Privacy Policy

This Privacy Policy is entered into between you ("Client") and Brains by Bay LLC ("Company"), a limited liability company providing life coaching services both virtually and in person within the state of Rhode Island. The Company is firmly committed to safeguarding the privacy of our clients' information. The following outlines our practices regarding the collection, use, and protection of your personal information.

1. Information Collection: The Company may collect personal information that identifies you in connection with the provision of our life coaching services. Personal information includes, but is not limited to, your name, address, email address, phone number, and any other information that can be used to identify you as an individual. This information is collected for the purposes of providing our life coaching services, communicating with you, and improving our services. Additionally, we may collect non-personal information related to your use of our services. The provision of personal information is voluntary, but necessary for the Company to provide our life coaching services. If you choose not to provide certain personal information, we may be unable to provide you with certain services.

(a) Use of Information: The personal information collected by the Company is used solely for the purpose of providing life coaching services, processing payments, and improving the quality of our services. We may also use your information to communicate with you about your account, our services, and any changes to our policies or terms.

(b) Information Sharing and Disclosure: The Company will not sell, rent, or share your personal information with third parties, except as required by law or as necessary to provide the services requested by you. This includes sharing information with third-party service providers to facilitate our services, such as payment processing. Any third-party service providers used by the Company are strictly required to maintain the confidentiality of your information and are prohibited from using it for any other purpose.

(c) Data Security: We implement appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal information. This includes, but is not limited to, encryption, physical security measures, and management of data access.

(d) Your Rights: You have the right to access, update, or delete your personal information in our possession by contacting us directly. We will respond to your request in a timely manner. You may request the deletion of your personal data at the end of our service relationship.

2. Cookies and Analytics: The Company employs the use of cookies and similar tracking technologies to monitor and analyze the use of our website. These technologies help us understand how our clients interact with our website, which enables us to improve and personalize the experience.

(a) Cookies: A cookie is a small data file that is placed on your device when you visit our website. It allows our website to remember your actions and preferences over a period of time, making your subsequent visits more personalized and efficient. You have the option to control or refuse cookies through your browser settings, but please note that disabling cookies may limit your ability to use certain features of our services.

(b) Analytics: We use third-party analytics services to collect and analyze information about the use of our services. This information helps us to improve the functionality and user experience of our services. The analytics services may use cookies and similar technologies to collect information such as how often users visit our website, what pages they visit, and what other sites they used prior to visiting ours.

(c) Use of Cookies: The information collected through cookies and analytics is used solely for the purposes of analyzing use of our services, managing the content on our site, and improving our services. We do not share or sell this information to third parties for their advertising or marketing purposes.

(d) Your Choices: You have the right to decide whether to accept or reject cookies. Most web browsers are set to accept cookies by default, but you can usually modify your browser settings to reject cookies if you prefer. Additionally, you can opt out of certain third-party analytics services to prevent your data from being used by those services.

3. Changes to This Privacy Policy: The Company reserves the right to update this Privacy Policy at any time. Any changes will be posted on our website and, where appropriate, notified to you by email. We encourage you to periodically review this policy for the latest information on our privacy practices.

4. Contact Information: If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at brainsbybay@gmail.com.
By accessing and using the Company's services, you acknowledge and agree to the terms outlined in this Privacy Policy.

PRIVACY POLICY ADDENDUM: GDPR COMPLIANCE

This GDPR Compliance Addendum forms part of the Privacy Policy between you ("Client") and Brains by Bay LLC ("Company") and applies to individuals located in the European Economic Area (EEA), United Kingdom (UK), and Switzerland. The Company recognizes the importance of and is committed to complying with the EU General Data Protection Regulation (GDPR) and any applicable national implementing laws, regulations, and secondary legislation relating to privacy and data protection.

5. Lawful Basis for Processing Personal Data: The Company will only process your personal data where we have a lawful basis for doing so. The lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), and "legitimate interests". Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time.

