Privacy Policy

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1. Privacy Policy of Rethinking the Brain Pty Ltd

 

“Brain Camp” means training courses, services and all materials delivered by Rethinking the Brain Pty Limited. 

Rethinking the Brain Pty Ltd collects some Personal Data from its Users. Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section. This document can be printed for reference by using the print command in the settings of any browser.
 

‍2. Owner and Data Controller
‍Rethinking the Brain Pty Ltd
14A Melbourne Ave,
Mona Vale, NSW 2103
 

‍Owner contact email: admin@brain-camp.com.au
 

From time to time, Rethinking the Brain Pty Ltd may be related to other companies and entities (related entities). Except in respect of Rethinking the Brain Pty Ltd's responsibilities as Data Controller, a reference in this privacy policy to Rethinking the Brain Pty Ltd, Owner, we, us or our is also a reference to those related entities. This privacy policy applies to the use of your Personal Data by Rethinking the Brain Pty Ltd and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices.  To the extent that those privacy policies are inconsistent with this privacy policy, those privacy policies will prevail over this privacy policy in relation to the actions of those related entities.  
 

‍3. Types of Data collected
‍Among the types of Personal Data that Rethinking the Brain Pty Ltd collects, by itself or through third parties, there are: Cookies; Usage Data; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; first name; last name; phone number; address; geographic position.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Rethinking the Brain Pty Ltd.
Unless specified otherwise, all Data requested by Rethinking the Brain Pty Ltd is mandatory and failure to provide this Data may make it impossible for Rethinking the Brain Pty Ltd to provide its services. In cases where Rethinking the Brain Pty Ltd specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Rethinking the Brain Pty Ltd or by the owners of third-party services used by Rethinking the Brain Pty Ltd serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Rethinking the Brain Pty Ltd and confirm that they have the third party's consent to provide the Data to the Owner.
 

‍4. Mode and place of processing the Data
 

‍5. Methods of processing
‍The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Rethinking the Brain Pty Ltd (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
 

‍6. Legal basis of processing
‍The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
 

‍7. Place
‍The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
 

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
 

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
 

‍8. Retention time
‍Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
 

Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
 

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
 

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
 

‍9. The purposes of processing
‍The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Remarketing and behavioural targeting, Advertising, Heat mapping and session recording, Managing contacts and sending messages, User database management, Tag Management, Displaying content from external platforms, Managing support and contact requests, Contacting the User, Location-based interactions, Handling payments and Hosting and backend infrastructure, in each case including by or on behalf of its related entities.For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
 

‍10. Detailed information on the processing of Personal Data
‍Personal Data is collected for the following purposes and using the following services:
 

‍Advertising
‍This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Rethinking the Brain Pty Ltd, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside Rethinking the Brain Pty Ltd. For more information, please check the privacy policies of the relevant services. In addition to any opt-out offered by any of the services below, the User may opt-out of a third-party service's use of cookies for certain advertising features by visiting the Network Advertising Initiative opt-out page.
 

‍Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
 

‍11. Direct Email Marketing (DEM) (Rethinking the Brain Pty Ltd and its related entities)
‍Rethinking the Brain Pty Ltd and its related entities use the User Data to propose services and products provided by Rethinking the Brain Pty Ltd, Brain Camp, and their related entities, and by third parties including services and products unrelated to the product or service provided by Rethinking the Brain Pty Ltd. Personal Data processed: email address; first name; last name.
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‍Contacting the User
 

12. Mailing list or newsletter (Rethinking the Brain Pty Ltd)
‍By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Rethinking the Brain Pty Ltd. Your email address might also be added to this list as a result of signing up to Rethinking the Brain Pty Ltd or after making a purchase. Personal Data processed: address; email address; first name; last name; phone number; Usage Data.
 

‍13. Contact form (Rethinking the Brain Pty Ltd)
‍By filling in the contact form with their Data, the User authorizes Rethinking the Brain Pty Ltd to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data processed: email address; first name; last name; various types of Data.
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‍Handling payments
‍Payment processing services enable Rethinking the Brain Pty Ltd to process payments by credit card, bank transfer or other means. To ensure greater security, Rethinking the Brain Pty Ltd shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
 

‍14. Stripe (Stripe Inc)
‍Stripe is a payment service provided by Stripe Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.
 

‍15. The rights of Users
‍Users may exercise certain rights regarding their Data processed by the Owner. Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.I n particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. 

• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority. In Australia, Users also have the right to complain directly to us. Further details are provided in the section on how to exercise these rights, below.
 

‍16. Details about the right to object to processing
‍Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing and opt out or unsubscribe at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document. If you do not want to receive marketing information from us or if you want to stop receiving telemarketing, you can unsubscribe in any of the following ways: (a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us; or (b) contacting us using the contact details provided in this document.
 

‍17. How to exercise these rights
‍Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month. If you have made a privacy complaint directly to us, we will investigate your complaints within a reasonable period of time depending on the complexity of the issue. It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint. We will notify you of the outcome of our investigation.
 

‍18. Applicability of broader protection standards
‍While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.
Such broader protection standards apply when the processing:
• is performed by an Owner based within the EU;
• concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
• concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behaviour taking place in the EU.
 

‍Additional information about Data collection and processing
 

‍19. Legal action
‍The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Rethinking the Brain Pty Ltd or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
 

20. Additional information about User's Personal Data
‍In addition to the information contained in this privacy policy, Rethinking the Brain Pty Ltd may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
 

‍21. Information not contained in this policy
‍More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
 

‍22. Changes to this privacy policy
‍The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Rethinking the Brain Pty Ltd and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references
 

Personal Data (or Data)
‍Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
 

User
‍The individual using Rethinking the Brain Pty Ltd who, unless otherwise specified, coincides with the Data Subject.
 

‍Data Subject
‍The natural person to whom the Personal Data refers.
 

‍Data Processor (or Data Supervisor)
‍The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
 

‍Data Controller (or Owner)
‍The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Rethinking the Brain Pty Ltd. The Data Controller, unless otherwise specified, is the Owner of Rethinking the Brain Pty Ltd.
 

‍Rethinking the Brain Pty Ltd (or this Application)
‍The means by which the Personal Data of the User is collected and processed.
 

‍Service
‍The service provided by Rethinking the Brain Pty Ltd as described in the relative terms (if available) and on this site/application.
 

European Union (or EU)
‍Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
 

‍Cookie
‍Cookies are Trackers consisting of small sets of data stored in the User's browser.
 

‍Tracker
‍Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
 

‍Legal information
‍This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).This privacy policy relates solely to Rethinking the Brain Pty Ltd, if not stated otherwise within this document.