Privacy and Data Policy



Welcome to this Brainsy, Inc. (“Brainsy”) powered website (“Site”). This Privacy and Data Policy governs aspects of your use of the Site and should be read in connection with the Terms. Together the Terms and the Privacy and Data Policy govern your use of the Site and are referred to as the Terms of Use. By accessing and using this Site, you agree to be bound by the Terms of Use. In the event of a conflict between the Terms and Conditions and the Privacy and Data Policy, the Terms and Conditions shall control. Some of the features offered by Brainsy, such as “Expert Calling Networks” or “ECNs” and “Knowledge Exchange and Expert Networks” or “KEENs” will be subject to separate Agreements and policies in addition to these Terms of Use.


Some of the features offered by Brainsy, such as “Expert Calling Networks” and “Expert Communities Online” and “Online Ecosystems” and "Who is Who Guides" and “Knowledge Exchange and Expert Networks,” (collectively or individually “ECNs”) will be subject to separate Agreements and policies in addition to these Terms.


General. When you visit the Site, we may collect certain personally-identifiable information you choose to disclose to us, such as your name, postal address, telephone number, and email address. We may also passively collect non-personal and aggregated information that is automatically sent to us by your web browser or device, including your Internet Service Provider and IP address, the date and time you access the Site, the pages you have accessed while visiting the Site, and the Internet address from which you accessed the Site. We may receive information from third party sources and incorporate it with your personally-identifiable information. If you register and transact on an ECN, your call may be recorded in accordance with the Brainsy agreement governing your participation in that ECN. Please read all agreements carefully.


Personal Information. Our Site may share or disclose personally-identifiable information about you to other companies or individuals when:

  • We utilize third party service providers to provide products, services or functions on our behalf (such as sending emails or processing credit cards or fulfilling contests or subscriptions), and ask these service providers to agree to maintain the confidentiality of your user-specific information and not to use your user-specific information for any reason except to carry out the purpose(s) for which we hired them.
  • You have entered a give-away, contest or sweepstakes sponsored by us or a third party, in which case the information will be used and disclosed by us and the third party to run the give-away, contest or sweepstakes and may be used by us or the third party, in our discretion, including direct marketing and as otherwise provided in the applicable rules for the give-away, contest or sweepstakes (if you don't want your name shared, you should not enter the give-away, contest or sweepstakes).
  • It is required by law.


Sharing. As described in this Privacy and Data Policy, if you register on one or more ECN Sites “powered by Brainsy,” then we may make your email address available to the Network Sponsor of that ECN. Network Sponsors are independent of Brainsy and therefore, Brainsy cannot and does not assume any responsibility or liability for the actions of any Network Sponsor or their use of your email address. You should review any individual ECN Network Sponsor’s privacy notice to understand how they will use your personal information.


Ownership. Any data or information collected and held by Brainsy shall be the property of Brainsy and may be sold or transferred by Brainsy in conjunction with the sale or transfer of the business to which the data or information relates.


Traffic Data Collected. We automatically track and collect the following information when you visit our Site: (i) your IP address; (ii) the type of computer you are using; and (iii) the type of Web browser you are using (collectively "Traffic Data"). Traffic Data is helpful -- in the aggregate -- for marketing purposes and for improving our customers overall experience of the Site.


Cookies.  Cookies are pieces of information that a website transfers to an individual's hard drive for record-keeping purposes. They allow a website to remember you and allows for the personalization of web pages. The use of cookies is an industry standard; you'll find them on most major websites. Our Site may use cookies to understand our users better and to track information for them. Use your browser to manage your cookies recognizing that if you limit the use of cookies not all of the Site functionality may be available to you.


Log Files. We use IP addresses to analyze trends, administer the Site, track users' movements, and gather broad demographic information for anonymous and aggregate use.


Data Incognito Mode. Data Incognito Mode (or “Incognito”) represents our best efforts to help participants on a Brainsy powered site maintain control of their data in a simple fashion. Data Incognito Mode is a feature that may not be available on all ECNs. Please check your user settings to see if you have access to Data Incognito controls.  


If you enable Incognito, you will not become anonymous because identity verification is an important feature on many ECNs. Furthermore, your public profile information and activity may still be visible to other users if you choose to interact on the ECN. However, in Data Incognito mode, any and all data attributes associated with your profile will not be used for analytical purposes, to serve content (including advertising) or to target you in any other way. 


In Data Incognito mode:


- Any and all data attributes associated with your profile will not be used to serve you content or advertising. 


For example, if you are reading the site’s feed in incognito mode, then content served to you may be the same as any “generic user” and may appear in reverse chronological order without any reference to your personal preferences or your past behavior.   


- All data attributes associated with your profile will be excluded in data gathering for analytics or other targeting purposes except for general user counts and other exempt data.   


For example, if you have identified yourself as a school teacher and we run a query to determine how many school teachers are on our platform, then your specific data attributes will not be included in the tally. However, we can include you in total user counts. For example, we may calculate 100,000 users on a site and of them, 80,000 are in normal mode and of the 80,000 users 488 are school teachers. If you are one of the users and you enable incognito mode, then our report would indicate 100,000 users on the site, 79,999 are in normal mode and 487 are school teachers. Attributes that are exempt from the data incognito feature include top level account data such as whether or not you have logged into your account within the past 30 days, frequency of logins, and time spent online. We provide a transparent list of all exempt data parameters.     


- You will automatically be opted out of all email messages and system notifications except for messages related to your account maintenance or as necessary to complete a transaction that you have initiated with another user on the platform. 


- From time to time, we may send you email or provide system notifications with information about what features might available to you if you were to disable incognito mode. We consider these to be transactional communications. If you provide consent to us to use any individual data element associated with your profile, then we will provide you with full transparency about the way in which that data is used.  


- While you are in Incognito mode, if any third party using our platform, including an advertiser or other user tries to interact with you using identifiable data we have associated with your account (e.g. email address or telephone number), then you will be automatically opted out of those interactions. In that sense, we are hoping our system can operate similar to a “do not call” registry for telephony networks. 


For example, we may employ features and tools that allow a user to prompt or invite other users they know to engage in a particular way and the target users may incidentally be on or off the platform. If a target user is already on our platform and has enabled incognito mode, then the target user will not receive the prompt or invitation. 


- We will also disable 3rd party services that might otherwise be used for tracking and analytics (e.g. Google Analytics).  


Modifications. From time to time, we may use information for new, unanticipated uses not previously disclosed in the Privacy and Data Policy. If our information practices change at some time in the future we will post the policy changes to our Site to notify you of these changes, update the Privacy and Data Policy and we will use for these new purposes only data collected from the time of the Privacy and Data Policy change forward.


Security. With respect to security, we have standard security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our Site. Our Site encrypts sensitive information prior to transmission over the Internet using secure socket layer (SSL) encryption technology. Although we take precautions to safeguard your personal information, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us or information we transmit to you from our online products or services, and you do so at your own risk.


Contact Us. If you feel that this Site is not following its stated information policy, you may contact us via email (, Subject “Privacy and Data Policy”).


Last updated: November 30, 2020