Actum Ventures Limited Privacy Policy

1    Preamble

Actum Ventures Limited (hereinafter “AVL”) has the utmost respect for the privacy of the users of its  website, e-learning classes, edutainment, games and applications. We kindly ask that each of the foregoing users (hereinafter “You”, “Your”) review and make sure You understand this privacy policy before visiting the Login and myBrainspool sections of the brainspool.com website.

This Privacy Policy defines how AVL processes the information You provide through the Brainspool Project website www.brainspool.com, via AVL customer support or by means of any of Your other interactions with AVL (hereinafter collectively referred to as the “Service”). The Service is made available by AVL, a Limited Company established in the U.K. (Companies Act 1986), and registered in England and Wales (Reg. No. 5840967).

YOUR USE OF THE SERVICE SHALL CONSTITUTE ON YOUR PART (I) AN INFORMED, EXPLICIT AND UNRESERVED ACCEPTANCE OF THE TERMS HEREOF; AND (II) A FULL CONSENT FOR THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY AS WELL AS FOR ANY AND ALL POTENTIAL DISCLOSURES OF SUCH DATA IN ACCORDANCE WITH SECTION 6 (DISCLOSURES OF PERSONAL DATA) HEREOF.

IF YOU DO NOT ACCEPT THE PROCESSING OF PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY, AVL HEREBY STRONGLY DISCOURAGES YOU FROM USING THE SERVICE.

IF YOU ARE UNDER 18 YEARS OF AGE OR, IN ANY EVENT, A MINOR IN YOUR COUNTRY OF RESIDENCE, PLEASE ASK YOUR LEGAL GUARDIAN TO COMPLETE YOUR REGISTRATION TO THE SERVICE FOR YOU.

AVL reserves the right to reasonably amend this policy, so please review it frequently.   Your continued use of the Service after such amendment shall be deemed as Your explicit and unreserved acceptance of any such amendments.

2    Your Personal Data File

The name of Your personal data file is “myBrainspool Account” Data File (hereinafter the “Data File”).

3    Why the Processing of Personal Data is Necessary

The purpose of the processing of personal data is to provide and/or manage the services You need and maintain proper customer relationships between AVL and You. The personal data is used to identify users of the Service and for the activation, execution, management and invoicing of the Service as well as for the providing of information and notifications to the customers. Further, Your personal data may be used for the purposes of direct marketing, provided that You have consented to this, as well as for investigation and follow up in cases of misuse.

Personal data may also be used for the planning and development of AVL’s business and services and to measure the amount of customers using the Service. In addition, AVL may use and disclose personal data contained in the data file for legitimate purposes (such as direct marketing, distance selling, other direct advertising, hardware and/or software peformance opinion polls or marketing research) in accordance with the Data Protection Act 1988 (U.K.) and other applicable European Union (“EU”), USA and international legislation.

4    Information AVL Collects from You

AVL collects the following information from You on a “need-to-know” basis only: Your contact information such as e-mail address, delivery address and other contact information that You may have provided to AVL. Further, AVL collects certain personal information regarding Your order, such as payment information, ordered Products, shipment method and Product order number. AVL may also collect other personal information that You have submitted to AVL in connection with the use and/or provision of the Service.

AVL may use third party tools or service providers in order to track Your visits to the Service and Your actions and movements within the Service (such as time, location within the Service and IP address) as well as device- specific ID (the ID of the computer or smartphone or tablet via which You have logged in to the Service) and information regarding Your browser type and Your operating system (collectively referred to as “Traffic Data”).

5   Sources of Information

The personal data in the Data File is acquired from You when You use the Service. Moreover, personal data may be acquired from You when You contact AVL via e-mail or by equivalent means of communication aiming at obtaining access to the Service.

AVL may use cookies for the purposes of acquiring Your information. Cookies are small pieces of information stored on Your computer by means of the web browser You use. No personal data is stored on the cookies themselves.

6    Disclosure and Protection of Personal Data to Third Parties

AVL does not disclose personal data contained in the Data File to third parties on a regular basis. Personal data may, however, have to be disclosed on occasion and in accordance with the laws of the UK and the directives of the EU. Further, personal data may be disclosed for research and marketing purposes (including direct marketing) provided that You have consented to this.  AVL may transfer any portion of Your personal data to its affiliates and partners inside the EU, where personal data protection rules are in force.

Only those persons with a need to process Your data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to the Data File. All data contained in the Data File are protected in accordance with general industry practice.

AVL reserves the right to use subcontractors at its sole discretion in connection with the provision and development of the Service in order to better provide the Service to You.  Personal data may be transferred to such subcontractors to the extent necessary for the provision of services, including but not limited to the storage of data on a server maintained by a third party on assignment by AVL or for the purposes of analyzing Traffic Data in order for AVL to better understand how the users of the Service interact with it. Such data transfers will only be made if and as necessary for the performance under an agreement in Your interest between AVL and a third party and/or for the implementation of an agreement between AVL and You.

7    Non-Financial Data

PERSONAL DATA COLLECTED BY AVL THROUGH THE SERVICE DO NOT INCLUDE ANY FINANCIAL DATA, E.G. YOUR CREDIT CARD NUMBERS OR BANK ACCOUNT NUMBERS OR CREDIT WORTHINESS DATA.

8    Accuracy of  Data and Data Retention

AVL does not verify the accuracy or correctness of the personal data. The data relating to the use of the Service is removed when their storage is no longer necessary.

9    Links to Third Party Websites

The Service may contain links to third party websites, such as information sources (e.g. Wikipedia, or manufacturers websites, etc.) or social networks (e.g. Twitter, Facebook, et.al.). The linked websites are neither controlled nor operated in any way by AVL; therefore, AVL is not responsible for any content on such third party websites or the links that they may contain. Should You visit a linked website, AVL recommends You to review the privacy policy and other applicable terms and conditions of the third party website in question.  If any links are dead or misrepresent themselves, you are kindly requested to send AVL a message (from the “Contact” page) so we can further investigate and remove the link.

10    Data Controlling Entity

Actum Ventures Limited

The Brainspool Project

Address: Hartfield Place, 40-44 High Street, Northwood, Middlesex HA6 1BN, United Kingdom

11    Person in Charge of Privacy Policy Matters

Spyridon Papageorgiou

E-mail: neurons@brainspool.com

Should You have any questions relating to this privacy policy, please contact us at neurons@brainspool.com.

You can also find additional information on the use of the Service in our Terms of Service.

 

 
Copyright © The Brainspool Project, Actum Ventures Limited 2011-2012