Brunner Academy –Privacy Policy

Brunner Academy takes your privacy as seriously as you do. We try to be transparent about our data practices and give you control over the information we collect about you. This Privacy Policy covers the Consumer Services offered by Brunner Communications, Inc. dba Brunner Academy, 400 Stuart Street, 24B, Boston, Massachusetts 02116, which include our websites (the “Sites”), our mobile applications (the “Apps”), and other online services that we own or control (collectively, the “Consumer Services”). This Privacy Policy does not apply to our enterprise customers, business partners or data suppliers. This Policy also describes applicable data protection rights including a right to object to some of our processing.

1. What Data Does Brunner Academy Collect

Data You Provide to Us:

We collect data that you provide to us when you create an account, such as full name, email address, phone number, birthday, gender, the city in which you created your account, and, where applicable, your social media username and other data if you create an account using third party log-in credentials (please see “Data Received From Third Parties” below).

We may also collect other data you provide when you use the Consumer Services, including pictures you upload, messages you send through the Apps, searches, survey responses, demographic information, and any other data that you voluntarily provide to us.

Data Collected Automatically When You Use Our Consumer Services:

If you opt in to sharing your location with us, we automatically receive data about your precise location (e.g., latitude-longitude coordinates) whenever you use the Consumer Services (e.g. open our mobile apps, visit our website, etc.). If you opt in to have background location on in our Apps, we will collect data about your location when you are not using the Apps and when the Apps are closed (as permitted by your device settings).

We also collect additional data about you when you use the Consumer Services. For example:

• data about how you interact with the Consumer Services, such as your search words, page views, date and time of interactions, time spent on each page, or posts you make;

• device information, such as your hardware model, operating system and version, unique ID and device data such as device identifiers, IP address, sensor data, browser type, language, and wireless network, mobile device name, types of mobile apps installed; and

• data from cookies, pixels and other technologies, such as cookie ID, advertising ID or other unique advertising ID, web beacons, and local storage. You can control certain types of cookies through your browser settings or other tools.

Data Received From Third Parties

We may receive data about you from third parties, including:

• Our Enterprise Customers (e.g. business customers of our Products);

• Third parties that provide services to us, such as unaffiliated apps and websites, offered by our business partners, including those from whom we license data; and

The information we obtain from third parties includes demographic data, data about how you interact with the third party's websites and apps, device data (including mobile device and advertising identifiers, such as Apple IDFA or Google Advertising ID), and information from cookies, pixels and other similar technologies. In the event that we obtain data about you from our Enterprise Customers and third parties, we will combine all data collected about you into one single profile.

2. How Is My Data Used by Brunner Academy?

To Operate, Maintain and Improve the Consumer Services

We use your data to operate and maintain the Consumer Services and our business, and to understand you better and personalize the Consumer Services. To do so, when you access the Consumer Services in more than one manner, we combine your data that we obtain in each case. In addition, if you use the Consumer Services when you are not logged into your Brunner Academy account, when you subsequently log in to your account, we combine data collected while you were not logged in.

Some features and functionality in our Consumer Services may require that you provide your location. If you have location services turned on, whenever you use our Apps on your mobile device, we collect and use your geocoordinates (e.g. latitude and longitude) to tailor the Consumer Services to your current location. We will only process your location with your express permission. If you have persistent background location turned on, we will obtain your device’s location even if you are not using the Apps. Your location is never shared with others, except with your consent or as permitted under this Privacy Policy.

We use various technologies to determine your precise location, such as the location services of your operating system or browser, sensor data from your device (e.g. magnetometer, barometer, gyroscopes, accelerometers, compasses, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other data that may help us understand your precise location.

If you have opted-in to sharing your background location with us in our Apps, you may remove your permission at any time by going into your operating device settings and toggling off background sharing.

We also use your data to improve the Consumer Services and our business, conduct research and development, perform analytics, develop and offer new products and service, and to infer certain details about you, including details about you, your interests and whether separate devices (e.g. mobile phones, tablets, and/or computers) are owned by you or by members of your household. We also use your data to help us map Locations (as defined below). For example, we may use device signals to determine that a particular device is within a particular venue. Additionally, if you consent to sharing crash data (when the Apps crash) with us, we may use that data to help us analyze the cause of the crash and improve the Consumer Services.

