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This privacy policy is for users of the website only. Your privacy is important to us. Spa Inc (referred to herein as “BrainSpa” “we,” “us,” “our”) appreciates your interest in our website, (the “Site”). Our Site is designed to provide access to online information about BrainSpa and our platform for brain health and fitness. In connection with providing this information and service, there are times when we may ask for or collect information from you, either in the form of anonymous data or personally identifiable information. As part of our commitment to honoring your privacy, this Privacy Policy explains the approach we take in protecting and using the information that we gather from you on our Site. By using the Site, you consent to this Privacy Policy.

Types of Information We Collect

Cookies: When you visit the Site, we ask your browser to store small text files containing a string of alphanumeric characters known as a cookie. We use both session cookies and persistent cookies. If you have chosen to identify yourself on a Site, we use session cookies containing encrypted information to identify you and facilitate your use of the Site. Session cookies are required to access much of the content and services offered on the Site. After you leave our Site and close your browser, a persistent cookie remains. Persistent cookies can be removed by following your help file directions in your web browser. If you refuse our cookies, some features of the Site may not function properly.

User Provided Information: When you choose to submit personally identifiable information to our Site (including name, telephone number, mailing address and email address), your information is used only for the specific purpose for which it was submitted, unless you consent otherwise or as required by law. In many cases, you choose the amount of information you supply. There may be instances where some of the information that we ask you to provide is identified as mandatory and some as voluntary. In such cases, if you do not provide mandatory personal information with respect to a particular activity, you will not be able to engage in that activity. We may collect personally identifiable information when you:

  • Inquire about our products and services;

  • Ask that we contact you;

  • Subscribe to our mailing list

  • Complete voluntary customer service surveys.

We maintain the data that you provide us in a secure database. To best serve you, we may combine this information with data that is publicly available and data that we receive from other reputable sources.

Log Files: Our servers automatically record certain information (e.g., web request, Internet Protocol (“IP”) address, browser type, browser language, URLs, etc) that your web browser sends whenever you visit our Site.

Web Beacons: We may employ clear GIFs or web beacons to track anonymously how users use the Site. We may also use web beacons in our emails to track which emails are opened.

Analytics: When someone visits the Site, our web servers automatically gather information that allows the Site to communicate with the user’s computer during the visit. We also may use any of the following information: the number of visits to the Site, which parts of the Site users select, IP address (the Internet address assigned to your computer from your Internet Service Provider), domain type, browser type (e.g., Internet Explorer) and date and time of day. We use this information for statistical purposes that help us design and administer the Site. Those types of information do not disclose personally identifiable information that would permit us to identify or locate individual visitors.

Use of Information: We will use your information as described in this Privacy Policy. In all circumstances, we will delete your information when that information is no longer required for any of the purposes for which it was collected.

Mandatory Communications: Even if you have opted out of email communications, we reserve the right to communicate with you from time to time about important administrative, policy, legal, and financial matters that affect your use of the Site. These communications are mandatory.

Research: We may conduct demographic or other research about our users to determine how users engage with our Site.

Communications from BrainSpa: As a Site user, you will be asked if you want to receive marketing materials from BrainSpa and its Business Partners (defined below). If you opt-in we will send you marketing materials. From time to time, we may also send you offers for similar products and services from BrainSpa, special premiums, or special offers from our Business Partners. We do not share your personally identifiable information with any third parties in connection with these communications. You can always decline these communications by simply following the “unsubscribe” link at the bottom of each communication.

Business Partners: We may provide information about how our users collectively use our Site to our customers, advertisers, sponsors, and other companies with which we do business (“Business Partners”). This data does not include any personally identifiable information about you.

Third-Party Information Sharing: Generally, we do not share your information with third parties. We reserve the right to share your information with third-party companies we may use to perform other service functions for us. However, at all times, we will control and be responsible for the use of your information and will ensure that sufficient contractual mechanisms are in place to ensure that the information remains secure. We do not share equipment or databases with these companies. Additionally, any company we use for these reasons will not share, sell, or distribute your information, or otherwise use your information except to provide us services.

Sale of BrainSpa or its Assets: In the event that BrainSpa or our assets or stock are ever sold, acquired, merged, liquidated, reorganized, or otherwise transferred, we reserve the right to transfer our user databases together with any personally identifiable information contained in them, to a third-party acquiring our assets. In the event we do so, we will place a prominent notice of the sale on the homepage of our Site, with links to information about how you can change your privacy preferences.

Disclosure Exceptions:

  • We reserve the right to disclose your personal information to appropriate third parties if we are required to do so by law or we reasonably believe that such action is necessary:

  • To comply with legal process such as a search warrant, subpoena or court order;

  • To protect BrainSpas’ rights and property;

  • To investigate reports of users sending material using a false e-mail address or users sending harassing, threatening, or abusive messages;

  • To protect against misuse or unauthorized use of our Site, products, or services; or

  • During emergencies, such as when we believe someone’s physical safety is at risk.

Security Measures: We will take reasonable measures which we believe are appropriate to protect your information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer your information take comparable steps to protect that security. Although we will use all reasonable efforts to safeguard the confidentiality of any visitor information collected, we shall have no liability for disclosure of any visitor information obtained due to errors in transmission or the unauthorized acts of third parties. Email is not a secure form of communication. Please do not send us your social security number or other personal information via email.

Unfortunately, the transmission of information via the Internet or over mobile networks is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and from the Site or over mobile networks; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access. We ask that any third parties to whom we may transfer your personal information take comparable steps to protect that security.

Other Websites: This Privacy Policy only applies to the Site. Please be aware that our Site and email communications may contain links to other websites or webpages that are owned and operated by our customers or other third parties. The information practices of websites linked to our Site are not covered by this Privacy Policy and, therefore, we are not responsible for the content or privacy policies of websites to which our Site links. We encourage you to review the privacy policies of the third-party websites to understand their privacy practices.

Opt Out: If you would like to request that your name be removed from our marketing list, please contact us at

Please include your full name and telephone number in case we have any questions. You can also opt-out of receiving email communications from BrainSpa by clicking on the “unsubscribe” link in our emails. We will make a reasonable effort to accommodate your request.

Changes and Updates to this Privacy Policy: If you choose to visit our Site, your visit and any disputes over privacy are subject to this Privacy Policy. We reserve the right to change this Privacy Policy at any time without notice except as otherwise provided here. Please check back periodically to see if our Privacy Policy has been updated. If we make material changes to this Privacy Policy, we will notify you by updating this Privacy Policy, posting notice of the change on our home page and/or send you email notice. Your continued use of the Site constitutes your agreement to the terms of this Privacy Policy and any future versions of this Privacy Policy.

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