Last updated March 18, 2023
This privacy notice for
BotBrains
( ' Company
', 'we', 'us', or
'our'
), describes how and why we might collect, store, use, and/or
share ( 'process' ) your
information when you use our services ( 'Services' ), such as when you:
- Visit our website
at https://botbrains.app , or any website of ours that links to this privacy notice
- Engage with us in
other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will
help you understand your privacy rights and choices. If you do not agree with our policies and
practices, please do not use our Services. If you still have any questions or concerns, please contact
us at support@botbrains.app .
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but
you can find out more details about any of these topics by clicking the link following each key point
or by using our table of contents below to find the section you are looking for. You can also
click here to go directly to our table of
contents.
What
personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with
BotBrains
and the Services, the choices you make, and the products
and features you use. Click
here to learn more.
Do we
process any sensitive personal information?
We do not process sensitive personal information.
Do we
receive any information from third parties?
We do not receive any information from third parties.
How do
we process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent. We process your information only when we
have a valid legal reason to do so. Click here to learn more.
In
what situations and with which parties do we share personal
information? We may share information in specific situations and with specific third parties. Click here to learn more.
How do
we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised third parties will not be
able to defeat our security and improperly collect, access, steal, or modify your information.
Click here to learn more.
What
are your rights? Depending on where you are located geographically, the applicable privacy law
may mean you have certain rights regarding your personal information. Click here to learn more.
How do
you exercise your rights? The easiest way to exercise your rights is by filling out our data
subject request form available here
, or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
Want to learn
more about what
BotBrains
does with any information we collect? Click
here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you disclose to
us
In
Short: We collect personal information
that you provide to us.
We collect personal
information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information about
us or our products and Services, when you participate in activities on the Services, or otherwise when
you contact us.
Personal
Information Provided by You. The personal information that we collect depends on the context
of your interactions with us and the Services, the choices you make, and the products and features you
use. The personal information we collect may include the following:
-
names
-
email addresses
-
phone numbers
-
mailing addresses
-
job titles
-
usernames
-
passwords
-
contact preferences
-
contact or authentication data
-
billing addresses
-
debit/credit card numbers
Sensitive Information.
We do not process sensitive information.
Social Media
Login Data. We may provide you with the option to register with us using your existing social
media account details, like your Facebook, Twitter, or other social media account. If you choose to
register in this way, we will collect the information described in the section called ' HOW DO WE
HANDLE YOUR SOCIAL LOGINS?
' below.
All personal
information that you provide to us must be true, complete, and accurate, and you must notify us of any
changes to such personal information.
Information automatically collected
In
Short: Some information — such as your
Internet Protocol (IP) address and/or browser and device characteristics — is collected
automatically when you visit our Services.
We automatically
collect certain information when you visit, use, or navigate the Services. This information does not
reveal your specific identity (like your name or contact information) but may include device and usage
information, such as your IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how and when you use our
Services, and other technical information. This information is primarily needed to maintain the security
and operation of our Services, and for our internal analytics and reporting
purposes.
Like many businesses,
we also collect information through cookies and similar technologies.
The information we
collect includes:
- Log and Usage
Data. Log and usage data is service-related, diagnostic, usage, and performance information our
servers automatically collect when you access or use our Services and which we record in log files.
Depending on how you interact with us, this log data may include your IP address, device information,
browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and
files viewed, searches, and other actions you take such as which features you use), device event
information (such as system activity, error reports (sometimes called
), and hardware settings).
- Device
Data. We collect device data such as information about your computer, phone, tablet, or other
device you use to access the Services. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and application identification numbers,
location, browser type, hardware model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
- Location
Data. We collect location data such as information about your device's location, which can be
either precise or imprecise. How much information we collect depends on the type and settings of the
device you use to access the Services. For example, we may use GPS and other technologies to collect
geolocation data that tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or by disabling
your Location setting on your device. However, if you choose to opt out, you may not be able to use
certain aspects of the Services.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information
for other purposes with your consent.
We process
your personal information for a variety of reasons, depending on how you interact with our Services,
including:
- To
facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well as keep your account in
working order.
- To save or protect an
individual's vital interest. We may process your
information when necessary to save or protect an
individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY
ON TO PROCESS YOUR INFORMATION?
In Short: We
only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e. legal basis) to do so under
applicable law, like with your consent, to comply with laws,
to provide you with services to enter into or fulfil our contractual obligations, to
protect your rights, or to
fulfil our legitimate
business interests.
If you are located
in the EU or UK, this section applies to
you.
The General Data Protection
Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases
to process your personal information:
- Consent. We
may process your information if you have given us permission
(i.e.
consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legal
Obligations. We may process your information
where we believe it is necessary for compliance with our
legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend
our legal rights, or disclose your information as evidence
in litigation in which we are involved.
