Brain Gain
Network Privacy Policy Highlights
This page summarizes
the key highlights from our privacy policy. For more information, read
our full privacy policy.
1. Personal
information collected.
We collect information:
2. Uses of
personal information.
We use the information you provide to:
3. Your information
choices.
You can:
4. Important
information.
5. Security
6. How to contact
us
If you have any
questions or comments, please e-mail us at [e-mail] or contact us at:
Brain Gain Network Ventures
ATTN: Privacy Policy Issues
Unit 105 Plaza B
Northgate Cyberzone
Muntinlupa City 1781
Philippines
Brain Gain
Network Privacy Policy
Your privacy is
our top concern. We work hard to earn and keep your trust, so we adhere
to the following principles to protect your privacy:
We reserve the
right to modify this privacy statement at any time, so please review
it frequently. If we make material changes to this policy, we will notify
you here, by e-mail, or by means of a notice on our home page. By continuing
to use the Brain Gain Network service after notice of changes have been
sent to you or published on the Brain Gain Network website, you are
consenting to the changes.
Please read this
privacy policy to learn more about:
Personal information
collected.
The purpose of
the Brain Gain Network website is to permit Users to voluntarily provide
information about themselves for the purposes of developing, maintaining
and enhancing a network of professional contacts. You willingly provide
us certain personal information, which we collect in order to allow
you to benefit from the Brain Gain Network website. If you have any
hesitation about providing such information to us and/or having such
information displayed on the Brain Gain Network website or otherwise
used in any manner permitted in this Privacy Policy and the User Agreement,
you should not become a member of the Brain Gain Network community.
We collect your
personal information in the following ways:
Registration
In order to become
a User, you must first create an account in our website. To create an
account you are required to provide the following contact information,
which you recognize and expressly acknowledge is personal information
allowing others, including Brain Gain Network, to identify you – name,
e-mail, country, ZIP/postal code, a brief summary of your professional
background and a password chosen by you.
Profile
Information
Once you become
a User, you may provide additional information in the Profile section
describing your skills, professional experiences and networking objectives.
Providing additional information beyond what is required at registration
to become a User is entirely optional, but enables you to better identify
yourself and find new opportunities in the Brain Gain Network system
to build and leverage your professional network. Any information your
provide at registration or in the Profile section that is not personally
identifiable may be used in the same manner and extent to which other
information that is not personally identifiable is permitted to be used
hereunder, including for the purpose of serving advertisements through
the service. If you opt out, you may lose the potential benefit of being
a User, including receiving ads that are more targeted to your interests.
Contacts
Information
In order to invite
others to connect with you directly in Brain Gain Network, you may use
the Brain Gain Network services to invite them if they are a User, or
enter their names and e-mails. This information will be used by Brain
Gain Network to send your invitation including a message that you write.
The names and e-mails of people that you invite will be used only to
send your invitation and reminders.
You may also choose
to manually enter or upload data about your contacts into the private
“My Contacts” section of the Brain Gain Network website. You may
not invite anyone to connect with you whom you do not know. All information
entered there will only be viewable by you and will not be searchable
by others in the Brain Gain Network without your permission. All information
that you enter or upload about your contacts will be covered by the
same terms of this privacy policy as cover for your own information.
Customer
Service
Brain Gain Network
may collect information through the Brain Gain Network website or through
the Customer Service website in order to – among other things –
accurately categorize and respond to a customer’s inquiry and deliver
appropriate service levels.
Cookies
Like most websites,
Brain Gain Network uses cookies and web log files to track site usage.
A cookie is a tiny data file which resides in your computer allowing
Brain Gain Network to recognize you as a User when you return to the
Brain Gain Network website using the same computer and web browser.
If your browser settings do not allow cookies, you will not be able
to use the Brain Gain Network website. Like the information entered
during registration on in your Profile, cookie and log file data is
used to customize your experience in our website.
One type of cookie,
known as a “persistent” cookie, is set once you’ve logged in to
your Brain Gain Network account. The next time you visit the Brain Gain
Network website, the persistent cookie will allow us to recognize you
as an existing User so you will not need to log in before using the
service. In order to access or change any of your private information
(like a credit card number) or to send a message to another User, you
must log in securely again with your password even if your computer
contains your persistent cookie.
