Privacy is a fundamental human right, and we at Ninth Brain Suite LLC are committed to respecting and safeguarding your privacy. In this document, we outline our privacy practices, ensuring you have a clear understanding of how we handle your personal information.

We do take the security and privacy of your data seriously. In an increasingly digital world, your trust is our most valuable asset, and we want to ensure you that we’re here to protect your information.

So, let’s delve into the finer details of our privacy policy and how we work to keep your data secure and confidential. Your privacy is important to us, and we want to make sure you’re well-informed about how we handle it.

Thank you for entrusting us with your data, and rest assured, we’re dedicated to keeping it safe.

About Ninth Brain Suite Privacy

Effective Date: May 14, 2024

Previous Version of Our Privacy Policy

May 2024 Changes to this Privacy Statement

We restructured our Privacy Statement and made language changes to clarify our existing privacy practices. We also added language regarding our reliance on the EU-U.S. Data Privacy Framework and the UK extension to the EU-U.S. DPF as a legal basis for transfers of personal information.

What our Privacy Policy is about

Before we delve further into our privacy program and procedures, let’s establish a common understanding of the Ninth Brain Suite business model and its significance in relation to your privacy rights.

About Ninth Brain Suite

Ninth Brain Suite, LLC is a team of imaginative professionals who started with an idea to design a better, quicker, safer, and more accurate way to manage compliance and meet regulatory requirements for the healthcare industry. Ninth Brain Suite is recognized as one of the premier solutions for managing data, providing continuing education, and tracking regulatory requirements.

The Ninth Brain Suite business model

We operate a Software-as-a-Service (SaaS) business model, meaning we do not sell our customers’ users’ data or monetize that by selling advertising. Instead, we sell subscriptions to our services. Our customers have full control over the data they input into our services and how it is employed. A comprehensive explanation of how we manage and share data related to our customer representatives can be found in the subsequent section.

What does this Privacy Policy cover?

For the purposes of this policy, we will use the terms “controllers” and “processors” when referring to usage of your personal information. The controller is the entity or organization that determines the purposes and means of processing personal data. In other words, they decide why and how personal data is collected and processed. This entity is responsible for ensuring that the processing of personal data complies with data protection regulations. The processor is an entity that processes personal data on behalf of and according to the instructions of the controller. Processors do not determine the purposes or means of processing; their role is to execute the data processing activities as directed by the controller. Ninth Brain Suite may be either a controller or a processor, depending on the scenario.

This Privacy Policy applies when Ninth Brain Suite is the controller of your personal information and explains how Ninth Brain Suite collects, uses, and shares your personal information for its own purposes. For example, this Privacy Policy covers when you:

  • Visit a Ninth Brain Suite website that links to this Privacy Policy
  • Interact with Ninth Brain Suite as a representative of a company that has an account with Ninth Brain Suite
  • Register for or attend a Ninth Brain Suite webinar
  • Provide us with feedback about our products or services
  • Receive a sales or marketing communication from us, including emails or telephone calls

This Privacy Policy does not cover how we process personal information on behalf of our customers as a processor. If you are an employee of an organization that uses a Ninth Brain Suite product or service and you have questions or concerns about the personal information your organization holds in Ninth Brain Suite about you, please direct your request to that organization.

Privacy Policy

How we collect and use your personal information.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

Information provided by you.

In Short: We collect personal information that you provide to us. When we do so, we will use it in accordance with applicable laws.

When you request information from us. When you fill out a contact form or otherwise contact us to express interest in obtaining information about Ninth Brain Suite or our services, we may ask you to provide us with your contact information, such as name, business email, telephone number, company name, job level, functional role, and address.

  • Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests or your consent (where you have opted in to email marketing) to:
    • Fulfill your request and communicate with you
    • Provide you with information about our products in accordance with your marketing preferences (including telemarketing calls and marketing emails)

If you are our customer. If you are a representative of a company that has an account with Ninth Brain Suite, we collect your business contact information including your name, business email, telephone number, and company name. If you contact Ninth Brain Suite for support related to your organization’s use of our products, services, or events, we will also collect information about the reason for your inquiry and any other information you choose to provide to us.

  • Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests or your consent (where you have opted in to email marketing) to:
    • Communicate with you and fulfill your request for Ninth Brain Suite support
    • Manage your organization’s account, including invoicing and other account-related issues
    • Provide you with information about our products in accordance with your marketing preferences (including telemarketing calls and marketing emails)

If you register for events and webinars. When you register for an event or webinar, we may ask you to provide us with your contact information such as your name, business email, telephone number, and company name; your health and safety information such as your emergency contact and your dietary preferences; and your billing information such as your billing name, billing address, and credit card number.

  • Purpose and Legal Basis Under Data Protection Law: We process your personal information with your consent (where you have opted in to email marketing) to perform or enter contracts or terms of service with you, or if we do not have a contract directly with you, in reliance on our legitimate interests to:
    • Manage, plan, and host the event, including to send related communications
    • Improve our future events and our mobile application
    • Improve or enhance your (or your organization’s) experience interacting with Ninth Brain Suite
    • Provide you with information about our products in accordance with your marketing preferences (including telemarketing calls and marketing emails)

If you participate in research with us or otherwise provide us with feedback. When you voluntarily submit certain information to us such as providing Ninth Brain Suite with feedback about our products and services, we may ask for certain biographical or demographic information, such as your name, email address, contact information, time zone, location, company, employment status, tenure, role, job information, and other relevant information.

