Any processing of personal data is carried out under the responsibility of SKILL WAGON, a limited liability company incorporated under English law, registered in the United Kingdom under number 15627219, whose registered office is at 7 Bell Yard, London, WC2A 2 JR, United Kingdom (hereinafter "BRAINLify"). BRAINLify can be contacted by e-mail at the following address:
Any transfer of data to a partner is carried out with your consent and the partner's processing of data is subject to the partner's confidentiality policy.
BRAINLify may collect and process some or all of the following data:
| CATEGORY OF PERSONAL DATA PROCESSING | DESCRIPTION OF THE CATEGORY |
|---|---|
| Data processed in connection with the use of the Learner's Personal Account on the Site |
This is the personal data collected from the Learner when creating and managing a Customer account on the Site and/or placing an order. It may include in particular
|
| Contact Form | This is the personal data provided to make contact via the Site. It includes the surname, first name, e-mail, subject and content of the message. |
| Connection and browsing data |
The cookies placed on your terminal give us access to the following information:
|
The compulsory or optional nature of the data is specified when it is collected. If this information is incomplete, obsolete or inaccurate, it may be impossible to create an account on the Site.
BRAINLify does not collect any sensitive data about you.
Sensitive data concerns the processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation.
If such data is provided to BRAINLify, please contact us by e-mail at the following address: contact@brainlify.ai so that it can be deleted.
Your personal data is collected for the following purposes:
| LEGAL BASIS | PURPOSE |
|---|---|
| Use of your data for the performance of the contract |
On the basis of the performance of the contract between us, BRAINLify uses your data to :
|
| Use of your data on the basis of your consent |
On the basis of your consent, BRAINLify uses your data to :
|
| Use of your data on the basis of our legitimate interests |
On the basis of our legitimate interest, in particular with a view to ensuring better quality of our services, BRAINLify uses your data to:
|
| Use of your data to comply with our legal obligations | BRAINLify may process your data for evidential purposes and to comply with its legal obligations. |
The length of time personal data is kept varies according to the purpose for which it was collected:
| DATA CONCERNED | THE DURATION OF THE CONVERSATION |
|---|---|
| Your bank card details | This data is kept by our payment service provider until the last payment due date and, for the purposes of proof in the event of a claim, for 13 months, or 15 months in the case of a deferred debit card. |
| Data relating to use of the Site | This data is kept for a period of 5 years after your request to unsubscribe from the Site, in particular for evidential purposes, it being specified that after a period of inactivity of 3 years, the account may be deleted. |
| Data relating to the management of your contract and orders | This data is kept for a period of 5 years after each order, in particular for purposes of proof. In the event of a dispute, the data required to process the dispute may be kept beyond this period until the end of the dispute. |
| Data relating to the sending of information and commercial offers relating to our services (email, telephone) | This data is kept until you request unsubscription or deletion of your personal data, or after a maximum period of 3 years following the last contact from the person concerned. |
| Information required to comply with legal obligations is kept for the legal retention period. |
|
| Cookies placed on your terminal | This data is only kept for as long as is necessary to achieve its purpose (for example, session identification cookies are only kept for the duration of a session) and for a maximum of 13 months. Your choices regarding cookie settings are retained for a maximum of 6 months. |
We undertake to treat all your personal data as confidential.
BRAINLify's internal team may have access to your personal data but only in the course of their duties and for the purposes set out in this Policy.
We do not share your data with third parties, except in the following limited cases:
Your personal data may be stored in various countries outside the European Union, including the United States. In the event of data being transferred in this context, we check that the processing is carried out in accordance with this privacy policy and that a sufficient level of protection is guaranteed in compliance with the applicable regulations, either as part of contractual obligations or as part of adequacy decisions.
