Privacy Policy

[10/7/2020]

This notice describes the Privacy Policy that applies to all information collected or submitted when you install or use the TagWiz application or any of Brain Rewiring, Inc.’s application or any of the other proprietary software applications or services we provide, and when you visit our website (all of which are referred to collectively herein as the "TagWiz Technologies"). The TagWiz Technologies are owned and operated by Brain Rewiring, Inc. (referred to herein as "we," "us," "our," “TagWiz” or  "Brain Rewiring"), which has developed applications and services for use in connection with a variety of devices and platforms, including without limitation, Windows, Mac, iPhone, iPad, Kindle Fire, Android, BlackBerry, Windows phone, Chrome, Safari, Firefox and other mobile devices and computers.

 

We understand your concerns about privacy. We want you to understand what types of information we collect and what may happen to that information if you install the TagWiz application or use any of the TagWiz Technologies.

 

What information do we collect?

We store some personal information to make your use of the TagWiz Technologies possible. There are several ways in which we may collect personal information from you: you may submit it or we will collect it automatically through the TagWiz Technologies. Different types of personal information may be collected depending on the way you use the TagWiz Technologies.

 

You are not required to create a user account or provide any personal information in order to visit our website. We may require you to provide personal information to create an account.  We also may require you to create a user account to use our application. If you elect to register, you will be required to provide a name, password and valid email address.

 

The TagWiz Technologies do not include advertising and we do not share your personal information with advertisers.

Personal information you submit

We collect, processes or host personal information you provide to us, such as 

●      Contact Information: ​your name and your email address or the email address of the recipient(s).

●      Preferences: We may collect information regarding your preferences for use of the TagWiz Technologies.

●      Content:  You may choose to upload or create Content, which contains personal information about you or others as well as other information such as filename, size and type of content.

●      Content Sharing:  If you choose to share any articles, videos, or other content with another person, we will ask you to provide a valid email address for that person. 

●      Third Party Websites: We may also ask you to provide your username and password for third party websites in order to access the articles and information published on such sites. 

●      Personal messages:​ the ones you send to people along with sharing your files.

●      Support messages:  We will collect information if you contact us for support or help, submit an application or otherwise communicate with us. 

●      Payment Information:  If you choose to subscribe to our paid subscription service, our third party payment processors will collect and handle your credit card and related payment information. Such third party processors’ use of your personal information is governed by their respective privacy policies.

Personal information we collect by automated means

We also collect and use personal information by automated means while you use the TagWiz Technologies.  We collect the following information:

●      Browser information:​ type of browser, language settings, country and timezone.

●      Advertiser Identification: If you are on a mobile device, we collect the advertising identifiers provided by Apple on iOS and by Google on Android.

●      Cookie or web beacon information:​ cookie IDs and settings and other personal
information received through cookies, web beacons or pixel tags. Learn more about
under section “Why and how are cookies used”.

●      Device information:​ the type of device, hardware model and operating system.

●      Identification details:​ unique identifiers such as an IDFA (for iOS), MAC address or a
UserID.

●      Network information:​ IP-addresses and mobile network information.

●      Location data: ​data on your geo-location. If we use your device based, precise
GPS-location, we will make sure we only do so after receiving your consent.

●      Service usage​: information regarding the way you interact with the TagWiz Technologies.

  • In addition to the information that you provide to us when you register for a user account, we collect information about the URLs, titles and content of the web pages and other information you save to our Applications. 

Personal information we receive from partners

In some cases we receive personal information from third parties, such as:

●      Integration information:​ you can choose to integrate the TagWiz Technologies with your (social media or messaging services) account, such as Slack, in order to provide you with a rich messaging functionality.

●      Legal Information: ​when law enforcement agencies or courts order us to take down Content, we may initially receive personal information about you and your behaviour.

Why do we use your personal information?

We use your personal information in order to provide and improve the Tag Wiz Technologies, to comply with legal obligations and to advertise our TagWiz Technologies and to keep these technologies safe and secure. Please find below how we use your personal information specifically and on what legal grounds we base the use of your personal information.

ACTIVITIES & PURPOSES

●      Service: ​the most important reason for using your personal information is, of course, to offer you our services as mentioned in our Terms of Service, for example to create or visualize your Content or share your ideas and to let you access and use your Content across different devices.

●      Support: ​we provide a wide range of support services to help you out whenever you’re in need, for instance when you need technical assistance. If it’s needed to offer support, the Support-team can, on your request, access your Content in order to help you out.

●      Account & billing:​ creating and upholding your personal account for example to facilitate your address book and to enable you to access your Content across different devices, facilitating payment of your subscription fee and perform accounting, auditing & billing activities.

