BrainRunner Inc. (“CampBrain”) Privacy Policy

Introduction

We respect our customers’/prospective customers’ (“You”/”Your”) and Your Customers’ (defined as Your customers and other stakeholders with respect to whom You collect Personal Information, including campers, staff and their families) right to privacy with respect to Personal Information (as defined in the Canadian Personal Information Protection and Electronic Documents Act). Personal Information collected by us will be kept strictly confidential and will only be collected, used and disclosed as provided for in this policy or as otherwise specifically consented to by You. The policy will apply to and protect Personal Information collected by CampBrain, except information that is aggregated in such a manner that it cannot be connected to a person, information which is publicly listed in a written or online directory or typically made available through directory assistance, and an employee’s name, title, business address (including email address) and business phone and fax numbers.

As CampBrain’s business and customer relations are inherently “business to business” in nature (i.e., with the camps and similar entities utilizing the CampBrain software), Personal Information provided directly from individuals to CampBrain is for the most part limited to that provided by You, Your employees or Your representatives in inquiring about, subscribing to, implementing and managing the relationship between You and CampBrain, as well as the software and related services provided by CampBrain. However, a large part of the Personal Information actually in CampBrain’s possession comes to CampBrain indirectly from the individuals to whom such information relates (i.e., Your Customers), as a result of You and other CampBrain customers choosing to provide us with database and other information for the purpose of providing You certain requested services such as initial import/migration, customization, maintenance, support and professional services (collectively, “CampBrain Services”). As CampBrain generally has no direct customer or other relationship/interaction with the individuals (i.e.,Your Customers) whose Personal Information populates the databases and storage mechanisms provided by You from time to time, CampBrain assumes and is depending on the fact that You have received the requisite consent from such individuals to collect and possess that Personal Information, as well as to provide such Personal Information to CampBrain for the above-noted purposes.

Collection of Personal Information

As indicated above, we only collect Personal Information that You consciously provide us with in the following circumstances and using the following means.

Inquiries

When You inquire about our company, products or services, Personal Information may be collected through e-mail, telephone conversations or the completion of forms. This information is provided voluntarily by You to provide us with certain background information about You or Your business so that we can mutually assess the prospects for You to find out more about, assess and potentially purchase, our products or services. The type and accuracy of the information collected is solely contingent upon what You provide. Typical information provided includes contact name, address, e-mail and phone number, some of which does not constitute Personal Information. We maintain this Personal Information only for the purposes of serving You and providing You with information on our products, services and company.

Website Visitors

As You browse our website, web servers collect information about Your visit. Via web server logs, we monitor statistics such as:

  • How many people visit our website.
  • Which pages people visit on our website.
  • From which domains our visitors come.
  • Which browsers people use to visit our website.

We use these statistics to improve our website, monitor its performance, improve the relevance of the content, and to make it easier for You and other visitors to use. There are no personally identifiable details collected, with the exception of information voluntarily provided by You, such as Your email address in the event that You contact us in that manner.

Customers

When You purchase our products or services, it is necessary for us to collect and retain certain types of information about You and Your business in order to best service Your needs. We will collect contact information, business type, business size and other related information for administrative purposes, through a “checklist” provided upon sign-up and other means of communication. As part of our service on some of our products, we use detailed information about Your products and services to configure and customize the software purchased from us. In certain circumstances, this may include Personal Information of Your Customers. We use this information only to provide a more complete, better product to You. The information that You provide to us is optional, at Your discretion and subject to Your obligation to obtain the requisite consents from the individuals involved to convey any such Personal Information to us for the purposes described in this policy.

At certain times, You may provide us with Personal Information, including what would likely be considered sensitive data such as financial payment information and health information, in an electronic format either for the purpose of transferring said data into our software on Your behalf (for example, importing existing data into the software upon commencement of the relationship), or for providing other CampBrain Services to You on Your existing software. We only use this data for the purpose of completing the required work requested by You. The nature and extent of any data that You provide to us is optional.

In connection with the provision of CampBrain Services, as requested by You from time to time, we offer the ability for You to initiate remote access to Your computers. Such access inherently entails access to the software, related database information and any other information visible or accessible on such computer on the part of our employees or contractors. Any such access will be initiated by You and specifically consented to via a click-through checkbox built into the software.

Use and Retention of Personal Information

Any Personal Information collected by us will be used solely for the purposes of carrying on our internal business affairs and providing CampBrain Services to You, as You may request and authorize from time to time. Any Personal Information in our possession is stored electronically, either on our server or on other electronic storage media that may be retained as part of Your files or otherwise.

