Privacy Policy

Last Updated: July 24, 2018

Cambridge Brain Sciences Inc. and its subsidiaries and affiliates (collectively, “CBS,” “we,” “us,” or “our”) may collect personal information in the course of providing you with our services. This CBS Privacy Policy (“Privacy Policy”) explains how CBS handles your personal information when you visit or use: (a) the CBS websites located at www.cambridgebrainsciences.com, health.cambridgebrainsciences.com, research.cambridgebrainsciences.com, brainlabs.me, legal.cambridgebrainsciences.com or home.cambridgebrainsciences.com (the “CBS Websites”); and (b) all other services provided by us, as described on, or provided through, the CBS Websites, including our web-based software-as-a-service solutions that are designed to test and assess cognitive functions by administering tests of memory, attention, reasoning and planning and collecting and displaying the resulting data (such web-based software-as-a-service solutions, the “Platforms”), and any other website that links to this Privacy Policy (collectively, the “CBS Services”).

CBS makes available the following Platforms, which are accessible to users with an active Account (as defined below) for the applicable Platform:

(a) health.cambridgebrainsciences.com, designed to provide health and wellness providers with the ability to quantify and track a client’s cognition through administering tests in key cognitive domains such as memory, reasoning and concentration;

(b) legal.cambridgebrainsciences.com, designed to provide lawyers with the ability to quickly and conveniently quantify a client’s executive function;

(c) research.cambridgebrainsciences.com, designed for research and commercial-focused use in connection with the controlled assessment and analysis of cognitive function in targeted groups; and

(d) brainlabs.me, designed to enable users to test their cognition, track it over time, and compare their results to other users.

1. Collection of Information

CBS offers web-based Platforms for measuring and tracking cognition. Our scientifically valid tests (the “Test” or “Tests”), which are based on over two decades of pioneering research by leading neuroscientist Dr. Adrian Owen and are backed by hundreds of peer reviewed articles in scientific journals, evaluate such cognitive elements as memory, reasoning, verbal ability, and concentration.

The CBS Services are enabled by the CBS Websites. By using the CBS Services, CBS may collect the following types of information:

(a) Account Information:

To access and use certain features of the CBS Services, you may need to register for a CBS account (the “Account”) through the available CBS interfaces, namely, the CBS Websites. During the registration process, you may be asked to provide us with information such as your full name, email address, gender, city or town, education level, occupation, and picture. You may also be asked to choose a username, password and security questions. If you are using the CBS Services offered by a third party such as a healthcare practitioner, researcher, or lawyer (a “Third Party Provider”), your Third Party Provider will obtain your consent to create an Account on your behalf by providing your email and a unique Account ID to CBS.

In registering for an Account (or after registration), you may be able to provide your social media login information and password through platforms such as Facebook. If you do so, you authorize us to access certain social media account information (consistent with your social media privacy settings), including but not limited to your profile information, full name, username, email address and full physical address. All such information is provided directly by the social media platform, whose use of your personal information will be subject to its own privacy policy and terms of use.

(b) Information Related to the Tests

To use the CBS Services, you will need to complete Tests related to cognitive elements, such as, memory, reasoning, verbal ability and concentration. Your responses to each Test will be collected and tracked over time.

Further, we may collect your responses to questions related to such lifestyle and other factors as your stress level, sleep amount and physical activity as these factors may have an impact on your Test results.

When completing a Test, if you do not wish to make optional personal information available, you do not have to complete those sections. If you supply personal information and later wish for it to be removed, please contact us at info@cambridgebrainsciences.com.

(c) Payment Processing Information

When you pay for the CBS Services, we collect payment information from you such as credit card information for processing by our third party payment service provider. We retain the last four digits of your credit card in an encrypted format to link the payment that you have made to your Account. Aside from the last four digits of your credit card, we do not retain any payment processing information or any financial information such as credit card numbers. All such information is provided directly to our third party processor, Stripe Payments Canada Ltd., whose use of your personal information will be subject to the payment processor's own privacy policy and terms of service. If you are using the CBS Services offered by a Third Party Provider, we will not collect payment information from you.

(d) Information We Collect When You Visit Our Websites When you use a computer, tablet, smart phone or other device to access the CBS Websites, we may collect information about the device and how you use it. This information may include the type of device, your operating system, your browser (for example, whether you used Internet Explorer, Firefox, Safari, Chrome or another browser), your internet service provider, your domain name, your internet protocol (IP) address, your device identifier (or UDID), the date and time that you accessed our service, the website that referred you to the CBS Websites, the web pages you requested, the date and time of those requests and your physical location.

2. Use of Information

We use the information described above to:

(a) provide the CBS Services to you which include, but are not limited to allowing users to test their cognition and track it over time, as well as comparing their results to others;

(b) maintain, enhance and modify the CBS Services;

(c) communicate with you, where such communications may include, but are not limited to, informing you of developments to the CBS Services;

(d) assess whether the results of the Tests are affected by factors such as age, occupation, education level, stress, sleep and physical activity; and

(e) comply with legal and regulatory requirements. We may use information for any purpose if we aggregate and anonymize it so that it no longer reasonably identifies you.

3. Disclosure of Information

We may transfer or disclose information as follows:

(a) Service Providers Arrangements

Your information may be transferred (or otherwise made available) to our affiliates and other third parties who provide services on our behalf. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes.

Your information may be stored and processed by us, our affiliates and other third party service providers in the United States or other jurisdictions. In the event that personal information is transferred to the United States or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

(b) Legal and Compliance

We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

(c) Sale of Business

Personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of CBS or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

(d) Aggregated and Anonymized Data

When you participate in a Test, you are assisting our world-class research into neuroscience and cognition and improving the scientific value of the Tests themselves. The personal information we collect when you participate in Tests (such as your responses to queries) will be de-identified, aggregated and used for our research and analysis to help us better understand the Tests and serve our users. All data is analyzed anonymously and will not be presented in identifiable form. For example, results may be presented to indicate that the average score of a 27-year-old left-handed user for an attention Test is 53, but that right-handed users score 52. Any personal information that might identify a user will be kept confidential and not shared with any third party (except as otherwise set out in this Privacy Policy).

Information that is aggregated and anonymized so that it does not reasonably identify you may be shared with or sold to third parties.

4. Safeguarding and Retention of Personal Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

5. Access to Personal Information

You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may make a request to access, update and/or correct inaccuracies in your personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

6. Cookies and Other Tracking Technologies

We use cookies and other tracking technologies for the following purposes: (i) to operate the CBS Services; (ii) to understand how the CBS Services function and are used; (iii) to personalize the content we present you on the CBS Services, (iv) to provide or improve the CBS Services; and (v) to provide you with offers that may interest you (including on third-party websites). Some cookies exist only during a particular session and some are persistent over multiple sessions over time. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the CBS Services, you may not be able to take advantage of all of the features on the CBS Services.

7. Third Party Websites

The CBS Websites may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our service and go to another site. During this process, another entity may collect personal information from you.

8. Updates to the Privacy Policy

We may update this Privacy Policy to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices.

9. Contact Us

CBS welcomes your comments and questions regarding this Privacy Policy and the use of your personal information. To respond to your request, we may ask you for your full name, email address and phone number. If you have questions or concerns, please contact our Privacy Office at info@cambridgebrainsciences.com.