Communicate With You

We use your data to communicate with you by email, text (if you opt-in), or as part of the Consumer Services, about new product offerings, updates to the Consumer Services, or anything else we think may be of interest to you. To opt out of receiving marketing communications, please see the “Unsubscribe from Marketing Emails and Text Messages” section of this Privacy Policy below.

Rewards and Accomplishments

We may use your data, including your completed surveys, to enable you to earn points and track your accomplishments within the Consumer Services.

Protection of Our Rights

We may use your data to protect the rights, property or safety of Brunner Academy, the Consumer Services, our users and employees, or any third party. For example, we may use your data to protect against identity theft, prevent fraud or other criminal activity, claims or other liabilities. We may also use your data to comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Privacy Policy and our Terms and Conditions.

3. When Is My Data Shared?

We may share certain data about you as further described in this Privacy Policy or when you have given us consent to do so.

Data That May Be Shared with Other Users

When you use the Consumer Services, other users may see some of your data (e.g. username, profile photo, degree or certificate program, and other information you post). When you communicate using the Consumer Services, such as by sending messages to other users, those users may see this data. You can control what you want visible to others, including your friends, in your “Settings”.

Data That May Be Shared with Affiliates, Service Providers and Partners

We may share your data with our affiliated entities, and service providers that perform services on our behalf, such as cloud storage, IT services, marketing, analytics and search engine and other software services. These service providers may be located in countries other than the country in which the information originally was collected, such as the United States and Canada. We do not authorize our service providers to retain, use or disclose the data except as necessary to perform services on our behalf or comply with legal requirements.

Data That May Be Shared with Our Affiliates and Subsidiaries

We may share data with our affiliates and subsidiaries in order to improve the Consumer Services, develop and offer our Products, and for other purposes.

Compliance with Law, Protection of Rights and Corporate Events

We may share data (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (v) in connection with an investigation of suspected or actual illegal activity; or (vi) to protect the rights, property, or safety of Brunner Academy and our products and services, our employees, or users and others.

We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.

When You Consent

We will also share your data with your consent.

4. What About Cookies and Similar Technologies?

We may use technologies like cookies, pixels, web beacons, local storage and other automated technologies on our Sites, in our emails, within our Consumer Services, and sometimes in third party apps that use our APIs or SDKs to provide you with a range of products and services. We use these technologies for a number of purposes, such as for authentication, security, preference settings, in our Products for advertising, measurement and analytics.

You can control cookies through your browser settings and other tools. If you reject cookies, this could affect the availability and functionality of the Consumer Services.

Third-Party Analytics

On our Consumer Services, we may use third-party analytics services, such as those of Google Analytics. The service providers that administer these analytics services use cookies and other automated technologies to collect data (such as IP addresses and other device identifiers) to evaluate, for example, use of our Consumer Services and to diagnose technical issues. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

Interest-Based Advertising

Through our Consumer Services, both we and certain third parties (such as our business partners) may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. You may see our ads on other websites or mobile apps because we use third-party ad services. Through such ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track users’ online activities over time and across multiple online services by collecting information through automated means, including through the use cookies, web server logs, web beacons, device identifiers and other similar technologies. The ad services use this information to show ads that may be tailored to users’ interests. The information ad services may collect includes data about users’ visits to our Consumer Services and other websites and apps that participate in the relevant ad services, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on our Consumer Services and on unaffiliated third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

5. How do I Access or Delete My Data?

You may access and update your data at any time through the “My Account” tab in your Brunner Academy account. 

You may also may send us a request at any time to delete your data and account by emailing [email protected] and providing your full name, username, and a request that we delete your personal data and account. Once we delete your data, your profile, including your course history, messages, and other user-specific information will be removed from the Consumer Services, and you will no longer be able to access such data. We will not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your personal information or posts may remain on backup media for a short period of time thereafter.

We may also retain data as required by applicable law and we may retain data that has been anonymized or otherwise does not constitute or contain personal information.