6. Data Subject Rights: Under GDPR, you have several rights in relation to your personal data. These include the right to access, rectify, erase, restrict processing of, object to processing, and the right to data portability. If you wish to exercise any of these rights, please contact us using the contact information provided in our Privacy Policy.

7. Data Transfers: Personal information we collect from you may be processed outside the EEA, UK, and Switzerland, including in countries that may not provide the same level of data protection as your home country. We ensure that all data transfers comply with GDPR by implementing appropriate safeguards such as standard contractual clauses approved by the European Commission.

8. Data Protection Officer (DPO): The Company has appointed a Data Protection Officer to oversee compliance with GDPR. If you have any questions about this addendum, the processing of your personal data, or your data protection rights, please contact our DPO at the provided contact information on our website.

9. Data Breach Notification: In the unlikely event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the appropriate regulatory authorities within 72 hours of becoming aware of the breach, in accordance with GDPR requirements.

10. Privacy by Design: The Company incorporates privacy by design principles into the development and implementation of our life coaching services. This means that we consider privacy implications for any new or substantially changed service or business practice that involves the processing of personal data.

11. Consent for Children: In relation to our services, we do not knowingly collect or process the personal data of individuals under the age of 16 without the consent of the child's parent or guardian. If we become aware that personal data from a child under 16 has been collected without such consent, we will take steps to delete the information as soon as possible.

This GDPR Compliance Addendum is integral to our Privacy Policy. By accessing and using the Company's services, Clients located in the EEA, UK, and Switzerland acknowledge and agree to the terms outlined in this Addendum.

For any changes to our GDPR Compliance practices, Clients will be notified through our website or via email, ensuring Clients are always aware of what information we collect, how it's used, and under what circumstances, if any, it is disclosed.

PRIVACY POLICY ADDENDUM: CALIFORNIA CONSUMER PRIVACY ACT (CCPA) COMPLIANCE

This CCPA Compliance Addendum forms part of the Privacy Policy between you ("Client") and Brains by Bay LLC ("Company") and applies to individuals residing in the State of California. The Company acknowledges the importance of and is committed to complying with the California Consumer Privacy Act (CCPA) and any applicable state implementing laws, regulations, and secondary legislation relating to privacy and data protection within the state of California.

12. Rights Under CCPA: In line with the CCPA, California residents have specific rights regarding their personal information. These rights include the right to request disclosure of the categories and specific pieces of personal information collected, the right to request the deletion of personal information, the right to opt-out of the sale of personal information, and the right to non-discrimination for exercising their CCPA rights.

13. Request for Information: Clients may submit a request for information regarding the categories of personal information collected, the purposes for which the collected personal information is used, and whether their personal information is sold or disclosed and to whom. Requests can be made by contacting us using the contact information provided as part of the client onboarding experience.

14. Deletion Requests: Clients have the right to request the deletion of any personal information that the Company has collected from them. Upon receiving a verified request, we will delete the client's personal information from our records and direct any service providers to do the same, unless exceptions apply under the CCPA.

15. Sale of Personal Information: The Company does not sell personal information.

16. Non-Discrimination: The Company will not discriminate against any client for exercising their rights under the CCPA. This includes, but is not limited to, denying goods or services, charging different prices or rates for goods or services, providing a different level or quality of goods or services, or suggesting that the client will receive a different price or rate for goods or services or a different level or quality of goods or services.

17. Contact for More Information: If you have any questions about this addendum or need to make a request regarding your personal information under the CCPA, please contact information provided as part of the client onboarding experience.

18. Data Protection Officer (DPO): The Company has appointed a Data Protection Officer to oversee compliance with CCPA. If you have any questions about the processing of your personal information, please contact our DPO at the provided contact information on our website.

This CCPA Compliance Addendum is integral to our Privacy Policy. By accessing and using the Company's services, Clients residing in California acknowledge and agree to the terms outlined in this Addendum.

For any changes to our CCPA Compliance practices, Clients will be notified through our website or via email, ensuring Clients are always aware of what information we collect, how it's used, and under what circumstances, if any, it is disclosed.