Privacy Policy

This Privacy Policy was last updated on July 31, 2024

With the development of new communication tools, it is necessary to pay particular attention to the protection of privacy. Therefore, Brainbox AI Inc., and its affiliates worldwide (collectively, “we”, or “our”) are committed to respecting the privacy of the Personal Information (defined below) we collect from your use of our website (https://brainboxai.com) and to inform you on how we process your information if you are a purchaser or user of Brainbox AI’s product and/or services.

“Personal Information” refers to any information in any medium and from any source that allows a natural person to be identified. This Privacy Policy explains the purposes for collecting your Personal Information, how we protect that information, and the rights you have regarding your Personal Information. As an organization, we are aware of our responsibilities under the European Union General Data Protection Regulation (GDPR), and Québec’s Law 25.

Please read this policy carefully to understand how we handle your information. This policy describes the types of information we may collect from you or that you may provide when you visit our website or use or access the services, and our practices for collecting, using, maintaining, protecting, and disclosing that information. By using or accessing the website and/or services, you agree to this policy. If you do not agree to this policy, please do not access or use the website or the services. This policy may change from time to time. Your continued use of this website and/or the services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our website and services are not intended for children under 18 years of age. Additionally, no one under the age of 16 may provide any information to or on the website or via the services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use the services or use or provide any information on this website or on or through any of its features or register on the website, use any of the interactive or public comment features of this website, if available, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at contact@brainboxai.com.

Types of Personal Information we collect

• Last Name
• First Name
• Address
• Postal Code
• Email address
• Phone and/or Fax numbers
• Employment history, education, and other information that may be included in a resume as well as information such as date of birth, gender, position, etc. for employment purposes
• Social media profiles

How we use your Personal Information

To provide services to you.

Communicate with you regarding the services, including providing customer service, support and sales.

To present our website and its contents to you.

To provide you with information, products, or services that you request from us.

Promote and market Brainbox AI products and services.

To fulfill any other purpose for which you provide it.

To provide you with notices about your account.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our services and/or website or any products or services we offer or provide though it.

Analyze use of the services.

Statistics.

Improve any services or products we provide and research or develop other products or services.

Compliance with legal and regulatory requirements

Keep our Services operational.

Create or maintain aggregated, anonymized and/or de-identified information, which we may use and disclose without restriction.

In any other way we may describe when you provide the information.

For any other purpose with your consent.

Third parties who collect and/or retain your Personal Information

The following third-party service providers help us operating by collecting and/or retaining your Personal Information on our behalf:

• AWS
• Atlassian
• Microsoft
• Bamboo HR
• HubSpot
• Pipedrive

Third party service providers have their own privacy policies in place for your review. We are not responsible for the privacy practices of these third-party service providers.

We use cookies

Cookies are small text files that are saved on your computer when you view a website. We use cookies on our website to give you the most customized browsing experience. You can disable cookies by adjusting your web browser settings at any time. Turning off cookies could limit the use of our website. We use all data collected from cookies according to this policy.

Our website includes links to our social media accounts, which may use cookies to obtain information about your use. Please read the privacy policies of these third-party websites carefully before browsing or providing any information on such websites. We are not responsible for your activities or any collection or tracking of your information on such sites.

When and how we collect Personal Information

We collect Personal Information from: individuals who view our website, customers of Brainbox AI, forms (which may include become a Partner, media requests, Implement the solution or document downloads) filled out on our website.

The Personal Information is also collected from log files and cookies, which is mainly through:

• IP Addresses
• Operating systems

We collect your Personal Information when you request a dashboard account.

Marketing

You may receive marketing emails from us from time to time by signing up on our website. You can unsubscribe from these emails at any time by means of a link provided in the emails that are sent by us. Please note that even if you opt out of, and unsubscribe from, receiving marketing communications, we may still send you certain communications relating to your use of the services.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this policy:

To our subsidiaries and affiliates.

To contractors, service providers, and other third parties we use to support our business.

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred.

To fulfill the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our website Terms of Use, our Terms of Service and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others.

How we protect your Personal Information

We will protect your Personal Information from unauthorized access, use and disclosure using appropriate physical safeguards such as a clean desk policy and restricted areas for visitors in the office; technical safeguards such as encryption, and organizational security measures such as the use of multi-factor authentication. We ensure that the Personal Information we collect is kept in a secure environment. People working for us are required to respect the confidentiality of your Personal Information.

Furthermore, we are committed to maintaining a high degree of confidentiality by incorporating the latest technological innovations to ensure the confidentiality of your transactions. However, since no mechanism offers maximum security, there is always a risk involved when using the Internet to transmit Personal Information.

