may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Age Limitations

To the extent prohibited by applicable law, we do not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review them to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Website. If you disagree with the changes to this Privacy Policy, you should deactivate your account.

 

TERMS AND CONDITIONS

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website at this page

 

YOUR CONSENT

By using our site, you consent to our privacy policy and all terms and conditions as found at this page.

 

The Laws and Regulations

The laws that govern personal data in the UK are:

  • The Data Protection Act (1998)
  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing General Data Protection Regulation (“GDPR”).

The independent authority that upholds information rights in the public interest in the United Kingdom is the Information Commissioner’s Office (the “ICO”). Further information can be found at https://ico.org.uk.