Effective Date: November 21, 2023
This Privacy Policy details the data protection practices of The Braintrust Consulting Group, LLC. ("TBCG," "Braintrust," "we," "us," or "our"). This Privacy Policy applies to information that we collect and use about you when you access or use the Braintrust website or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the "Services."
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
The Information We Collect
We collect information about you in several ways as is more discussed below. In order to provide the Services to you, we need certain types of information. If you do not provide us with such information, or request that we delete it, you may no longer be able to access or use our Services.
Information You Provide to Us
We collect a variety of information that you provide to us directly. The following are examples of ways you may provide us information:
The Services you use for processing your orders
Registration information when you create or update your Braintrust account
Any requests for customer support including online forms, email, etc.
Information about your customer service interactions with us
Participating in promotional events or surveys
Classes in which you enroll
Information about purchases or other transactions with us
Information you upload or post within or to the Services
User-generated content you provide to us, such as when you comment on content on the Services, respond to a survey request, review a class, or participate in the public forums
Personal information about you
Your Email address
Name, if you choose to provide it
Phone number, if you choose to provide it
Shipping information for any purchases requiring delivery
Billing information including credit or debit card number, ZIP Code, expiry and verification code
Any reviews or comments that you post
Demographic information such as your gender or other information you choose to provide as part of your Braintrust profile
Any other information you choose to directly provide to us in connection with your use of the Services
Information about others
If you request that your purchase be provided to someone other than yourself, we use the information you provide about the other person to fulfill the appropriate shipment or electronic delivery.
Information We May Obtain Through Other Methods
When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Website Tracking
When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.
Geographic Tracking Information
When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and/or postal code associated with an IP address, city/state) from your computer or mobile device.
Information We Obtain from Content Platforms
If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or X), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your "likes" and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information disclosed, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you enrolled in a class on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.
Information Obtained from Third-Parties
We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to provide a better and more customized experience for you.
Ways in Which We Use Your Information
Your information is used by us or our service providers for a number of purposes. The information we have collected from or about you may be used for the following:
Provide the Services in general or to operate the business
Communications for information requests, customer or technical support
Completion of purchases you may make with Braintrust or our partners
Providing you with updates and information about classes in which you have enrolled
Contact you by email, postal mail, or phone regarding Braintrust and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
Continuous improvement of the Services based on your interests and information
When compelled by law or other regulations to establish, exercise, or defend our legal rights
In combination with the information that we collect through the Services as well as other sources as detailed in this Privacy Policy.
Aggregate Data
We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, promotional partners, and sponsors.
Tracking and Cookies
We and our service providers may use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to create a more customized experience. You can alter the settings in your browser to limit the use of cookies or other tracking methods, but this may limit some of the functions that you can access within the Services. Cookies are small text files that are placed on your computer or mobile device when you visit a site. These files enable us to recognize when you return to our site. We attempt to retain your settings and track the pages you have chosen to visit within the Services. We can also use this information to improve the Services and the information provided by us, our advertisers or other partners.
Analytics and Advertising
Tracking Analytics
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
Advertising
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above, including your email address. These third parties (e.g., ad networks and ad servers such as Google, DoubleClick, Meta, and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications, and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties.
How We May Disclose Your Information
Braintrust will disclose your information in the following ways:
For Legal Purposes
By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Braintrust, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Third Parties
We provide access to or disclose your information to select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
Business Sale or other Related Transactions
Braintrust will disclose your information in the following ways: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
Public Forums
Certain features of our Services may make it possible for you to post comments publicly that other users can see. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
Aggregate/Anonymous Information
From time to time, we may disclose Aggregate/Anonymous Information about use of the Services, such as by publishing a report on usage trends. The disclosure of such data is unrestricted.
Protection of Your Information
We take a number of steps to protect the information we collect. These include security measures in our systems and operations to prevent unauthorized access to the information in our Services. Although we work hard to secure the information in our Services, nothing sent or accessed over the internet is ever completely secure or free from technical or human error. We encourage you to consider this with any information you provide to us.