If a confidentiality incident has occurred involving your Personal Information and a serious risk of harm may be caused, we will notify you and the Commission d’accès à l’information du Québec (Québec Commission for Access to Information) as soon as possible.

Retention of Personal Information

We will retain the Personal Information that we obtain from you for as long as is required to satisfy the purpose for which the Personal Information was obtained, or to comply with applicable legal, and/or regulatory obligations.

Transfer of Personal Information Internationally

We may transfer your Personal Information to our affiliates worldwide to, for example, provide you with the latest information regarding our products, services, and promotions. We will take reasonable steps to ensure that your Personal Information is protected in accordance with our Privacy Policy. By providing your Personal Information, you agree to any transfer and/or retention of your Personal Information.

Know your Rights

We are committed to offering you the right to oppose and opt out of the collection of your Personal Information. The right of opposition is understood as the possibility offered to Internet users to refuse that their Personal Information be used for certain purposes mentioned during the collection. The right of withdrawal is understood as the possibility offered to Internet users to request that their Personal Information no longer appear, for example, in a mailing list. We are also committed to recognizing a right of access, rectification, and erasure to those concerned wishing to consult, modify or delete Personal Information concerning them. You also have the right to data portability where your Personal Information can be transferred from one electronic data processing system to another without being prohibited by us. To exercise any of these rights, you can reach us by:

Mail: 2001 Boul. Robert-Bourassa Suite 840, Montreal, Canada H3A 2A6

Email: Contact our Chief Legal, Compliance, and Data Privacy Officer at: contact@brainboxai.com

We will respond to requests within 30 days of receipt.

Changes to our Privacy Policy

We may make changes to our Privacy Policy periodically. Any changes will be posted on this webpage.

Additional Rights Regarding Personal Data under GDPR

The following notices and disclosures apply to all natural persons who provide personal data to Brainbox AI, i.e., data subjects, who are covered by the EU General Data Protection Regulation (Regulation EU 2016/679):

• Length of Data Use: Personal data of a data subject is maintained while the data subject or the data subject’s employer is a customer of Brainbox AI, and for a reasonable time afterwards to make it easier for Brainbox AI to serve the data subject or his or her employer if either re-subscribe to Brainbox AI’s services and to contact them about subscription renewal and new products and services.
• Right to Access and Rectification: A data subject has the right to demand access to and the rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability.
• Withdrawal of Consent: A data subject also has the right to withdraw the consent provided by his or her acceptance of this policy at any time, without affecting the lawfulness of any data processing based on consent before its withdrawal.
• Right to Lodge Complaint: A data subject also has the right to lodge a complaint with a supervisory authority regarding Brainbox AI’s processing of his or her personal data.
• Need for Personal Data & Consequences of Withdrawing Consent: The personal data provided by the data subject under this policy is required for Brainbox AI to perform its obligations under any contract between Brainbox AI and the data subject or an employer of the data subject because this information is needed to identify authorized users and provide customer service. A data subject that no longer provides consent or requests erasure of his or her personal data will no longer be able to use Brainbox AI services or products because this information is needed to ensure that the data subject is an authorized user.
• Providing Personal Data to Data Subject: Brainbox AI can provide to a data subject—upon request—remote access to a secure system that provides that natural person with direct access to his or her personal data. This type of request will not be fulfilled in way that may adversely affect the rights or freedoms of others, including trade secrets or intellectual property, and, in particular, the copyrights, protecting Brainbox AI’s software. Depending on the amount of data that falls within this type of request, Brainbox AI may request that, before the information is delivered, the data subject specify the information or processing activities to which his or her request relates.
• Data Transfer outside the EU: Brainbox AI transfers your information, including personal information of natural persons, outside the European Union to the United States or Canada because the transfer is necessary for the performance of the services contract between you and Brainbox AI or the implementation of pre-contractual measures taken at your request. Not all states in the United States have data-protection and privacy laws as comprehensive as the European Union. If European Union data-protection and privacy laws apply to you, then Brainbox AI will maintain measures to protect your personal information identifying natural persons in a manner commiserate with the protections required under European Union law. The EU has not determined that the United States has adequate legal safeguards outside of certain self-certification programs that Brainbox AI currently does not participate in.
• Who to Contact: A data subject can use the following email to contact Brainbox AI regarding any of the privacy rights provided for or granted under law or under this policy: contact@brainboxai.com

California Consumers Only: This additional provision applies only to California consumers.