The Personal Information we collect directly will be used to create customer profiles for our records only, to be used during the course of our active business dealings.  Subsequent to the conclusion of our business relationship, this Personal Information will be retained only for the purposes of maintaining company records in accordance with reasonable and legal standards.

When You provide us with Your database and other information related to Your use of the Software so that we can provide CampBrain Services, we will generally maintain a copy on our server for backup and potential future remedial or ongoing service purposes.

From time to time, we will review historic database information on our server and in our customer files and, where no longer needed or relevant for the above-noted purposes, we will destroy, erase or make anonymous such information.

We do not currently convey Your or Your Customers’ Personal Information to third parties for the purposes of outsourcing CampBrain Services or other storage or processing. To the extent that may occur in the future, CampBrain commits to contractually bind such entities to abide by the fundamental terms of this policy and applicable laws, including with respect to their capability to use, disclose and retain such Personal Information.

From time to time, we may post the following information on our website: customer contact information, links to their websites and comments or feedback pertaining to our products and services. This information is posted to provide potential customers with further information on and assessment of our products and services, and is only done with Your prior consent.

From time to time, we may offer links to other websites from our site. We neither support nor necessarily endorse any of the products, services or opinions contained on any of these sites.  Furthermore, if You elect to visit any of these sites, we recommend that You familiarize Yourself with their respective privacy policies, as they may, to the extent they exist, differ from ours, as may the laws respecting Personal Information protection in their jurisdiction.

Except as provided for in this policy, we will not sell, rent, lease, commercially exploit or otherwise disclose inquiry, visitor or Your/Your Customer Personal Information or data to third parties unless: (i) required by law or to cooperate with any bona fide legal investigation; (ii) required to protect the legal interests of CampBrain, including for credit checking and collection purposes, as applicable; or (iii) You provide consent to such disclosure.

Access

You may access or inquire about Your or Your Customers’ Personal Information in our possession at any time during our business hours. The Personal Information requested will be provided within a reasonable time, and at a minimal or no cost to You.

You always have the right to request that we delete, destroy, return, amend or update Your or Your Customers’ Personal Information in our possession as You may direct, subject to reasonable notice.

NOTE: In certain situations, CampBrain may not be able to provide access to all of the Personal Information it holds about You or Your Customer. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. CampBrain will provide the reasons for denying access upon request.

Security

We have security measures in place to protect against the loss, misuse, access to or alteration of Your and Your Customers’ Personal Information and data under our control. We operate computer networks that are protected by industry standard firewalls and password protection. Appropriate physical and managerial security is also in place. including but not limited to the execution by our employees of a confidentiality/non-disclosure agreement as a standard practice of our hiring and employment.

While we cannot guarantee that loss, misuse or alteration to Your or Your Customers’ information and data will not occur, we will use our resources and expertise to attempt to prevent such occurrences.

We commit to providing a minimum of an annual review and training with respect to this policy among our staff with potential access to Your or Your Customers’ Personal Information.

Notification of changes

We may update this privacy policy from time to time, so please review it periodically on our website at http://www.campbrain.com/privacy. However, regardless of our right to update this policy as indicated, we will never use Personal Information that You have provided to us in a new way without providing You an opportunity to give us Your consent.

Existing Personal Information

This policy applies to both existing Personal Information in our possession and future Personal Information that may come into our possession as described in this policy. With respect to Personal Information already collected prior to the publication of this policy, this policy will constitute reasonable notice to You, Your Customers and our employees of the purposes and uses for which such Personal Information has been collected. Should You object to these ongoing uses or disclosures, consent may be withdrawn as indicated above.

Complaint Procedure

In the event of any dispute, complaint or problem with respect to this policy and related CampBrain practices, a definitive procedure for resolution has been established as outlined below. CampBrain is committed to resolving any such issues promptly, justly, objectively and, where possible, confidentially.

A written outline of the issue should be forwarded directly to the Privacy Officer of CampBrain, who in turn will investigate, examine and evaluate all the facts. On the information gathered and other related details, a formal written decision will be completed and will be forwarded to You within 30 days of the Privacy Officer’s receipt of Your complaint. During investigation of the issue, it may be necessary for further Personal Information to be shared with the Privacy Officer or other appropriate parties internal or external to CampBrain. In all cases, CampBrain will remain responsible for the protection of all such Personal Information.

You may also contact the office of the Privacy Commissioner of the federal government if You are dissatisfied with the implementation of the policy by CampBrain.

Contact us

For further information concerning this privacy policy or its application or for access to Your or Your Customers’ Personal Information, please write to us, in English only, via e-mail at privacy@campbrain.com. The Privacy Officer at CampBrain is Rob Carmichael.