Access via Mobile Devices
The Service may include certain services that are available via a mobile device, including (i) the ability to upload content to the Service via a mobile device, (ii) the ability to browse the Service and the Site from a mobile device and (iii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the "Mobile Services"). To the extent you access the Service through a mobile device, your wireless service carrier’s standard charges, data rates and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices. In using the Mobile Services, you may provide your telephone number. By providing your telephone number, you consent to receive calls and/or SMS, MMS, or text messages at that number. We may share your phone numbers with our affiliates or with our service providers (such as customer support, billing or collections companies, and text message service providers) who we have contracted with to assist us in pursuing our rights or providing our Services under our Terms of Service, our policies, applicable law, or any other agreement we may have with you. You agree these parties may also contact you using autodialed or prerecorded calls and text messages, as authorized by us to carry out the purposes we have identified above, and not for their own purposes. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Braintrust account information to ensure that your messages are not sent to the person that acquires your old number.
Links to Third Party Sites or Services
The Services contain links to third-party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook "like" button and Twitter "follow" button). If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.
Children's Privacy
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected "personal information" (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
Your Rights and Choices
GENERAL RIGHTS
Depending on your jurisdiction, you may have the right to make certain requests regarding your "personal information" or "personal data" (as such terms are defined under applicable law, and collectively referred to herein as "personal information"). Specifically, you may have the right to ask us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
Provide you access to and/or a copy of certain personal information we hold about you.
Correct or update personal information we hold about you.
Delete certain personal information we have about you.
Object to or restrict processing of your information
Revoke your consent for the processing of your information
Transfer your information to a third-party provider of services
Opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You also have the right to opt out of "sales" of your information and "sharing/use of your information for targeted advertising" as described below in subsection 3.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights or would like to exercise any of them, please submit a privacy request here or email us at privacy@Braintrust.com
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.
OPTING OUT OF MARKETING EMAILS
You can unsubscribe from our marketing emails via the unsubscribe link provided in the emails. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.
NOTICE OF RIGHT TO OPT OUT OF SALES OF PERSONAL INFORMATION AND PROCESSING/SHARING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING PURPOSES
As explained in the "Online Analytics and Advertising" section above, we provide certain information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, and use analytics partners to assist us in analyzing use of our services and our user/customer base. The disclosure of your information to these third parties to assist us in providing these services may be considered a "sale" of personal information under applicable law, or, the processing/sharing of your information for targeted advertising purposes.
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" for purposes of targeted advertising, please click here . You can also submit a sale opt-out request to opt out of our offline disclosures of information that are subject to applicable opt out rights by emailing us at privacy@Braintrust.com. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.
Legal Reasons for Use of Your Information
There are a number of legal reasons for using your information as set out in this Privacy Policy are as follows:
Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you); where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services); where we are required to process information in accordance with an EU Member State legal obligation; or where we have your consent, in accordance with applicable law.
The information discussed in this Policy is processed in the United States by Braintrust, whose principal office in the United States is located at
8911 Sparkleberry Lane, Zephyrhills, FL 33541.
Changes to the Braintrust Privacy Policy
This Privacy Policy may be updated or changed at any time to reflect changes in the law, how or why we collect data, how we use the data, or to support changing features in our Services, or advances in technology. We will post any changes to the Privacy Policy on this page, along with an indication of when it was updated. We recommend periodically checking to see if you have reviewed the most current version. If a substantial change occurs to the policy, we will make commercially reasonable efforts to proactively communicate this to you via your online information. Please note that your use of the Services confirms you have read, understood and agree to the condition of this Privacy Policy.
Contact Information
Please feel free to contact us if you have any questions about the Braintrust Privacy Policy or the information practices of the Services.
You may contact us as follows:
The Braintrust Consulting Group, LLC
PO Box 172607
Tampa, FL 33672