Privacy Policy

Last Modified: February 8, 2017

Thank you for using the RobertoTM web site (the "Roberto Site") and the Roberto brain performance monitoring application (the "Roberto Test"). The Roberto Site and the Roberto Test were created by Home Base Impairment Company, Inc. ("HBIC" or "we"). This Privacy Policy governs the use by HBIC of any information collected from someone's access of the Roberto Site and/or use of the Roberto Test.

If for any reason you do NOT agree to the terms of this Privacy Policy, you must NOT use, and/or immediately STOP using, the Roberto Site, and/or immediately STOP taking the Roberto Test.

  1. Registration and Access to Services Although many aspects of the Roberto Site are available without having to register, some of the content and functionality of the Roberto Site, including the ability to take the Roberto Test and to review the results of the Roberto Test, require you to register. If you register on the Roberto Site to take the Roberto Test, you will be required to submit certain information which could be used to personally identify you such as, for example, your name, address, email, password, height, weight, date of birth, gender, education level, demographic information, ethnicity, profession, place of work, preferred language, handedness, current and general physical activity level, Roberto Test site, Roberto Test location, Roberto Test supervision, and/or current and general physical/mental condition (collectively "Personally Identifiable Information").
  2. What Information We Collect
    • A. Information You Provide. You are not required to create an account with HBIC in order to access the Roberto Site. If you do create an account, we will request that you provide Personally Identifiable Information. If you subscribe to a paid account, in addition to Personally Identifiable Information, we will also need to collect billing information. We may also allow you to upload a photo of yourself and select your preferences receiving email communications.
    • B. Third Party Credentials. If you sign into the Roberto Site using your Facebook or other third party credentials, we may use that service to authenticate you. We may also collect other information that you have agreed may be provided by that third party, such as your username, name, email address, date of birth and gender. We collect this information so that it can be used for the purposes explained in this Policy. We may supplement the information you provide to us with additional information gathered from other sources, such as publicly available information.
    • C. Data We Collect. In addition to the Personally Identifiable Information you provide to us when you use the Roberto Site and the Roberto Test, we may also collect and store information about the computer, mobile device, or other devices you use to access the Roberto Site and the Roberto Test and about how you use the Roberto Site and the Roberto Test. We may also collect and store information such as your browser type, IP address, language, operating system, unique device identifier, the date and time of your visit, the pages you view and the websites you visited immediately before and after visiting the Roberto Site.

      As for those who take the Roberto Test, we may also collect and store information regarding your performance and/or how efficiently you complete the Roberto Test, as well as how your performance compares to your earlier performances. We may collect and store information about you including your general and current physical/mental conditions prior to taking the Roberto Test.
    • D. Our Use of Cookies. To collect information, we use cookies and other standard web technologies (e.g., pixel tags). Cookies are small text files placed on the browser of your computer or mobile device when you visit a website that collects non-personal information. We use "persistent cookies" to save your login information for future logins to the Roberto Site. We use "session ID cookies" to enable certain features of the Roberto Test, to better understand how you interact therewith and to monitor aggregate usage and web traffic routing on the Roberto Site. Most browsers automatically accept cookies, but allow you to disable cookies through the "options" or "preferences" menu of your browser. Please be aware that disabling cookies could interfere with the functionality of the Roberto Site and the Roberto Test.