●      Safety, integrity & security: ​We follow up on abuse reports, NTD/DMCA reports, fraud investigations and could investigate your compliance with our of our [TERMS OF SERVICE]  Finally, we could use your personal information for internal control to safeguard our and your safety, integrity and security. For instance, in case of any suspicion of violations of our Terms of Service.

●      Improvement & development:​ we evaluate the use of the TagWiz Technologies to improve our services, fix bugs, develop new products and services. We do this either by market research (for instance by sending out surveys) or by performing analyses (for example by tracking and bringing together your personal information across the TagWiz Technologies or across your mobile devices). We do this in order to understand how our user base as a whole interacts with the TagWiz Technologies and to improve those services accordingly.

●      Legal: ​in so far as necessary, we might use your personal information to defend us in legal proceedings in relation to or as a result of your use of the TagWiz Technologies, following a court order, abiding by any law, regulation or governmental request, cooperating with law enforcement, cooperating in fraud investigations of third parties, safeguarding national security, defense, public security, and to uphold our Terms of Service.

LEGAL GROUNDS

Each processing activity has a valid legal ground, which is described below.

●      Contractual obligations with you​: regarding the activities and purposes mentioned under Service, Support and Account & Billing. We need to process personal information to offer the TagWiz Technologies through our websites and mobile apps, to provide (technical) support and to bill your subscription fee.

●      Legal obligations:​ regarding the activities and purposes under Account & Billing, Safety Integrity & Security and Legal. We’re legally obliged to process your personal information for accounting purposes, to respond to legal requests and NTD- or DMCA-requests.

●      Consent: ​(partially) regarding activities and purposes mentioned under Support (e.g. accessing your Content for support).

●      Legitimate interests: ​(partially) regarding activities and purposes under Service and Account & Billing (e.g. to provide cross device access). For the purposes mentioned under Safety, Integrity and Security  in order to provide safe services, to prevent fraud and react against illegal use of the TagWiz Technologies. For our innovative interests as mentioned under improvement & development. And finally for our compliance interests as stated under legal.  When we use your personal information based on our or a third party’s legitimate interest, we will endeavour to balance your rights and freedoms against said legitimate interest. If, to the extent applicable, you wish to object to the activities based on our legitimate interest and there’s no opt-out available in your account settings or received communication, please contact support@brain-rewiring.com.

What parties do we share personal information with?

Public content

If you choose to make the content you save publicly available, we may share that information with others in accordance with the options you select. In addition, if you choose to use the TagWiz Technologies to share articles, videos, or other content with another person, we will send an email on your behalf to that person with a link to the content that you have chosen to share.

Aggregate data

We also share aggregated, non-personal data and related usage information, which does not contain any personal information which can identify you or any other individual user, with third parties, including content providers, website operators, advertisers and publishers. For example, we may share with a content provider a list of the most saved articles to TagWiz based on an analysis of aggregated, anonymous user data, but we would not share with such content provider any personal information regarding such users.

Links to other sites and apps

We may allow you to connect your TagWiz account to third-party applications to enable additional features like saving from your favorite apps or other unique features third-party developers have created. In this case, we will set up controls in our Applications so that you can control the information that is shared with third-party providers of products and services.  Although we may allow you to use the TagWiz Technologies in conjunction with third-party products and services, we are not affiliated with, and have no control over, such third parties. Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you and we encourage you to check the privacy policy of each third-party provider of products or services that you choose to connect your TagWiz account to.

Working with third parties

We may work with trusted third parties to facilitate one or more aspects of the products and services that we provide to you and to conduct research related to Internet usage, and we may provide some of your personal information directly to these third parties. For example, as discussed above, we may use a third party payment processor to process payments for our paid subscription service.  We may also use hosting providers, user support providers, IT & Software providers, email processors and accountants.  These parties are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide to them for any other purpose other than those discussed above, unless you have explicitly agreed or given your prior permission to them for additional uses.

Sharing as required by law or asset sale

In the event that we or certain of our assets are acquired, user information may be included among the transferred assets. By using or website or Applications, you expressly consent to this transfer.

 

Although we strive to protect the personal information of our users, we will release personal information if required by law or in the good-faith belief that such action is necessary. We follow the law whenever we receive requests about you from a government or related to a lawsuit. We will notify you when we are asked to hand over your personally identifiable information in this way unless we are legally prohibited from doing so. When we receive requests like this, we will only release your personally identifiable information if we are required to do so or have a good faith belief that disclosure is necessary or appropriate under applicable law. Nothing in this policy is intended to limit any legal defenses or objections that you may have to a third party's request to disclose your information.

Why and how are cookies used?

