Your privacy is important to us (but you already knew that). It’s our policy to respect your privacy and comply with any applicable law and regulation regarding the personal information we collect about you through this website, 36brains.com, and through any associated services and third-party platforms we may use.
This policy was last updated on September 27, 2021.
1. Information we collect
Personal information is any information about you which can be used to identify you. Any information we collect may be automatically collected (i.e. information automatically sent to us by your devices when you access our services) or voluntarily provided (i.e. information you knowingly and actively provide us).
2. Automatically collected information
Our servers automatically log standard data provided by your web browser when you visit our website. This data may include your device’s IP address, device type, operating system, browser type and version, the pages you visit, the time and date of your visit, time spent on each page, and other details about your visit or device.
Device data we collect can depend on the settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Additionally, if you encounter errors on this site, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other information relating to the problem. You may or may not receive notice of such errors.
Please be aware that while this information may not be personally identifying by itself, it is possible to combine it with other data to personally identify individual persons.
3. Voluntarily provided personal information
When you use our contact form, we ask for personal information such as your name, email address, website address, and work information.
When you contact us or interact with us on social media, we may collect the personal information associated with your activity, such as your name and profile.
4. User generated content
We generally do not involve user-generated, meaning content on the website generated by users. However, from time to time it may be possible that users generate content through comments or reviews, voluntarily submitted by our users and customers through the widgets. We may use personal information in order to attribute user-generated content we publish on our site and on other platforms (including social media platforms).
5. How we collect and use your personal information
We only collect and use your personal information when we have legitimate reasons (what are considered to be “lawful bases” by the EU General Data Protection Regulation) for doing so, such as following up after a contact request, responding to your email, and identifying you so we can assist you with a support enquiry.
In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our reasons depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
6. Consent From You
7. Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you purchase a product or service from us, we would need to use your personal and payment information in order to process and deliver the requested service to you.
8. Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. For example, we collect technical information about your device in order to improve and personalize your experience of our website. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
9. Compliance with Law
10. Processing your personal information
Personal information will not be further processed in a manner that is incompatible with the aforementioned purposes.
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, we may combine personal information voluntarily provided in an email enquiry with anonymised analytics data to understand regional demands for our services.
11. Data Controller / Data Processor
The EU General Data Protection Regulation distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). Within the bounds of this definition, 36Brains is a data controller with respect to the personal information you provide to us.
12. Disclosure of personal information to third parties
We may disclose personal information to a parent, subsidiary, or affiliate of our company; third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators; our employees, contractors, and/or related entities; our existing or potential agents or business partners; courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; third parties to collect and process data; an entity that buys, or to which we transfer all or substantially all of our assets and business.
Third parties we currently use include Google Analytics, Google Adwords and Google Optimize for analytics, search engine marketing, and A/B testing; Amazon for our web hosting, data hosting and data storage.
13. Storing and protecting your personal information
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
14. Children’s Privacy
We do not aim any of our products or services directly at individuals under the age of 18, and we do not knowingly collect personal information about individuals below this age.
15. International transfers of personal information
The personal information we collect is stored and/or processed in Europe, and where we or our partners and third-party providers maintain facilities.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
16. Your rights and controlling your personal information
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer, we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like reviews and attribution, even after you have requested deletion of the information from our services.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.
18. Business transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
19. Limits of our policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
20. Changes to this policy
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
21. External links
22. Contact us
For any questions or concerns regarding your privacy, please contact us at firstname.lastname@example.org