Additionally,
if you log out of the Brain Gain Network website you will need to reenter
your password the next time you visit in order to access your account.
Another type of cookie, call a “session” cookie, is used to identify
a particular visit to the Brain Gain Network website. Session cookies
expire after a short time or when you close your web browser.
We use cookies
to improve the quality of our service by storing User preferences and
tracking User trends. In the course of serving advertisements or optimizing
services to our Users, we may allow authorized third parties to place
or recognize a unique cookie on your browser. Any information provided
to third parties through such cookies will not be personally be identifiable
but may provide general segment information, e.g. your industry or geographic
location, your occupation or information about your professional or
educational background, for greater customization of your user experience.
Most browsers are initially set up to accept cookies, but you can reset
your browser to refuse all cookies or to indicate when a cookie is being
sent. Unfortunately, if your browser settings do not allow cookies or
you opt to refuse all cookies, you may not be able to use the Brain
Gain Network website or services. Brain Gain Network does not store
personally identifiable information in the cookies.
Web Beacons
We allow other
companies, called ad networks, to serve advertisements to Users. Ad
networks include third party ad servers, ad agencies, ad technology
vendors and research firms. Brain Gain Network may “target” some
ads to Users that fit a certain general profile – for example, “product
managers in Manila.” Brain Gain Network does NOT use personally identifiable
information to target ads.
To deliver these
ads properly, Brain Gain Network may include a file, called a web beacon,
from these ad networks within pages served by Brain Gain Network so
the networks may provide anonymous, aggregated auditing, research and
reporting for advertisers as well as to target ads to you while you
visit other websites.
Because your web
browser must request these advertisements and web beacons from the ad
network’s servers, these companies can view, edit or set their own
cookies just as if you had requested a web page from their site.
These general
targets may also be used by ad networks to display targeted ads on other
websites as a substitute for random, irrelevant ads. Brain Gain Network
does not provide personally identifiable information to any advertiser
or any other third party.
You may opt out
the use of web beacons in Brain Gain Network pages that you view and
of placement of a cookie by ad networks in your browser. To opt out,
click [note: provide opt out link or function] and go to the “Advertising”
section at the bottom and change the setting there to “No”. If you
opt out you may lose the potential benefit of receiving ads that are
more targeted to your interests which, in turn, may limit your ability
to fully realize the benefits of the Brain Gain Network services to
build and leverage your professional network.
Log files,
IP addresses and information about your computer.
Due to the communications standards on the Internet, when you visit the Brain Gain Network web site we automatically receive the URL of the site from which you came and the site to which you are going when you leave Brain Gain Network. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, e-mail patterns, as well as the name of your ISP. This information is used to analyze overall trends to help us improve the Brain Gain Network service. The information is used to analyze overall trends to help us improve the Brain Gain Network service. The linkage between your IP address and your personally identifiable information is not shared with third parties without your permission or except when required by law.
Consent
to Brain Gain Network Processing Personal Information
Certain information
you provide to Brain Gain Network may reveal, or allow others to identify
your nationality, ethnic origin, religion or other aspects of your private
life and more generally about you. Please be aware that in providing
information to Brain Gain Network for the purposes of opening your user
account, you are expressly and voluntarily accepting the terms and conditions
of this Privacy Policy and Brain Gain Network’s User Agreement. The
supplying of all such information by you to Brain Gain Network, including
all information deemed “sensitive” by applicable law, is entirely
voluntary on your part. You have the right to withdraw your consent
at any time, in accordance with the terms of this Privacy Policy and
the User Agreement but please note that your withdrawal of consent will
not be retroactive.
Rights to
Access, Correct and Eliminate Personal Information
You have a right
to access, modify, correct and eliminate the data about you which has
been collected pursuant to your decision to become a User. If you update
any of your information, we may keep a copy of the information which
you originally provided to us in our archives for uses documented herein.
We take your rights
seriously and encourage you to use them if you deem this to be appropriate.
You may exercise these rights by e-mailing us administrator@bgn.org or by
contacting us at:
Brain Gain Network Ventures
ATTN: Privacy Policy Issues
Unit 105 Plaza B
Northgate Cyberzone
Muntinlupa City 1781
Philippines
2. Uses of
personal information
Brain Gain Network
is an online service dedicated to helping all types of professionals
more effectively connect with one another. The personally identifiable
information you choose to provide on our website is used to help you
describe yourself to other Users. Other information, that does not personally
identify you as an individual, is collected by Brain Gain Network from
Users (such as, for example, patterns of utilization) and is exclusively
owned by Brain Gain Network. This information can be utilized by Brain
Gain Network in such manner as Brain Gain Network, in its sole discretion,
deems appropriate.