- Vital Interests.
We may process your information where we believe it is
necessary to protect your vital interests or the vital
interests of a third party, such as situations involving
potential threats to the safety of any
person.
In legal terms, we are generally
the 'data controller' under European data protection
laws of the personal information described in this privacy
notice, since we determine the means and/or purposes of the
data processing we perform. This privacy notice does not
apply to the personal information we process as a 'data processor' on behalf of our customers. In
those situations, the customer that we provide services to
and with whom we have entered into a data processing
agreement is the 'data
controller' responsible for
your personal information, and we merely process your
information on their behalf in accordance with your
instructions. If you want to know more about our customers'
privacy practices, you should read their privacy policies
and direct any questions you have to them.
If you are located
in Canada, this section applies to
you.
We may process your information if
you have given us specific permission (i.e. express consent) to use
your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e. implied consent). You can
withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may
be legally permitted under applicable law to process your
information without your consent, including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud
detection and prevention
- For business transactions
provided certain conditions are met
- If it is contained in a witness
statement and the collection is necessary to assess,
process, or settle an insurance claim
- For identifying injured, ill, or
deceased persons and communicating with next of
kin
- If we have reasonable grounds to
believe an individual has been, is, or may be victim of
financial abuse
- If it is reasonable to expect
collection and use with consent would compromise the
availability or the accuracy of the information and the
collection is reasonable for purposes related to
investigating a breach of an agreement or a contravention
of the laws of Canada or a province
- If disclosure is required to
comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records
- If it was produced by an
individual in the course of their employment, business, or
profession and the collection is consistent with the
purposes for which the information was produced
- If the collection is solely
for journalistic, artistic, or literary purposes
- If the information is
publicly available and is specified by the
regulations
In
Short: We may share information in
specific situations described in this section and/or
with the following
third parties.
We may need to share your
personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In
Short: We may use cookies
and other tracking technologies to collect and
store your
information.
We may use cookies
and similar tracking technologies (like web
beacons and pixels) to access or store
information. Specific information about how we
use such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.
In
Short: If you choose to
register or log in to our Services using a
social media account, we may have access to
certain information about
you.
Our Services offer
you the ability to register and log in using
your third-party social media account details
(like your Facebook or Twitter logins). Where
you choose to do this, we will receive certain
profile information about you from your social
media provider. The profile information we
receive may vary depending on the social media
provider concerned, but will often include your
name, email address, friends list, and profile
picture, as well as other information you choose
to make public on such a social media platform.
We will use the
information we receive only for the purposes
that are described in this privacy notice or
that are otherwise made clear to you on the
relevant Services. Please note that we do not
control, and are not responsible for, other uses
of your personal information by your third-party
social media provider. We recommend that you
review their privacy notice to understand how
they collect, use, and share your personal
information, and how you can set your privacy
preferences on their sites and apps.
7. HOW
LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your
information for as long as necessary to fulfil the purposes
outlined in this privacy notice unless
otherwise required by
law.
We will only keep
your personal information for as long as it is
necessary for the purposes set out in this
privacy notice, unless a longer retention period
is required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in
this notice will require us keeping your
personal information for longer than
the period of
time in which users have an account with us
.
When we have no
ongoing legitimate business need to process your
personal information, we will either delete or
anonymise such information,
or, if this is not possible (for example,
because your personal information has been
stored in backup archives), then we will
securely store your personal information and
isolate it from any further processing until
deletion is possible.
8. HOW DO
WE KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to protect
your personal information through a system of
organisational
and technical security
measures.
We have
implemented appropriate and reasonable technical
and
organisational
security measures designed to protect the
security of any personal information we process.
However, despite our safeguards and efforts to
secure your information, no electronic
transmission over the Internet or information
storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties will
not be able to defeat our security and
improperly collect, access, steal, or modify
your information. Although we will do our best
to protect your personal information,
transmission of personal information to and from
our Services is at your own risk. You should
only access the Services within a secure
environment.
9. WHAT
ARE YOUR PRIVACY
RIGHTS?
In
Short:
In some
regions, such as
the European Economic Area (EEA), United
Kingdom (UK), and Canada , you have
rights that allow you greater access to and
control over your personal information.
You may
review, change, or terminate your account at
any time.
In some regions
(like the
EEA, UK, and Canada
), you have certain rights under
applicable data protection laws. These may
include the right (i) to request access and
obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to
restrict the processing of your personal
information; and (iv) if applicable, to data
portability. In certain circumstances, you may
also have the right to object to the processing
of your personal information. You can make such
a request by contacting us by using the contact
details provided in the section '
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
' below.
We will consider
and act upon any request in accordance with
applicable data protection laws.