      Third parties whose products or services are accessible in and on the Roberto Site, including social networking services (e.g., Facebook, Twitter, etc.) may also use cookies or similar tools. Please review their privacy policies for information about their cookies and other privacy practices. The third-party advertising and analytics companies with whom we or our advertisers partner or may partner (e.g., Google, Yahoo, Bing, New Relic, etc.) may place a unique cookie or utilize similar technologies on your browser in order to collect non-personal information about your visits to the Roberto Site.
  3. 3. Submission of Personal Information Using the Roberto Site and/or taking the Roberto Test will require you to submit certain Personally Identifiable Information. If you are a parent or guardian of a child under 18 or under the age of majority in their jurisdiction of residence (a "Minor"), and are enrolling that Minor to take the Roberto Test, you and/or that Minor will need to also submit such personal information pertaining to that Minor to HBIC. By enrolling yourself, or a Minor over which you have authority, to take the Roberto Test, you are consenting to have HBIC collect your and/or your Minor's personal information. If you do not consent to HBIC collecting your or your Minor's personal information for use as set out in the Terms and Conditions, you must not enroll either yourself or your Minor to take the Roberto Test. Your consent to the submission of such personal information, be it from you or from a Minor over which you have authority, and HBIC's use of the same, is governed by the Terms and Conditions, and by the terms of this Privacy Policy. In the event of an inconsistency between the Terms and Conditions and this Privacy Policy, the Terms and Conditions shall control.
  4. 4. Minor's Privacy
    • A. HBIC believes that protecting the privacy of Minors is important. Although the content on the Roberto Site and the Roberto Test may be used by a Minor, including by a child under the age of thirteen, neither the Roberto Site nor the Roberto Test are designed to attract such Minors, especially those under the age of thirteen.
    • B. It is HBIC's intent and directive to comply with all laws pertaining to the protection of a Minor's privacy, including, without limitation, the Children's Online Privacy Protection Rule (16 CFR 312).
    • C. Regarding the privacy of all Minors who access the Roberto Site and who use the Roberto Test, it is the responsibility of that Minor's parent or guardian to consent to such access or use. For a more detailed explanation of the parent's or guardian's responsibilities regarding a Minor's right to access the Roberto Site or to use the Roberto Test, refer to Section 1.B. of the Terms and Conditions.
  5. 5. How We Use Your Information at HBIC
    • A. We use the information we collect to operate and provide you with the Roberto Site and the Roberto Test. This includes, but is not limited to, the following: (1) Authenticating your login and processing your payments; (2) Personalizing your Roberto Site and your Roberto Test experience; (3) Allowing you to monitor your performance and progress in the Roberto Test through the Roberto Site, by, for example, presenting charts, graphs and/or reports of your performance to you; (4) Customizing and delivering information about our products and services to you by email; (5) Providing customer service and sending confirmations to you about your account; (6) Protecting our intellectual property or other rights; and (7) Managing and improving our business, our tests, our products, and our services.
    • B. You can opt out of receiving most emails by changing your preferences in your profile on the Email Notifications page, but we reserve the right to email you to confirm transactions or to address account issues, such as when you make a purchase, or you request a reset password.
    • C. We also reserve the right to use non-personal information (e.g., de-identified or aggregate data) for any purpose. For example, we may show aggregate performance measures to users to allow them to evaluate their performance against other Roberto Test takers. Also, we may disclose performance statistics to collaborators to evaluate, study, and improve the effectiveness of our programs or human cognition more generally. In these situations, all data is disclosed either in aggregate form or with information that can identify you removed. In addition, when we work with collaborators, we contractually prohibit them from attempting to re-identify individuals from data that has been de-identified.
  6. No Disclosure to Third Parties for Their Own Marketing Purposes We believe in protecting your privacy, and therefore do not provide your personal information to third parties for their marketing purposes
  7. When We Share Your Personal Information with Third Parties We reserve the right to share your personal information in the following ways with third parties:
    • A. Service Providers and Agents. We may share your information with certain third parties selected by HBIC to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer service requests. In addition, we may share limited personal information to third parties that help us market or advertise the Roberto Site and/or the Roberto Test. These third parties may have access to your information only for purposes of performing these tasks on our behalf; and we contractually require them to protect your information consistent with this Policy.
    • B. Affiliates. We may share your information with our corporate affiliates, such as entities under common ownership or control.
    • C. Business Transfers. We may sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, business transaction, or in the event of bankruptcy. In such scenarios, your information may be one of the assets transferred. We will post a notice or otherwise notify you before the information is transferred and becomes subject to a different privacy policy.
    • D. Compliance with Law and Law Enforcement Requests, and Protection of Our Rights. We may disclose your information when we have a good faith belief we are required to do so by law, or in response to a subpoena, court order, or other legal mechanism. We may also disclose your information when we have a good faith belief that disclosure may prevent fraud and abuse of the Roberto Site and/or the Roberto Test, or its users, or protect our property rights.
    • E. Consent. We may disclose your information when we believe we have your consent to do so, such as when you contact customer service and ask us about your account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your account. We may also disclose your information for the purpose of facilitating the research to which you have consented.
  8. Accessing, Reviewing, and Deleting Your Information You can access, review and correct the registration and demographic information we have collected about you by logging into your account and navigating to the Account page. You may also access or delete the information all of the information we have collected about you by contacting us at the contact information listed below. While we will make reasonable efforts to accommodate your requests, if allowed by applicable laws, we reserve the right to impose certain requirements and restrictions on such requests, such as limiting our production of information to certain formats.
  9. Security of Personal Information We have implemented and maintain reasonable security practices to protect against the unauthorized access, use, modification, destruction or disclosure of your personal information. For example, we use one or more of SSL encryption, firewalls, and anti-virus software. However, no method of transmission or storage is completely secure, and we therefore cannot guarantee absolute security.
  10. Outside the United States Consent to Processing and Transfer of Information If you access the Roberto Site and/or the Roberto Test outside of the United States, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection and processing of such personal information in the United States.
  11. Change Policy HBIC reserves the right, in its sole and absolute discretion, to amend this Policy from time to time. If we make material changes, we will provide advance notice to you either by email, by posting a notification on the Roberto Site or by posting an updated Privacy Policy on the Roberto Site. For purposes of this Policy, "material" means a change which expands the HBIC's ability to collect, use or discloses, Personally Identifiable Information.

    Please note that, for existing users and paid subscribers, unless otherwise provided by applicable law, your continued use of the Roberto Site and/or the Roberto Test following the effective date of a new Privacy Policy means that you agree with, and consent to be bound by, the updated Privacy Policy.
  12. Contact Information We welcome inquiries or comments about our Privacy Policy and you may contact us via email at Privacy@Roberto.com. You may also send a letter to the following address:

    Director of Privacy
    Home Base Impairment Company, Inc.
    425 Mill Street
    Coraopolis, PA 15108