  • Purpose and Legal Basis Under Data Protection Law: Where you have entered into a contract with us, we will process your personal information for the performance of such contract. If we do not have a contract directly with you or otherwise obtain your consent, we rely on our legitimate interests to:
    • Fulfill the purpose set out in the study or survey
    • Improve your (or your organization’s) experience interacting with Ninth Brain Suite
    • Identify potential product improvements or future product developments for the workforce
    • Contextualize your feedback and experience with our products and services so that we can improve them

If you participate in a sales call or online meeting with Ninth Brain Suite. We may record sales phone calls and online meetings (including audio and video content where applicable) for training, quality assurance, and administration purposes. This includes analyzing the content of such calls and online meetings using AI-powered tools to gain better insights into our interactions with our customers and prospects. We will always notify you before a call will be recorded and will obtain your consent where required under applicable law.

  • Purpose and Legal Basis Under Data Protection Law: We process your personal information with your consent where required under applicable law or in reliance on our legitimate interests to:
    • Maintain high-quality sales calls and engagements with prospects and customers
    • Provide training and coaching to our sales teams
    • Generate automated call transcripts
    • Keep our records up to date (for example, in relation to follow-up meetings, sales opportunities, and updating customer contact details)
    • Improve our sales processes and make our sales calls more impactful

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected automatically.

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

When you access our websites or content. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, as well as for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://www.ninthbrain.com/cookie-policy/.

  • Purpose and Legal Basis Under Data Protection Law: We process your personal information in reliance on our legitimate interests to:
    • Better understand the visitors who come to our websites, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our websites to our visitors.
    • Provide, operate, and maintain our websites, including providing access to content you have requested and displaying country-specific information.
    • Protect the security and prevent misuse of our websites and services by tracking the use of our websites and services, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies.

If you are an end user of a Ninth Brain Suite product through a Ninth Brain Suite customer. When you use our products and services through your employer, we log certain system usage information automatically. This information may include system-generated identifiers such as IP address, operating system type and version, date and time stamps, and details about which of our products you are using. We do not identify you from this systems usage information unless your organization first provides us with instructions to do so, and provides us with certain information about your end-user account. This may happen in the context of a customer support request (e.g., when you or your organization ask us to help you resolve an issue you are having with our products and services).

  • Purpose and Legal Basis Under Data Protection Law: To the extent our systems usage information is treated as “personal information” under applicable data protection laws, we process this personal information in reliance on our legitimate interests to:
    • Provide and maintain the functionality of services and products you and/or your organization request
    • Assess and analyze your (and your organization’s) experience interacting with Ninth Brain Suite’s services
    • Undertake research and development in light of this assessment in order to improve the performance of the services
    • Protect the security and prevent misuse of our services by investigating suspicious activity and enforcing our terms and policies

Information obtained from other sources.

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for purposes of targeted advertising and event promotion.

Disclosing your personal information.

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Ninth Brain Suite LLC may share or make accessible your personal information to third parties as follows:

Your organization. Where your organization is a customer or potential customer of Ninth Brain Suite, we may disclose your personal information to relevant people within your organization. For example, we may disclose inquiries from end users that should be addressed directly by the organization rather than Ninth Brain.

Additional disclosures: Ninth Brain may disclose data if we have a good-faith belief that such action is necessary to (a) conform to legal requirements or comply with legal processes; (b) protect and defend our rights or property; (c) enforce our website Terms and Conditions; and/or (d) act to protect the interests of our customers, users, or others. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Protecting your personal information.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Transferring your personal information internationally.

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States and other countries.

We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights. For example, if we transfer personal information from the EEA, the UK, or Switzerland to another country such as the United States, we will implement an appropriate data transfer solution such as entering into “standard contractual clauses” approved by the European Commission or competent governmental authority (as applicable) with the data importer.  Following the adequacy decision by the European Commission, Ninth Brain Suite currently relies on the EU-U.S. Data Privacy Framework and the UK extension to the EU-U.S. DPF as a legal basis for transfers of personal information from the EU to the United States. For more information, see the Certifications subsection below or our Data Privacy Framework Notice and the UK extension to the EU-U.S. DPF here.

Retaining your personal information.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Certifications.

Data Privacy Framework.

Ninth Brain Suite adheres to the principles of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Ninth Brain Suite relies on the EU-U.S. DPF and the UK extension to the EU-U.S. DPF as a legal basis for transfers of personal information. To learn more, visit our Data Privacy Framework Notice here.

Your privacy rights.

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “Contact Us” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “Contact Us” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “Contact Us” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://www.ninthbrain.com/cookie-policy/.

If you have questions or comments about your privacy rights, you may email us at privacy@ninthbrain.com.

California Residents’ Rights

Notice to California Residents: If you are a California resident, you may have certain additional privacy rights.  Visit California Privacy Rights page for more information.

Contact us.

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@ninthbrain.com, by phone at (888) 364-9995, or contact us by post at:

Ninth Brain Suite LLC
ATTN: Privacy & Compliance Officer
481 N. Main St. Ste 148
Frankenmuth, MI 48734
United States

If you have any questions about this Privacy Policy, or wish to exercise your rights, please submit your request by filling out the form here.

Changes to this Privacy Policy.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

This Privacy Policy may be amended or revised from time to time at the discretion of Ninth Brain Suite. Changes to this Privacy Policy will be posted on the website and links to the Privacy Policy will indicate that the policy has been changed or updated. If we propose to make any material changes, we will provide notice on this page prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

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