If you are located
in the EEA or UK and you believe we are
unlawfully processing your personal information,
you also have the right to complain to your
local data protection supervisory authority. You
can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located
in Switzerland, the contact details for the data
protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your consent: If we are relying
on your consent to process your personal
information,
which may be express and/or implied consent
depending on the applicable law, you
have the right to withdraw your consent at any
time. You can withdraw your consent at any time
by contacting us by using the contact details
provided in the section '
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
' below .
However, please note
that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable
law allows, will
it affect the processing of your personal
information conducted in reliance on lawful
processing grounds other than consent.
Opting
out of marketing and promotional
communications: You
can unsubscribe from our marketing and promotional
communications at any time by clicking on the
unsubscribe link in the emails that we send,
replying 'STOP' or
'UNSUBSCRIBE' to the
SMS messages that we send,
or by
contacting us using the details provided in the
section '
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
' below. You will then
be removed from the marketing lists. However, we
may still communicate with you — for example, to
send you service-related messages that are
necessary for the administration and use of your
account, to respond to service requests, or for
other non-marketing purposes.
Account
Information
If you would at any time
like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
-
Contact us using the contact information provided.
Upon your request to
terminate your account, we will deactivate or
delete your account and information from our
active databases. However, we may retain some
information in our files to prevent fraud,
troubleshoot problems, assist with any
investigations, enforce our legal terms and/or
comply with applicable legal
requirements.
Cookies
and similar technologies: Most
Web browsers are set to accept cookies by
default. If you prefer, you can usually choose
to set your browser to remove cookies and to
reject cookies. If you choose to remove cookies
or reject cookies, this could affect certain
features or services of our Services. To opt out
of interest-based advertising by advertisers on
our Services visit http://www.aboutads.info/choices/.
10.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers
and some mobile operating systems and mobile
applications include a Do-Not-Track ( 'DNT' ) feature or setting
you can activate to signal your privacy
preference not to have data about your online
browsing activities monitored and collected. At
this stage no uniform technology standard for
recognising
and implementing
DNT signals has been finalised . As such, we do not
currently respond to DNT browser signals or any
other mechanism that automatically communicates
your choice not to be tracked online. If a
standard for online tracking is adopted that we
must follow in the future, we will inform you
about that practice in a revised version of this
privacy notice.
11. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY
RIGHTS?
In
Short: Yes, if you are a
resident of California, you are granted
specific rights regarding access to your
personal
information.
California Civil
Code Section 1798.83, also known as the 'Shine The
Light' law,
permits our users who are California residents
to request and obtain from us, once a year and
free of charge, information about categories of
personal information (if any) we disclosed to
third parties for direct marketing purposes and
the names and addresses of all third parties
with which we shared personal information in the
immediately preceding calendar year. If you are
a California resident and would like to make
such a request, please submit your request in
writing to us using the contact information
provided below.
If you are under
18 years of age, reside in California, and have
a registered account with Services, you have the
right to request removal of unwanted data that
you publicly post on the Services. To request
removal of such data, please contact us using
the contact information provided below and
include the email address associated with your
account and a statement that you reside in
California. We will make sure the data is not
publicly displayed on the Services, but please
be aware that the data may not be completely or
comprehensively removed from all our systems
(e.g.
backups, etc.).
CCPA Privacy
Notice
The
California Code of Regulations defines a
'resident'
as:
(1) every
individual who is in the State of California for
other than a temporary or transitory purpose
and
(2) every
individual who is domiciled in the State of
California who is outside the State of
California for a temporary or transitory
purpose
All other
individuals are defined as 'non-residents'.
If this definition
of 'resident'
applies to you,
we must adhere to certain rights and obligations
regarding your personal
information.
What
categories of personal information do we
collect?
We have collected
the following categories of personal information
in the past twelve (12) months:
Category | Examples | Collected |
A.
Identifiers
|
Contact
details, such as real name, alias,
postal address, telephone or mobile
contact number, unique personal
identifier, online identifier, Internet
Protocol address, email address, and
account name
|
|
B.
Personal information categories listed
in the California Customer Records
statute
|
Name,
contact information, education,
employment, employment history, and
financial
information
|
|
C.
Protected classification characteristics
under California or federal
law
|
Gender and
date of birth
|
|
D.
Commercial
information
|
Transaction
information, purchase history, financial
details, and payment
information
|
|
E.
Biometric
information
|
Fingerprints
and voiceprints
|
|
F.
Internet or other similar network
activity
|
Browsing
history, search history, online
|
|
G.
Geolocation data
|
Device
location
|
|
H. Audio,
electronic, visual, thermal, olfactory,
or similar
information
|
Images and
audio, video or call recordings created
in connection with our business
activities
|
|
I.
