Last Modified: February 8, 2017
- 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").
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.
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. 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.
- 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
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.
- 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.
- 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.
- 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.
- 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.
Director of Privacy
Home Base Impairment Company, Inc.
425 Mill Street
Coraopolis, PA 15108