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Privacy Policy

Effective Date: June 1, 2018

MSC Brain group Holdings, Inc. ("we" or "us") wants you to be familiar with what information we collect about you, how the information is being used and what choices you have regarding the collection and use of the information. This Privacy Policy (the "Policy") describes our practices in connection with information that we collect in person, over the phone and through our websites, application program interfaces ("APIs") and mobile applications (collectively, the "Site"). Please take a moment to review this Policy.

By using the Site, you agree to the terms of this Policy. If you do not agree to the terms of this Policy, please do not use the Site. We reserve the right to change this Policy without prior notice. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Therefore, we encourage you to review this Site from time to time for changes to our Policy.

TYPES OF INFORMATION GATHERED

We collect personal information and non-personal information through the Site. Personal information is information that identifies you as an individual. Non-personal information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity.

Personal information. We may collect the following types of personal information:

  • Information provided by you when ordering COBI (Cognitive Orientation & Behavior Index) Assessment, BOSI (Brain Orientation & Suitability Inventory) Assessment and COCA (Cognitive Orientation and Competency Assessment) test products through the Site. For example, you will be required to submit personal information such as your name, address, date of birth, telephone number and e-mail address.
  • • Information provided about your children when ordering COBI (Cognitive Orientation & Behavior Index) Assessment, BOSI (Brain Orientation & Suitability Inventory) Assessment and COCA (Cognitive Orientation and Competency Assessment) test products. For example, as a legal guardian, you will be required to submit the child's first and last name, and date of birth.
  • • Credit and debit card account information collected from you. For example, we will collect credit and debit card account information from you on our sites, and over the phone in order to cancel the cards per your request in the event that they are lost or stolen.
  • • When you make a purchase through the Site, we may collect your credit and debit card number or other payment account number, billing address and other information related to such purchase (collectively, "Payment Information") from you. However, purchases using our mobile applications may require the use of your mobile phone's default payment processing application.
  • • Other information we collect, such as city of birth and mother's maiden name, is used to verify your identity in the event you forget your login information required for our online products.
  • • Information you provide us through customer service correspondence and general feedback.
  • • Video content you choose to submit to us, such as commentary about our products and services, testimonials, or other similar content you share through video.

Non-Personal information. When you visit the Site, we may collect non-personal information, such as a catalog of the Site pages you visit. Non-personal information is generally collected through the Site from the following sources: server log files, environmental variables, crash logs, cookies, pixel tags and other similar technologies, mobile software development kits, advertising identifiers, device identifiers and information that you voluntarily provide.