Brain Gain
Network Communications
Brain Gain Network
will communicate with you through e-mail and notices posted on the Brain
Gain Network website or through other means available through the service,
including text and other forms of messaging. If we send any communication
via the carrier service of which you have a mobile communication subscription
or otherwise have access, you understand you will pay any service fees
associated with any such access (including text messaging charges for
messages to your mobile device). These include a series of up to five
(5) welcome e-mails which help inform new Users about various features
of the service. Please be aware that you will always receive certain
e-mails from Brain Gain Network related to the proper functioning of
your account, such as e-mail notices when another User in your network
sends you an opportunity. Brain Gain Network may send you promotional
information unless you have opted out of receiving such information.
You can change your e-mail and contact preferences at any time by logging
in to your “Accounts & Settings” and amending your e-mail notification
choices. If you wish, you can also opt out of receiving promotional
e-mails, by sending a request to [provide e-mail address].
Customized
Content
Information provided
to Brain Gain Network (or to third parties with whom it offers combined
services) is also used to customize your experience on our website.
For example, when you log in to your account we will display the screen
names of new Users who have recently joined your network.
Sharing
Information with Third Parties
Brain Gain Network
takes the privacy of Users very seriously. We do not sell, rent or otherwise
provide your personal identifiable information to third parties for
marketing purposes. We will only share your information with third parties
to carry out your instructions or to provide specific services or information.
For instance, we use a credit card processing company to bill Users
for subscription fees. These third parties do not retain, share or store
any personal identifiable information except to provide these services
and they are bound by confidentiality agreements which limit their use
of such information.
Brain Gain Network
offers a “public profile” feature which allows Users to publish
portions of their Brain Gain Network profile, including their “name”,
but not their “e-mail address” to the public Internet. Users may
opt out of this feature by editing their account and settings, however
Brain Gain Network does not warrant how often third party search engines
will update their cache.
We may provide
aggregated anonymous data about the usage of our services to third parties
for such purposes as we deem, in our sole discretion, to be appropriate,
including to prospective advertisers on Brain Gain Network. We may segment
our Users by role (i.e. product managers, vice presidents), industry,
geographic location or company. If you would like to be excluded from
the aggregated research or products based upon aggregated data about
our Users’ activities on the site, please e-mail administrator@bgn.org.
Teaming
with Other Organizations to Offer Combined and Other Services
Brain Gain Network
may offer our services in connection with other websites (including
updates about the Brain Gain Network service) or may team with other
online services to give you the combined results of both services or
additional services and benefits. Platform Applications (as defined
in the User Agreement) can be designed by Platform Developers (as defined
in the User Agreement) or by a subset of Platform Developers with whom
Brain Gain Network has more closely aligned (“Partners”).
In the case of
Partners, we do some vetting and we only work with trusted Partners.
For example, [indicate BGN partner] is a Partner which lets you use
its services to [define BGN partner’s service/s] combined with the
use of Brain Gain Network to [indicate service offered]. Because of
Brain Gain Network’s trust in these Partners, Platform Applications
or services designed by a Partner may be automatically granted permission
to access account information to provide the combined services.
For Platform Applications
designed by most Platform Developers, you will be asked to confirm acceptance
of the Platform Developers’ respective privacy policies and user agreements,
which have not necessarily been reviewed or approved by Brain Gain Network.
In these cases, it will be your choice whether or not to make use of
the services and whether to proceed under the Platform Developers’
terms.
Platform Developers
are required to agree to restrictions on access, storage and usage of
your information. However, while we typically enter into contractual
agreements and take technical steps to restrict possible misuse of such
information by such Platform Developers, we may not screen or approve
Platform Developers, and we cannot and do not guarantee that all Platform
Developers will abide by such restrictions and agreements. Certain actions
you take through the Platform Applications will be displayed to your
connections. You understand that your use of any Platform Applications
is on an “as is” basis without any warranty as to the Platform Developers’
actions.