Professional or employment-related
information
|
Business
contact details in order to provide you
our Services at a business level or job
title, work history, and professional
qualifications if you apply for a job
with us
|
|
J.
Education
Information
|
Student
records and directory
information
|
|
K.
Inferences drawn from other personal
information
|
Inferences
drawn from any of the collected personal
information listed above to create a
profile or summary about, for example,
an individual’s preferences and
characteristics
|
|
L. Sensitive Personal Information |
|
|
We may also
collect other personal information outside of
these categories through instances where you
interact with us in person, online, or by
phone or mail in the context of:
- Receiving help
through our customer support
channels;
- Participation
in customer surveys or contests;
and
- Facilitation
in the delivery of our Services and to
respond to your inquiries.
How do
we use and share your personal
information?
You may contact
us
by email at
support@botbrains.app
,
or by referring to
the contact details at the bottom of this
document.
If you are using
an
authorised agent
to exercise your right to opt out we may deny
a request if the
authorised
agent does not submit proof that they have
been validly
authorised
to act on your behalf.
Will
your information be shared with anyone
else?
We may disclose
your personal information with our service
providers pursuant to a written contract
between us and each service provider. Each
service provider is a for-profit entity that
processes the information on our behalf,
following the same strict privacy protection
obligations mandated by the
CCPA.
We may use your
personal information for our own business
purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be
'selling'
of your
personal information.
Your
rights with respect to your personal
data
Right to
request deletion of the data — Request to
delete
You can ask for
the deletion of your personal information. If
you ask us to delete your personal
information, we will respect your request and
delete your personal information, subject to
certain exceptions provided by law, such as
(but not limited to) the exercise by another
consumer of his or her right to free speech,
our compliance requirements resulting from a
legal obligation, or any processing that may
be required to protect against illegal
activities.
Right to be
informed — Request to
know
Depending on the
circumstances, you have a right to know:
- whether we
collect and use your personal
information;
- the categories
of personal information that we
collect;
- the purposes
for which the collected personal information
is used;
- whether we
sell or share personal information to third
parties;
- the categories
of personal information that we sold,
shared, or disclosed for a business
purpose;
- the categories
of third parties to whom the personal
information was sold, shared, or disclosed
for a business purpose;
- the business
or commercial purpose for collecting,
selling, or sharing personal information;
and
- the specific
pieces of personal information we collected
about you.
In accordance
with applicable law, we are not obligated to
provide or delete consumer information that is
de-identified in response to a consumer
request or to re-identify individual data to
verify a consumer
request.
Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights
We will not
discriminate against you if you exercise your
privacy rights.
Right to Limit Use
and Disclosure of Sensitive Personal
Information
We do not process
consumer's sensitive personal information.
Verification
process
Upon receiving
your request, we will need to verify your
identity to determine you are the same person
about whom we have the information in our
system. These verification efforts require us
to ask you to provide information so that we
can match it with information you have
previously provided us. For instance,
depending on the type of request you submit,
we may ask you to provide certain information
so that we can match the information you
provide with the information we already have
on file, or we may contact you through a
communication method (e.g. phone or
email) that you have previously provided to
us. We may also use other verification methods
as the circumstances
dictate.
We will only use
personal information provided in your request
to verify your identity or authority to make
the request. To the extent possible, we will
avoid requesting additional information from
you for the purposes of verification. However,
if we cannot verify your identity from the
information already maintained by us, we may
request that you provide additional
information for the purposes of verifying your
identity and for security or fraud-prevention
purposes. We will delete such additionally
provided information as soon as we finish
verifying you.
Other privacy
rights
- You may object
to the processing of your personal
information.
- You may
request correction of your personal data if
it is incorrect or no longer relevant, or
ask to restrict the processing of the
information.
- You can
designate an
authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
- You may
request to opt out from future selling or
sharing of your personal information to
third parties. Upon receiving an opt-out
request, we will act upon the request as
soon as feasibly possible, but no later than
fifteen (15) days from the date of the
request submission.
To exercise
these rights, you can contact us
by
email at
support@botbrains.app ,
or by referring to
the contact details at the bottom of this
document. If you have a complaint about how we
handle your data, we would like to hear from
you.
12. DO
WE MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we will update this
notice as necessary to stay compliant with
relevant laws.
We may update
this privacy notice from time to time. The
updated version will be indicated by an
updated
'Revised' date
and the updated version will be effective as
soon as it is accessible. If we make material
changes to this privacy notice, we may notify
you either by prominently posting a notice of
such changes or by directly sending you a
notification. We encourage you to review this
privacy notice frequently to be informed of
how we are protecting your
information.
13. HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have
questions or comments about this notice, you
may
email
us at support@botbrains.app
14. HOW
CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM
YOU?