  • Server Log Files. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer or other device that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
  • Environmental Variables. We and our service providers may also collect certain environmental variables, such as computer or device type (Windows or Macintosh), screen resolution, operating system version, Internet browser, wireless carrier, Wi-Fi status and Internet browser version. Many of these environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.
  • Crash logs. We may collect information from crash logs that are generated in the event our mobile applications crash while they are in use. Crash logs gather certain pieces of information about your device and your device's activities at the time of the crash, but they do not contain any personal information. These help us determine the root cause of a crash so we can fix it in a future update.
  • Cookies and Similar Technologies. We, our service providers, and/or non-affiliated Third-parties, may use "cookies" or similar technologies, such as local storage, on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping purposes. Cookies are an industry standard used by many websites, and can facilitate your ongoing access to and use of a particular website; cookies do not cause damage to your computer systems or files. We use cookies or similar technologies to collect and store information for customizing user experiences and to track visitor usage on the Site. If you do not want information collected through the use of cookies, there are simple procedures in most browsers that allow you to delete existing cookies and local storage, automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. Additionally, please see the "Your Choices" section below for instructions on how to opt-out of sharing certain information related to the use of cookies.
  • Pixel Tags. We, our service providers, affiliates and/or non-affiliated Third-parties, may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with Cookies on the visitors' hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, to provide online advertising, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened. Together with cookies and other technologies, Pixel Tags enable us to administer and improve our Site and its content, including tracking user movements around the Site, to gather usage information and statistics about how the Site is used, to permit users to log in or enroll in our services, to store user preferences, to target and customize content.
  • Mobile Software Development Kits. We and our service providers may use mobile software development kits ("SDKs") to collect event properties within the mobile applications that are similar to environmental variables that are collected by most browsers, which may include general location data (derived from IP address), device manufacturer, and screen height and width. The SDKs track user movements and events occurring within our mobile applications as well as gather information on customers' interactions and satisfaction with our mobile applications. The SDKs help us improve our mobile applications for our customers.
  • Advertising Identifiers. We and our service providers may collect Advertising Identifiers ("Advertising IDs") that are generated by a mobile device's operating system. Advertising IDs enable us and our service providers to serve advertisements to a mobile device by helping to distinguish devices for ad tracking and suppression purposes. You may choose to enable a feature that limits the use of Advertising IDs, or you may reset the Advertising ID on your device. These features do not block all advertisements to your device, but they can prevent relevant advertisements (ads based on your browsing history) from appearing on your device.
  • Device Identifiers. We, our service providers, affiliates and/or non-affiliated third parties that may host our products and services, may collect information about your device, such as a device ID or another identifier as permitted by the device manufacturer, when you access the Site. This information is mainly used to aid in identity authentication and verification, and it is not used for advertising.
  • Information That You Voluntarily Provide. We also collect non-personal information (e.g., your geographic location, etc.) when you voluntarily provide such information to us. When such information is not combined with any personal information, such information is considered to be non-personal information, as it does not personally identify you or any other user. Additionally, we may aggregate personal information in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using personal information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered non-personal information for purposes of this Policy.
  • • Please note that if we combine any non-personal information with personal information, the combined information will be treated by us as personal information as long as it is so combined.

USE OF THE INFORMATION GATHERED

Personal Information. We may use personal information we collect in the following ways:

  • Fulfillment of Requests. We may use personal information collected about you to provide you with products, services or information that you request, including, but not limited to, COBI (Cognitive Orientation & Behavior Index) Assessment, BOSI (Brain Orientation & Suitability Inventory) Assessment and COCA (Cognitive Orientation and Competency Assessment) test products and other related services.
  • Administrative Communications. From time to time we may use personal information to send you important information regarding the Site, or changes to our terms, conditions, and policies. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
  • Other Communications. From time to time, we may use personal information to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer that we do not send such email marketing messages to you, please see the "Your Choices" section below.
  • Purchases. We may use personal information, including Payment Information, in order to fulfill your purchase.
  • Promotions. We may operate sweepstakes, contests and similar promotions (collectively, "Promotions") through the Site. We typically ask you for certain personal information when you enter and, if applicable, win a Promotion. You should carefully review the rules, if any, of each Promotion in which you participate through the Site, as they may contain additional important information about our use of personal information. To the extent that the terms and conditions of such rules concerning the treatment of personal information conflict with this Policy, the terms and conditions of such rules will control.
  • Internal Business Purposes. We may also use personal information for our internal business purposes, such as data analysis and audits. In addition, we may also use personal information to enhance our information and to aid us in providing our customers with targeted promotions.

Non-Personal Information. Because non-personal information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to disclose such non-personal information to other third parties, for any purpose.

In some instances, we may combine non-personal information with personal information. If we combine any non-personal information with personal information so that it personally identifies you, the combined information will be treated by us as personal information as long as it is combined.

We may, along with our affiliates and marketing partners, enhance and/or merge personal information about you with data collected from other sources and use it in direct and/or online marketing and, to the extent permitted by law, individual reference and look-up service programs. In the event we enhance and/or merge such personal information with data collected from other sources, we will take reasonable steps to maintain the integrity and quality of that information.

DISCLOSURE OF THE INFORMATION TO THIRD PARTIES

We may disclose information about you to affiliated and non-affiliated third parties.

