BrainRunner Inc. Privacy Policy

Introduction

BrainRunner Inc. dba CampBrain (“CampBrain, “we” or “us” and terms of similar meaning), is committed to your privacy.  This means we do not transfer, distribute, disclose, rent or sell any of your Personal Information (as defined below) to third parties except as provided for in this policy (the “Privacy Policy) or as specifically consented by you.

CampBrain operates an online camp management software for camp administrators and others to facilitate the enrollment and registration of yourself or other family member(s) (collectively, “You”, “Your” or other applicable derivations) at the camp(s) and organization(s) you have selected.  Most Personal Information that we collect from You is as the service provider for such camps and customers (our “Customers”).  We refer to such Personal Information as “Camp Data” and it will be subject to the applicable privacy policy of our Customers in addition to this Privacy Policy.  

By accepting this Privacy Policy in registration or by using the Services and/or using the CampBrain website (the “Site”), you expressly consent to our collection, use, transfer and disclosure of your Personal Information in accordance with this Privacy Policy.

Scope

This policy applies to Personal Information about Registrants that is collected, used or disclosed to CampBrain, including in connection with the Services. This Privacy Policy does not apply to an employee’s name, title, business address, telephone number and email address, which CampBrain collects, uses or discloses solely for the purpose of communicating with individuals in relation to their employment, business or profession.

Definitions

CampBrain has set out some basic definitions to use when reading and interpreting this Privacy Policy.

Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.

Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of CampBrain. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.

Disclosure: making Personal Information available to a third party for that party’s own use and includes the provision and/or making available Camp Data to our Customers.

Non-Personally Identifiable Information: means information that is aggregated or depersonalized and therefore cannot be associated or connected with a specific Registrant. 

Personal Information: means information about an identifiable individual that is recorded in any form, but does not include information which is publicly listed in a written or online directory or typically made available through directory assistance.

Services: means the CampBrain online camp registration services.

Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of CampBrain or our Customers.

Registrant: means the individual user of our Services.

Use: the treatment, handling and management of Personal Information by and within CampBrain.

Collection of Personal Information

As indicated above, we collect Personal Information that You directly provide as we provide the Services. We may also collect Personal Information if You contact us, through e-mail, telephone conversations or the completion of forms, for support and other inquiries.

Accountability

CampBrain is responsible for Personal Information under its control and has designated its Privacy Officer as accountable for the company’s compliance with the following principles.

1. CampBrain is responsible for Personal Information in its possession or custody, including information that has been transferred by CampBrain to a third party for processing or storage. CampBrain shall use contractual or other means to provide a comparable level of protection while the information is being processed by such a third party.

2. CampBrain shall implement policies and practices to give effect to:

(a) Implementing procedures to protect Personal Information;

(b) Establishing procedures to receive and respond to complaints and inquiries;

(c) Training staff and communicating to staff information about the organization’s policies and practices; and

(d) Developing information to explain the organization’s policies and procedures.

Purposes and Collection

Where appropriate, CampBrain will identify the purposes for which Personal Information is collected at or before the time the information is collected.

1. CampBrain collects Personal Information only for the following purposes:

(a) To provide the Services to You, including to enroll You at Your selected camp(s) or organization(s) and make online donations. In providing the Services, Camp Data will be disclosed to our Customers that You have chosen to create an account at;

(b) To establish and maintain responsible commercial relations with Registrants (which will include, but not be limited to: billing, communication and account verification);

(c) To meet legal and regulatory requirements; and

(d) To administer and manage its business operations.

2. Persons collecting Personal Information directly, other than through the Services, will be able to explain to individuals the purposes for which the information is being collected, or will, upon request, refer the individual to a designated person at CampBrain who will explain the purposes.

3. Unless required by law, CampBrain shall not use or disclose Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining the consent from You, where such consent may not reasonably be implied.

Non-Personally Identifiable Information

In any ongoing effort to better understand and serve our Customers and improve our Services and user functionality, we conduct research on our Registrants and user demographics and analytics with respect to the CampBrain website and products, and behavior and trends based on Personal Information and other information that we have collected.  This research may be used by CampBrain to analyze and improve our Site, Services and products.  This research will be compiled and analyzed on an aggregate basis and this aggregate does not identify any individual and therefore is considered Non-Personal Information under this Privacy Policy.

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.

Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below:

1. In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual’s life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available.

2. In obtaining consent, CampBrain will use reasonable efforts to ensure that You are advised of the identified purposes for which Personal Information collected will be used or disclosed.

3. The form of consent sought by CampBrain, in respect of information sought may vary depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, CampBrain shall take into account the sensitivity of the Personal Information and the reasonable expectations of its customers and employees.

4. Pursuant to applicable privacy laws, You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.  With respect to Camp Data, You should contact the applicable camp(s) directly.