COOKIES AND SIMILAR TECHNOLOGIES

We place several cookies (or similar technologies, like pixels or web beacons) on your device for the purpose of facilitating your use of the TagWiz Technologies and to find out how the TagWiz Technologies may be improved. We may also place cookies on our website(s). 

 

Cookies are small text files that are stored on your computer by your browser when you visit a website. Examples of cookie purposes are: your language preferences, logging into an account, remembering login details, serving you personalised advertisements and acceptance of the Terms of Service. 

We use persistent cookies and session cookies. A persistent cookie lasts beyond the current session and is used for many purposes, such as recognizing you as an existing user, so it’s easier to return to the TagWiz Technologies and interact with our services without signing in again. Since a persistent cookie stays in your browser, it will be read by us when you return to the Application or visit a connected third party site. Session cookies last only as long as the session (usually the current visit to a website or a browser session).

Our website can place cookies for the following purposes:

●      Functional cookies​ are used to provide functionalities when using the TagWiz Technologies, such as the possibility to set preferences or to remember your previous settings.

●      Analytical cookies​ are used to optimise the TagWiz Technologies. For example to optimise the usability of our website by AB-testing a new feature, to make the website more user-friendly and to analyse how you use the TagWiz Technologies.  We also use analytical cookies to stop bots and malicious behaviour like spam. When we use analytical cookies, this could include third party cookies, as found in the cookie list. These third party analytical cookies process personal information, which is detailed in the cookie list too.

Pixel tags, web beacons, “Clear GIFS” or similar means​ are pieces of code embedded on the website that collects personal information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page. The pixel also allows us to see from which previous website or channel a user arrived at our website.  We also use these technologies in connection with emails that we send to our users in order to collect usage data. 

You may decline our cookies if your browser permits, although in that case you may not be able to use certain features, you may be required to enter your password more frequently during a session, and you may be unable to install or use certain TagWiz Technologies. Cookies and other technologies make the Brain TagWiz Technologies easier to use and help us customize and personalize the services we provide based on your interests and activities.  If you have questions about disabling cookies, please contact us at support@tagwiz.com.

KEEPING INFORMATION

We will keep your information only for as long as we need it to provide you services, manage our business or as required by law or contract.

TRANSFER OF INFORMATION

We're a global organization and our computers are in several different places around the world. We also use service providers whose computers may also be in various countries. This means that your information might end up on one of those computers in another country, and that country may have a different level of data protection regulation than yours. By giving us information, you consent to this kind of transfer of your information. No matter what country your information is in, we comply with applicable law and will also abide by the commitments we make in this privacy policy.

SECURITY

We have agreements with third parties and have adopted other security measures in place to protect against the loss, misuse and/or unauthorized alteration of the information under our control or under the control of our service providers. Your personally identifiable information is protected by utilizing both online and offline security methods, including firewalls, passwords and restricted physical access to the places where your information is stored. Although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain free from security issues. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

PHISHING

Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

MANAGING MY PRIVACY AND EMAIL SETTINGS

If you would like to access, correct, or delete your personal information and export your data from your user profile, you may do so by contacting us at support@brain-rewiring.com.   We can also assist you in viewing and controlling which third party services, if any, you want to connect to your user account.  We may automate these functions in the future.

 

As part of our default settings to share saved and recommended content, we send emails to our users. You may opt-out of receiving these, and updates on our service and your use, by using the unsubscribe feature on any of our email correspondence or from your account settings. We will try to communicate with you only according to your instructions, although it may take some time to process your request.

 

CALIFORNIA CONSUMERS

Subject to certain limitations under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year and (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year. We do not, however, share your personal information with marketers.

AMENDMENTS TO POLICY

Please note this Privacy Policy will change from time to time. We may amend this Privacy Policy at any time by posting the amended terms on our Website that you can access through the options or help menu of our Application. All amended terms shall automatically be effective thirty (30) days after they are initially posted on our Application unless new terms are required by law, in which case, the amended policy will be effective when posted.  If we make any material changes to our Privacy Policy that affect user information already stored in our database, we will post a notice in our Applications notifying users that our Privacy Policy has changed. Our use of your information shall be governed by the terms and conditions of our Privacy Policy in effect when you first use our application or thirty (30) after the terms are changed (or, earlier if required by law), as explained above.

 

If you have questions about any of the provisions described above, please contact us at  or at the street address listed above.

CONTACT

If you have questions or concerns regarding this Privacy Policy, you should contact us at brain-rewiring.com. Alternatively, you may contact us at:

 

Brain Rewiring, Inc.

6469 Almaden Expy Ste 80 #532

San Jose, CA 95120

 

 

Europeans who believe a privacy complaint is unresolved have the right to lodge a complaint with the supervisory authority of their Member State.

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