If you, your connections,
members of your network, or others Users of Brain Gain Network use any
Platform Application, or if you interact with a Platform Application
being used by any of them, such Platform Application may access and
share certain information about you with others. Because a Platform
Application can make calls on behalf of the User interacting with it
to access non-public information, the level of detail accessible by
the Platform Application is constrained by the same settings that govern
visibility of your data to that User in Brain Gain Network.
For example, assuming
you have not already given a Platform Application permission to access
your information, your non-public profile information should not be
visible to someone using a Platform Application if it is not otherwise
accessible to that person in Brain Gain Network.
To uninstall a
Platform Application at any time, please click [provide link or function]
or, if the relevant Platform Application is not listed there, go directly
to the Application Details page for the Platform Application you wish
to uninstall. Note however that even if you uninstall a Platform Application,
your connections, other members of your network or other Users of Brain
Gain Network may still be using the Platform Application, and so it
may still have access to certain information about you, just as those
Users do. To report any suspected misuse of information, contact [provide
e-mail]. Brain Gain Network is not responsible for your use of or inability
to use any Platform Applications, including the content, accuracy or
reliability of such applications and the privacy practices or other
policies of Platform Developers.
Surveys
and Polls
As a User, you
will receive requests to participate in market research including polls
and surveys submitted by other Brain Gain Network members. If you participate
in surveys and polls offered through our website, the information you
provide may be visible to others using the Brain Gain Network website.
You may opt not to participate by changing your Account & Settings
to stop receiving these inquiries and requests.
Forums/
Chats/ Blogs
If you post on
the Answers section of Brain Gain Network website, or use a bulletin
board, import a blog, or participate in a chat room on Brain Gain Network,
you should be aware that any personally identifiable information you
choose to provide there can be read, collected, or used by other Users
of these forums, as well as Platform Developers and other third parties,
and could be used to send you unsolicited messages. Brain Gain Network
is not responsible for the personally identifiable information you choose
to submit in these forums.
Testimonials
and Advertisements Placed through Brain Gain Network DirectAds Service
If you provide
any testimonials about the Brain Gain Network service or place advertisements
through the Brain Gain Network DirectAds services, we may post those
testimonials and examples of advertisements you place in connection
with Brain Gain Network’s promotion of its service to third parties,
whose testimonials and advertisements may include your name and other
personal information provided. Fore more information about DirectAds
please see the DirectAds Terms of Use.
Communications
to other Users
Many e-mails you
initiate through the Brain Gain Network, e.g. an invitation sent to
a non-User, will list your e-mail and name in the header of the message.
Emails you initiate may also provide aggregate information about your
network (for instance how many people are in your network), but will
not list the people who are you are directly connected with. Other communications
you initiate through the Brain Gain Network website, like a request
to be a contact, will list your name as the initiator but will not include
your personal contact information. Your contact information will only
be shared with another User if both of you have indicated that you would
like to establish contact with one another.
Legal Disclaimer
It is possible
that we may need to disclose personal information when required by law,
such as responses to civil or criminal subpoenas or other requests by
law enforcement personnel. We will disclose such information wherein
we have good faith or believe that it is necessary to comply with a
court order, ongoing judicial proceeding, subpoena or other legal process
or request to Brain Gain Network brought in any country throughout the
world or to exercise our legal rights or defend against legal claims.
Disclosures
to others
We may also disclose
your personal and other information provided to another third party
as part of a reorganization or sale of the assets of Brain Gain Network
Ventures division or company. Any third party to which we transfer or
sell Brain Gain Network’s assets will have the right to continue to
use personal and other information provided to us.
3. Your Information
Choices
Accessing
and Changing Your Account Information
You can review
the personal information you provided and make any desired changes to
the information published or to the settings of your Brain Gain Network
account including your e-mail and contact preferences at any time by
logging in to your account on the Brain Gain Network website. Please
be aware that even after your request for a change is processed, Brain
Gain Network may, for a time, retain residual information about you
in its back-up and/or archival copies of its database.
Closing
Your Account
You can also close
your account through the Brain Gain Network website. If you close your
Brain Gain Network account, we will remove your name and other personally
identifiable information for our publicly viewable database. We may
retain certain data contributed by you if we believe it may be necessary
to prevent fraud or future abuse, or for legitimate business purposes,
such as an analysis of aggregate, non-personally identifiable data,
account recovery or if required by law. To request that we close your
account and remove your information from the Brain Gain Network website,
please send your request to administrator@bgn.org. Please send your request
using an e-mail account which you have registered with Brain Gain Network
under your name. You will receive a response to requests sent to [provide
e-mail] within five business days of its receipt.