Use and Retention of Personal Information

As noted above, CampBrain collects and discloses Camp Data on behalf of our Customers and it will be governed by our applicable Customer’s privacy policy.  We may also use your Personal Information, including Camp Data, to provide Services to You and other services as You or our Customers may request and authorize from time to time.  We may also collect certain Personal Information that is not considered Camp Data, such as support inquiries, that will be used solely for the purposes of carrying on our internal business affairs and providing services to You. Such Personal Information will be retained only as long as necessary for the fulfillment of those purposes.

1. Generally, all Camp Data collected by CampBrain is to provide You and our Customers with the Services (i.e., enroll You or Your children at the selected camp(s) and organization(s)) and will be disclosed to our applicable Customer(s) as well as for such reasonably ancillary use in connection with the operation of their businesses

2. CampBrain may also transfer Your Personal Information, including Camp Data, to third party suppliers, contractors and agents (“Service Providers”) who are contracted by CampBrain to assist us in providing the Services.  For example, we may transfer Your Personal Information to:

 (a) a credit card payment processing company to process your payments; and

 (b) a data storage company to host our data, including Your Personal Information.

3.  Your Personal Information may be used or stored by us or our Service Providers outside of Canada, in the United States. CampBrain takes reasonable contractual or other measures to protect Your Personal Information while processed or handled by these Service Providers outside of Canada. If Your Personal Information is located outside of Canada it will be subject to legal requirements in those foreign countries applicable to CampBrain’s Service Providers. For example, information that is processed, used, stored or accessed in the United States may be subject to the Patriot Act and applicable anti-terrorism legislation, together with other legislation applicable within the United States.  You may withdraw your consent with respect to such transfers outside of Canada, however as a result CampBrain may be unable to or restricted in providing you with the Services.

4. CampBrain may also disclose your Personal Information to any other third party, upon receiving Your consent or as required by law.

5. Only CampBrain’s employees whose duties reasonably so require are granted access to Your Personal Information.

6. Except as provided for in this Privacy Policy, we will not transfer or disclose Your 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 or our Customers, including for credit checking and collection purposes, as applicable, (iii) in connection with a potential financing, merger or acquisition in which case the applicable counterparties shall be placed under obligations of confidentiality; or (iv) You provide consent to such disclosure.

Accuracy

CampBrain will make reasonable efforts to ensure that Personal Information is accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.  Upon request, we will update Personal Information about Registrants as and when necessary to fulfill the identified purposes or upon notification by You. With respect to Camp Data, CampBrain will forward the request to our applicable Customer(s).

Security

Personal Information will be protected by security safeguards appropriate to the sensitivity of the information.

1. Any Personal Information in our possession is stored electronically, either on our server (which may be hosted offsite) or on other electronic storage media that may be retained as part of Your files or otherwise.

2. We have security measures in place to protect against the loss, misuse, access to or alteration of Your Personal Information and data under our control.

3. 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.

4. CampBrain will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

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

6. 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 Personal Information.

Openness and Access

CampBrain will make readily available to You information about its policies and practices relating to the management of Personal Information. CampBrain will make this Privacy Policy available to You prior to providing the Services. On request a copy of this Privacy Policy will be provided by mail.

You may access or inquire about Your Personal Information in our possession at any time during our business hours.  With respect to Camp Data, we forward the request to our applicable Customer(s). 

For other Personal Information, CampBrain will provide you with information about the Personal Information we hold, how it was obtained and how it is or has been used and to whom it has been disclosed.  Such Personal Information will be provided to You within a reasonable time, and at a minimal or no cost.  We will correct or amend Personal Information in cases where accuracy and completeness is deficient

NOTE: In certain situations, CampBrain may not be able to provide access to all of the Personal Information it holds about You. 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.

Challenging Compliance

In the event of any dispute, complaint or problem with respect to this Privacy 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 Privacy Policy by CampBrain.

Children’s Privacy Protection

Children under 13 years of age are not permitted to use our Services. We do not knowingly collect any information from children under 13 years of age. If You are under 13 years of age, You are not permitted to submit Personal Information to us.

Using the Site & Cookies

In order to improve the Site, we may use small files commonly known as “cookies”. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the Site and is stored on your device’s browser or hard drive.  Cookies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may generate reports based on the use of these technologies an aggregated basis

The cookies we use on the Site won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.  We use cookies to remember users’ settings, store login addresses, authenticate users and parent accounts, run website experiments, compile statistical reports on activity, analyze code-level information about usage and performance, and store analytics data, such as browser, device type and operating system.

Registrants can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

Cookies from Third Parties

We use Google Analytics, a web analytics service provided by Google Inc. ("Google") on the Site. Google Analytics uses "cookies", which are text files placed on your computer, to help analyse how users use the Site. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Site.  By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

We may use additional third party and such parties will have their own privacy policies describing how they use information that they collect. 

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/olrprivacy. 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.

Contact Us

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