If you have questions about accessing, updating, or deleting your data, please email [email protected].   

If you are from the EEA, UK or Switzerland, you may also have additional rights, which are summarized under "More Information for Consumers from the EEA, UK or Switzerland" below.

6. Unsubscribe from Marketing Emails and Text Messages

• By Email: You can opt out of marketing or promotional emails at any time by adjusting your preferences in your “Settings” tab. You may also unsubscribe from marketing emails by following the instructions in the email. Please note that you cannot opt out of service or legal notices.

• By SMS: If you have opted in to receive SMS messages, you can always unsubscribe at any time by texting STOP in response to a message or by following the instructions in the SMS.

7. Personal Information Retention

To the extent required by applicable law, we keep the personal information you provide for the duration of our relationship, plus a reasonable period thereafter to comply with the applicable statute of limitations and other applicable laws.

8. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Consumer Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

9. Children under 13

Our Consumer Services are intended for a general audience and are not directed at children. We do not knowingly collect personal information online from individuals under the age of 13 or such other age as may be directed by applicable law.

10. More Information for Consumers From the EEA, UK and Switzerland

Where GDPR applies to the processing of your Personal Data, we rely on several legal bases. These include:

• When the processing is necessary to perform our contract with you, such as our Terms & Conditions. This may include providing you with our Consumer Services or tailoring the Consumer Services to your preferences;

• When the processing is necessary for our legitimate business interests (or those of our Enterprise Customers), including but not limited to, improving the Consumer Services;

• When you have given us your consent, including as described in this Privacy Policy. You may withdraw your consent to processing at any time using the settings on your device or in your account;

• When we have a legal obligation to do so, as described in this Privacy Policy.

Your Rights

Subject to applicable law, you may have a number of rights regarding the processing of your Personal Data, including:

• the right to request access to, or copies of, your personal data that we process or control, together with information regarding the nature, processing and disclosure of that personal data;

• the right to request rectification of any inaccuracies in your Personal Data that we process or control;

• the right to request deletion of your personal data that we process or control, or restriction of processing of your personal data that we process or control;

• the right to object, to the processing of your personal data by us or on our behalf;

• the right to have your personal data that we process or control transferred to another data controller, to the extent applicable;

• the right to withdraw where we process your personal data on the basis of your consent, and

• the right to file a complaint with a Data Protection Authority regarding the processing of your personal data by us or on our behalf.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your personal data, please use the contact details provided in the Contact Us section.

These rights may be limited in certain circumstances, for example if fulfilling your request would (i) reveal personal data about another person, (ii) infringe the rights of a third party (including our rights), (iii) cause us to delete information that we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.

Transfers of Data to the United States

Brunner Academy may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we protect that information as described in this Privacy Policy. We transfer the Personal Data we collect about you to the U.S. in order to perform our contract with you or to take steps requested by you in order to enter into a contract. For example, we may transfer your Personal Data to the U.S. for the purposes of creating your account or providing our Services. We also may transfer your Personal Data to the U.S. where you have provided us with your explicit consent. Where we rely on your explicit consent, we will inform you of the purposes for which we require your Personal Data, as well as other supplementary information, at the point at which we obtain your Personal Data. Where you have provided your explicit consent, you have the right to withdraw the consent at any time by contacting us as indicated in the “Contact Us” section below.

Who is Responsible for Your Data?

Brunner Academy is a data controller for all data collected under this Consumer Services Privacy Policy.

13. Changes to this Privacy Policy?

Brunner Academy may amend this Privacy Policy from time to time. We encourage you to regularly check this page to review any changes we might make in accordance with this Privacy Policy. We will indicate at the top of the Privacy Policy when it was most recently updated. If we make material changes in the way we use your data, we will notify you by posting an announcement on our Sites or Apps, during the course of providing the Consumer Services, or by sending you an email (if we have your email).

14. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to our Data Protection Officer: [email protected] or Brunner Academy, 400 Stuart Street, 24B, Boston, Massachusetts 02116. We will make every effort to resolve your concerns.

As of November 10, 2020