4. Your Obligations
As a User, you
have certain obligations toward the other Users with whom you will be
communicating. Certain of these obligations are imposed by applicable
law and regulations, and other users have become commonplace in user-friendly
communities of likeminded members, such as Brain Gain Network:
Any violation
of these guidelines may lead to the restriction, suspension or termination
of your account by Brain Gain Network, as we take these principles seriously
and consider these to be the basis on which our Users adhere to the
Brain Gain Network website and the services it offers.
5. Important
Information
Children
Children are not
eligible to use our service and we ask that minors (under the age of
18) do not submit any personal information to us or use the service.
[TRUSTe
and Safe Harbor Adherence]
Brain Gain Network
is a licensee of the [TRUSTe] Privacy Program. [TRUSTe] is an independent
organization whose mission is to enable individuals and organizations
to establish trusting relationships based on respect for personal identity
and information by promoting the use of fair information practices.
Because we want to demonstrate our commitment to our Users’ privacy,
we have agreed to disclose our privacy practices and have these reviewed
for compliance by [TRUSTe].
If Users have
questions or concerns regarding this statement, you should first contact
Brain Gain Network by sending an e-mail at administrator@bgn.org. If you
do not receive acknowledgment of your inquiry or it is not satisfactorily
addressed, you should then contact [TRUSTe] through the [TRUSTe Watchdog
Dispute Resolution Process] [provide website]. [TRUSTe] will serve as
a liaison with Brain Gain Network to resolve Users’ concerns. However,
please understand that the [TRUSTe] program only covers information
collected through the site www2.bgn.org and does not cover information
collected through software downloaded from the site.
We participate
in the [EU Safe Harbor Privacy Framework] as set forth by the [Republic
of the Philippines’ Department of Trade and Industry]. As part of
our participation in the safe harbor, we have agreed to [TRUSTe] dispute
resolution for disputes relating to our compliance with the Safe Harbor
Privacy Framework. If you have any complaints regarding our compliance
with the Safe Harbor you should first contact us.
By becoming a
User, you have given us your expressed and informed consent to transfer
the data provided to us to the Republic of the Philippines and to process
it in the Republic of the Philippines as well.
If contacting
us does not resolve your complaint, you may raise your complaint with
[TRUSTe] through the Internet at [website], [fax number], or mail [address].
If you are faxing
or mailing [TRUSTe] to lodge a complaint, you must include the following
information: company name, the alleged privacy violation, your contact
information and whether you would like the particulars of your complaint
shared with the company. For information about [TRUSTe] or the operation
of [TRUSTe’s] dispute resolution process, see [website] or request
this information from [TRUSTe] at any of the addresses listed above.
The [TRUSTe] dispute resolution process shall be conducted in English.
Changes
to this Privacy Policy
Brain Gain Network
may update this privacy policy at any time, with or without advance
notice. In the event there are significant changes in the way we treat
your personally identifiable information, we will display a notice on
the Brain Gain Network website or send you an e-mail, as provided for
above. Unless stated otherwise, our current Privacy Policy applies to
all information we have about you and your account.
If you use the
Brain Gain Network service after notice of changes have been sent to
you or published on our site, you hereby provide your consent to the
changed practices.
6. Security
In order to secure
your personal information, access to your data on Brain Gain Network
is password-protected and sensitive data (such as credit card information)
is protected by SSL encryption when it is exchanged between your web
browser and the Brain Gain Network website. To protect any data you
store on our servers, we also regularly audit our system of possible
vulnerabilities and attacks, and we use a tier-one secured access data
center. It is your responsibility to protect the security of your log
in information. Please note that e-mails, instant messaging and similar
means of communication with other users of Brain Gain Network are not
encrypted. We strongly request you not to communicate any confidential
information through these means.
7. How to contact us
If you have questions
or comments about this privacy policy, please e-mail us at administrator@bgn.org
or contact us at:
Brain Gain Network Ventures
ATTN: Privacy Policy Issues
Unit 105 Plaza B
Northgate Cyberzone
Muntinlupa City 1781
Philippines