  • Affiliates. We may disclose the information that we collect to our affiliated companies to provide the products you request, to enhance our products to better suit your needs, for research related to new product development, and from time to time for marketing purposes.
  • Business Partners. We may partner with other companies to offer you products or services or to fulfill the products or services that you order. We may disclose personal information and/or non-personal or de-identified information collected about you to such third-party partners for the purposes described in this Policy.
  • Service Providers. We work with third parties who provide services including but not limited to data analysis, order fulfillment, list enhancement and other administrative services. We may disclose personal information to such third parties for the purpose of enabling these third parties to provide services to us. Such services may include: marketing distribution, email list management services, advertising, certain product functionalities, customer support, web hosting, customer data management and enhancement, fulfillment services (e.g., companies that fill product orders or coordinate mailings), research and surveys, data analysis and email service.
  • Assignment. We reserve the right to transfer any and all information that we collect from Site users to an affiliate or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • Law enforcement; emergencies; compliance; other purposes permitted by law. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose personal information to others as we believe appropriate (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms and Conditions; (d) to protect the rights, privacy, safety or property of MSC Brain Analytics, Inc., our affiliated companies, you or others; (e) to permit us to pursue available remedies or limit the damages that we may sustain; and (f) for any other purpose permitted by applicable law.
  • Aggregate, Non-Personal, or De-identified Information. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal, de-identified, or anonymous information we collect with third parties, including affiliates to develop and deliver targeted advertising on our Site and on the websites of third parties. If you would prefer that we do not utilize cookies with your website experience, or would prefer to restrict the use of cookies with network advertising partners, please see the "Your Choices" section below.

YOUR CHOICES

You have choices when it comes to updating your information, learning about new offers or products offered by us, our partners or affiliates. If you do not wish to receive offers of products from us, our partners or affiliates, here are the methods in which you can opt out:

  • MSC Brain Group Holdings, Inc. Commercial Email. If you prefer not to receive emails from us about offers and Promotions please unsubscribe via the unsubscribe link in an email, or Contact Us. Alternatively, you may opt-out of commercial email directly on the order form while placing a new order.
  • Cookies. Subject to the section above pertaining to cookies and similar technologies, you have the ability to prohibit being served an advertisement based on cookie technology. We utilize reputable third-party vendors to serve advertisements. If however, you are not comfortable with cookies, you can adjust the settings within your browser to further prohibit being served a cookie. Please see the browser's instructions to perform this task.
  • Changing information. Corrections or updates to your information including your email address, phone number, mailing address, credit card information or password reminder phrase can be made through the edit profile section of your account on the Site. If necessary, other corrections or updates to your information can be made by contacting Us. For your protection, our customer care representatives may request supporting documents before making any changes or updates to your membership information.

We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove personal information about you from the databases of third parties with which we have already disclosed personal information as of the date that we implement your opt-out request. If you wish to cease receiving marketing-related e-mails from third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.

PROTECTION AND SECURITY OF THE INFORMATION GATHERED

We have security measures and tools, such as firewalls, in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem as soon as possible by contacting us in accordance with the Section "Contacting Us" below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

THIRD-PARTY WEBSITES AND LINKS

The Site may contain links to third-party websites. These linked sites and all third-party websites that may host our products and services are not under our control and we are not responsible for the privacy practices or the contents of any such linked or third-party site, or any link contained in any linked or third-party site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by us. Unless you are providing personal information to us on a third-party website through an application program interface (API), if you provide any personal information through any such third-party website, your transaction will occur on the third party's website (not on the Site) and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

LOCATION

We control and operate the Site from the Republic of Korea (South Korea), and the Site is not intended to subject us to the laws or jurisdiction of country or territory other than that of the Republic of Korea (South Korea). We do not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

A SPECIAL NOTE REGARDING INDIVIDUALS UNDER 18 YEARS OLD

The Site is not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personal information through the Site. If you are under 18 years of age, you may browse our Site; however, you may not provide personal information to us such as name, address, or email address, and you may not register for, enroll in, and/or make product purchases.

CONTACT INFORMATION

If you have any questions regarding this Policy, please Contact Us via email at info@mscbrain.com. Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.

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