Privacy Policy

This Privacy Policy discloses the practices of Native Brain, Inc. concerning information we obtain by and through your use of the Native Brain website (the “Site”), the Native Brain online services (the “Service”) and/or the Native Brain Mobile Application (the “Product”).  Native Brain is committed to respecting your privacy and recognizing your need for appropriate protection and management of Personally Identifiable Information you share with us. The purpose of this privacy policy is to explain the types of information Native Brain obtains about visitors to our Site and users of our Product and Service, how the information is obtained, how it is used, and the choices you have regarding our use of, and your ability to review and correct, the information.   By using the Site, the Service and/or the Product and by agreeing to Native Brain’s Site Terms of Use, you are accepting and consenting to the use of your information as described in this policy.

1.     What Information We Collect

The information we collect on our Site and through the use of our Product generally falls into the following two categories: Personally Identifiable Information and Non-Personally Identifiable Information.  If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, the combined information will be treated as personal information for as long as it remains combined.

Personally Identifiable Information

Personally Identifiable Information refers to information that lets us know the specifics of who you are. The Personally Identifiable Information we collect when you use our Site may include your name, mailing address, phone number, e-mail address, login name, passwords, etc. We request Personally Identifiable Information when you register on the Site.
Non-Personally Identifiable Information

Non-Personally Identifiable Information refers to information that does not by itself identify a specific individual. The non-personally identifiable data we collect when you visit our Site may include the Uniform Resource Locator ("URL") of the Web site that you came from before visiting our Site, which pages you visit on our Site, which URL you go to next, which browser you used to come to our Site, your Internet Protocol ("IP") address, and any search terms entered on our Site.   We also collect Non-Personally Identifiable Information in the form of statistics and information regarding the Product user’s game statistics, which may be combined with information you submit through the Service so that you can fully enjoy the benefits of Native Brain’s tracking, monitoring, and diagnostic tools.

Information You Provide for Your Children

You may choose to register and create an account for the Service through our Site.  Registration is not required for use of the Product, but certain features may not be available to unregistered users of the Product.  When you register for the Service through our Site, you may be asked to provide certain information regarding your children who use the Product’s educational games and activities; this information may include your child’s age and a username that you select for your child.  Providing this information will allow you to take full advantage of the diagnostic and monitoring tools offered through the Service/Site.  We do not collect Personally Identifiable Information directly from children and the information collected from use of the Product by children relates to game play (scores and statistics); your child will not be able to submit Personally Identifiable Information through the Product or the Service.  However, if you choose to register through the Service, your child’s username may be visible to other users of the Product and/or Service; we encourage you to use caution in selecting a username for your child to ensure that the username you select does not include specific information (i.e., full name, location, etc.) that could be used to identify your child.

Cookies

Our Site uses or may use "cookies" to gather Non-Personally Identifiable Information.  A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. Generally, we use cookies to store information about your preferences and activity during and after your visit to a web site.  Most browsers automatically accept cookies, but you can usually refuse cookies, or selectively accept certain cookies, by adjusting the preferences in your browser. If you turn off cookies, though, there may be some features of our Site that will not be available to you and some Web pages may not display properly.  By using the Site and/or Product, you consent to Native Brain’s use of “cookies.”

2.     Why We Collect Information About You

Our primary goals in collecting information from and about you are to:

• provide you with the all features and functions of the Site, the Service and the Product,
• provide Users with superior service
• provide all visitors a smooth, efficient, and personalized experience while using our Site, Service and/or Product. 

We may also use Non-Personally Identifiable Information on an aggregated and anonymous basis to analyze customer behavior and to help us understand how visitors use our Site and to measure interest in the various pages.   We use this information to gather statistical information,  improve the content of our Site, to make our Site easier to use, and to customize our advertising.  

We may also use information relating to use of the Site and the Product on an anonymous and aggregate basis for research purposes, for marketing and promotional purposes, and to develop new learning tools and solutions; when your information or your child’s information is used for such purposes it will be used anonymously and will not be tied to your Personally Identifiable Information.

We may use Personally Identifiable Information to communicate with you about the Site, the Service and/or the Product, to provide you with marketing and promotional information that we believe may be of interest to you, and for billing and customer service purposes.

3.     How We Collect Information

We collect Personally Identifiable Information only when you provide it to us.  Native Brain does not solicit or collect personal information from children and use of the Product and Service by children results only in the collection/transmission of Non-Personally Identifiable Information to Native Brain, such as game play scores and statistics.  If you do not wish for your Personally Identifiable Information to be used or collected, please do not submit it to us.  There may be times, such as when a User registers through the Site and/or Product and/or signs up for any other product or service we may offer through the Site or the Product, at which we will ask you to provide certain information about yourself, such as your name, street address, telephone number, e-mail address, title, etc. Whether or not you choose to provide such information is completely your own choice. But if you choose not to provide the information we request, you may be unable to use certain services, offers, and content on our Site, or that may be available by using the Product.