7.1 - Your rights of access to your personal data
In accordance with Article 13 of Regulation (EU) 2016/679 of 27 April 2016 and Article 32 of Law 78-17 of 6 January 1978, you are informed that you have the following rights:
| Right of access | This is your right to obtain confirmation as to whether or not your data is being processed, and if so, to access this data. |
| Right of rectification | This is your right to obtain, as soon as possible, the rectification of inaccurate data and the completion of incomplete data. |
| Right of deletion | This is your right to obtain, as soon as possible, the deletion of your data, subject to our legal retention obligations and our legitimate interest in retaining this information. |
| Right of limitation | This is your right to obtain the restriction of processing when you object to it, when you dispute the accuracy of your data, when you believe that processing is unlawful, or when you need it for the establishment, exercise or defence of legal claims. |
| Right to object | This is your right to object at any time to the processing of your data by BRAINLify, except where BRAINLify has legitimate reasons to do so. You may also object to the processing of your data for commercial prospecting purposes. |
| Right to portability | This is your right to receive your data in a structured, commonly used, machine-readable and interoperable format and to pass it on to another data controller without us interfering. |
| Right not to be subject to a decision based on automated processing | You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning or affecting you, except where such a decision is necessary for the conclusion or performance of a contract, or is authorised by law. |
| Instructions in the event of death | You have the right to give instructions concerning the fate of your personal data in the event of your death. |
How can you exercise your rights?
You can send any request accompanied by a copy of an identity document by e-mail or by post.
In accordance with Article 17 of Regulation (EU) 2016/679 of 27 April 2016, exercising these rights must not deprive BRAINLify of its right to retain data in order to comply with its legal obligations and for evidential purposes.
7.2 - Your rights to object to commercial offers
| Commercial offers by e-mail or SMS |
On the forms you fill in, your consent may be sought to receive offers from us and, where appropriate, from our partners. However, your express prior consent is not required if you are already a BRAINLify customer and the purpose of our request is to offer you products or services similar to those we already provide. How to object? :
|
| Commercial proposals by telephone |
If you do not wish to receive commercial offers on your personal telephone number (if this has been communicated to us), you can refuse to receive them:
|
The Site has not been designed for use by minors (under the age of 18). Under no circumstances do we authorise the use of our services by minors under the age of 18. We do not knowingly collect personal data from minors. If a parent becomes aware that his or her child has provided us with personal data (or if a guardian becomes aware that the child for whom he or she is responsible has provided us with personal data), he or she should contact us by e-mail.
BRAINLify has put in place physical and electronic security measures as well as safeguard procedures in relation to the collection, storage and communication of your personal data, in particular:
A cookie is a small text file placed on your terminal's hard drive when you visit a website or mobile application. It records certain information about your browsing or online behaviour which enables us to improve and facilitate your experience as an Internet user. For the purposes of this Charter, the term cookie includes any other similar technology used to collect this information.
The Site uses cookies to differentiate between Internet users in order to improve their browsing experience and the services offered to them. In practice, cookies enable you to be authenticated and identified, and may, where appropriate, record your preferences or measure the various uses of the Site.
10 .1 - What cookies do we use?
These cookies are not subject to your consent as they are necessary to enable the basic functions of the Site. Without these cookies, the Site cannot function properly. They help to make a website usable by activating the basic functions. Deactivating these cookies prevents you from browsing the Site.
10 .2 - Your choices regarding cookies
In accordance with CNIL recommendations, your choices concerning cookies are kept for a maximum of 6 months.
However, you may at any time express or modify your wishes with regard to cookies using the cookie management tool that our Site makes available to you at the bottom of any page of the Site. The choices expressed via this management tool are valid only on the Site.
You can also configure your browser to :
To do this, simply refer to your browser software and follow its instructions. For example :
Your choices will then be applied to all browsing on the Internet from your terminal and not just on our Site. If your Internet browser permits, you can deactivate these cookies at any time by referring to the procedures detailed above.
As indicated above, by choosing to block our cookies, we wish to inform you that browsing the Site and/or using certain functionalities may be altered, or even impossible to use.
10 .3 - Further information
If your terminal is used by several people and when the same terminal has several browsers, we cannot be certain that the services intended for your terminal correspond to your own use of this terminal and not to that of another user of this terminal.
You are free to choose and are responsible for sharing the use of your terminal with others and for configuring your browser settings with regard to cookies.
For any additional information or to send us your comments regarding the use of cookies, you can contact us by post at the :name head office or by e-mail.
This Privacy Policy may be amended, supplemented or updated in order to comply with any legal, regulatory, case law or technical developments. However, your personal data will always be processed in accordance with the Policy in force at the time it was collected, unless you agree otherwise or if a mandatory legal requirement stipulates otherwise.