Brainbox AI does not sell personal information. If Brainbox AI changes its policy and decides to sell consumer’s non-anonymized personal information to third parties—which it currently does not—a consumer will have the right, at any time, to direct Brainbox AI not to sell the consumer’s personal information. This right is referred to as the right to opt-out. Brainbox AI will provide notice of any change in its current policy before engaging in any sale of consumer’s personal information. Brainbox AI will not discriminate against a consumer because the consumer exercised any of the consumer’s rights. Nothing in this California-consumer provision prevents Brainbox AI from collecting, using, retaining, selling, or disclosing consumer information that is anonymized or in the aggregate consumer information to the extent otherwise allowed under this policy. Nor does it prevent Brainbox AI from collecting or selling a consumer’s personal information if every aspect of that commercial conduct takes place wholly outside of California to the extent otherwise allowed under this policy. For purposes of this provision, commercial conduct takes place wholly outside of California if the business collected that information while the consumer was outside of California, no part of the sale of the consumer’s personal information occurred in California, and no personal information collected while the consumer was in California is sold. You represent that any users of Brainbox AI’s products or services are at least 18 years old.

A consumer has the right to request that Brainbox AI disclose to that consumer the categories and specific pieces of personal information that Brainbox AI has collected. Brainbox AI does not have to provide information upon consumer request more than twice in any twelve-month period. Brainbox AI uses and collects the following types of personal information as described in the sections of this policy marked by the following headings: Types of Personal Information we collect, When and how we collect Personal Information, and Disclosure of Your Information. These categories of types of data and collection correspond to the following required disclosure of categories of use and collection found subdivision (c) of Section 1798.110 and subdivision (c) of Section 1798.115 (additional information is provided in italics below):

Section 1789.110:

(1) The categories of personal information it has collected about that consumer.

Brainbox AI collects name, address, password, email address, phone number and employer information.

(2) The categories of sources from which the personal information is collected.

Brainbox AI gets personal information from you, your employer, and from your computer and interaction and use of the Brainbox AI Website, services, and products and software.

(3) The business or commercial purpose for collecting or selling personal information.

Brainbox AI does not sell personal information. Brainbox AI uses personal information to identify authorized users, provide customer service, track use of Brainbox AI products and services, follow up with communications for new sales, services and renewals, and coordinate provision of products and services with Resellers, third-party developers, and Brainbox AI vendors.

(4) The categories of third parties with whom the business shares personal information.

As stated above, Brainbox AI shares personal information with third-party developers and Brainbox AI vendors that help Brainbox AI provide, develop, troubleshoot, or modify products or services.

Section 1798.115:

(c) A business that sells consumers’ personal information, or that discloses consumers’ personal information for a business purpose, shall disclose, pursuant to subparagraph (C) of paragraph (5) of subdivision (a) of Section 1798.130:

(1) The category or categories of consumers’ personal information it has sold, or if the business has not sold consumers’ personal information, it shall disclose that fact.

Brainbox AI does not sell consumers’ personal information.

(2) The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed the consumers’ personal information for a business purpose, it shall disclose that fact.

As explained above, Brainbox AI discloses consumers’ personal information only to vendors for customer service, product development, troubleshooting, customer sales, and verification purposes.

A consumer has the right to request that Brainbox AI delete any personal information about the consumer which Brainbox AI has collected from the consumer. Brainbox AI is not required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for Brainbox AI to maintain the consumer’s personal information in order to:

(1) Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of Brainbox AI’s ongoing business relationship with the consumer, or otherwise perform a contract between Brainbox AI and the consumer.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with Brainbox AI.

(8) Comply with a legal obligation.

(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

A consumer may contact Brainbox AI at the following email address contact@brainboxai.com to request the information, deletion, or exercise any right to opt out provided under this policy or California law, which has not been or cannot be waived by the requesting consumer. Brainbox AI will use any personal information collected from the consumer in connection with the business’s verification of the consumer’s request solely for the purposes of verification.

Definitions: “Consumers” means a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, as that section read on September 1, 2017, however identified, including by any unique identifier. “Aggregate consumer information” means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device. “Aggregate consumer information” does not mean one or more individual consumer records that have been anonymized. For California consumers, “anonymize” and its derivatives in this policy will have the same meaning as “deidentified” in the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100, et seq. For California consumers, “personal information” will have the following definition as found in the California Consumer Privacy Act of 2018: “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:

(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

(B) Any categories of personal information described in subdivision (e) of Section 1798.80.

(C) Characteristics of protected classifications under California or federal law.

(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

(E) Biometric information.

(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

(G) Geolocation data.

(H) Audio, electronic, visual, thermal, olfactory, or similar information.

(I) Professional or employment-related information.

(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

(2) “Personal information” does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.

For more information regarding our Privacy Policy, please email: contact@brainboxai.com.