Our web servers may automatically collect Non-Personally Identifiable Information, including the web page from which a visitor enters our Site, which pages a visitor visits on our Site, and on some Sites, how much time a visitor spends on each page.  We aggregate this information and use it to evaluate and improve our Site, Service and Product.

Native Brain does not solicit or collect personal information from children and use of the Product and Service by children results only in the collection/transmission of Non-Personally Identifiable Information to Native Brain, such as game play scores and statistics.  You may  choose to submit certain details relating to your children, including age, and you may choose to create a username for your child to enjoy full use of all features available through the Site and the Product. 

4.     How We Use Information About You

Our primary use of your information is to provide you with services through the Site, the Service and the Product.  Your information may be shared with other Users of the Product or Site with whom you choose to share information (for example, a teacher, tutor or other educator).  If you choose to create an account and username on the Site for your child, your child’s username and certain game scores or statistics may also be shared with other users of the Product (for example, a Product user’s username and high score for an activity or reward badge may be shared with other users on a display that is visible to other Product users).  You can update your preferences regarding the sharing of your information at any time by accessing your Profile on the Site. 

We may use Non-Personally Identifiable Information (for example, statistics regarding game play and educational tasks) for research purposes, for marketing and promotional purposes, and to develop new learning tools and solutions and we may share such information with third parties, including researchers and publishers, on an aggregate and anonymous basis.  

We may also use the information you provide for customer support and to respond to your requests in a timely fashion. 

5.     How We Protect Your Information

We use reasonable technological and physical safeguards to protect Personally Identifiable Information you provide to us from loss, misuse and unauthorized access, disclosure, alteration and destruction.  We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet is 100% secure, however. Therefore, while we strive to make all reasonable efforts to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. In the unlikely event of a data breach, you will be notified as soon as reasonably possible.

We urge you to keep any password for use of the Service and/or Site in a safe place and not to divulge it to anyone. Also remember to sign off your account and close your browser window when you have finished your visit to the Site.

6.     How to Correct or Remove Personal Information

If you do not want your Personally Identifiable Information collected or stored, please do not submit it to us. If you have already submitted personal information and would like us to correct or remove your information from our records, please contact Jeff Durso (privtos@nativebrain.com)

7.     Children’s Online Privacy and Protection Act

Native Brain does not knowingly collect personal information from children under the age of 13.  Any information collected from use of the Product by children is strictly anonymous and any data we do collect is aggregated and anonymized.  Any personal information submitted through the Site or the Service is collected from Users (parents or guardians) over the age of 18.  By using the Site or the Service, you represent that you are over the age of 18, that you are the parent or legal guardian of any child for whom you may submit information, that you consent to the collection and use of your (or your child’s) information by Native Brain consistent with this Policy, and that you consent to your child’s use of the Product.

8.     Disclosures to Third Parties

We may share your information with third parties as follows:

• With Affiliates: We may share your information with affiliated companies and businesses that we deem trustworthy and whose privacy policies are consistent with ours.
• With Service Providers: We may use other companies to perform services including, without limitation, facilitating some aspects of our Site or Service such as processing credit card transactions, sending emails, and fulfilling customer service requests. These other companies may be supplied with or have access to your information solely for the purpose of providing these services to you on our behalf.
• With Business partners: When you make purchases or engage in promotions offered through our Site, we may share information with the businesses with which we partner to offer you those products, services, and promotions. When you elect to engage in a particular business partner's offer or program, you authorize us to provide your information to that business partner.
• Special Circumstances: We also may disclose your information, including Personally Identifiable Information, in the following circumstances:
• In response to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law;
• When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Site’s terms and conditions or other agreements or policies.
• In connection with a corporate transaction, such as the sale of all or a portion of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy.  We will endeavor to contact you in the event of any of these transactions, but we do not promise to do so.

9.     Links to Third Party Sites

Our Site may contain links to web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked sites may be different from our privacy policy. You access such linked sites at your own risk. You should always read the privacy policy of a linked site before disclosing any personal information on such site.

If you purchased the Product through a third party vendor, your information will be collected and used by that third party in accordance with its own privacy policy and terms or use.  Native Brain is not responsible for information you submit to third parties.

10.  Policy Changes

To improve the services it can offer you, Native Brain may opt to expand its capabilities for obtaining information about users in the future. Native Brain will update this privacy statement continually to ensure that you are aware of developments in this area. We will post those changes here so that you will always know what information we collect online on through our Product, how we use it, and what choices you have. Please be sure to check this page before proceeding to use our Site or using the Product.

11.  Questions or Feedback

If you have any questions or comments regarding our privacy policy and practice, please  email us at privtos@nativebrain.com or write to us at Native Brain, One Marina Park Drive, 14th Floor, Boston, MA 02210

Last modified: August 21, 2012.