You trust us with your personal information and data and we take this highly. We take confidentiality and privacy very seriously and handle your personal information and data with the utmost care. Below you find our detailed Privacy Agreement, but in a nutshell we follow four core principles when it comes to handling sensitive information.
We collect as little personal data and information as possible to provide you with the requested services.
We remove all personal data and information within 6 months of ending our services with you.
At any point in time you can request to view, edit or delete the personal information and data we hold of you.
We would never sell your personal information and data to third parties or profit from it in any way.
LastUpdated October 31, 2020
Welcome to our Privacy Agreement. We are THE BREIMER GROUP PTE LTD (UEN201908908E) of 531AUpper Cross Street #04-95 Hong Lim Complex Singapore 051531 (“The BreimerGroup”). This policy sets out how we handle your personal information if you are a user or visitor to Sites or Services of The Breimer Group. It applies across TheBreimerGroup.com, CourageousTeams.com, our individual tech platforms and all related Sites and Services (the “Sites and Services”).
1.‘We’, ‘us’ or ‘The Breimer Group’ refers to our organization who owns and runs the Sites and Services.
2.If we say ‘agreement’ we are talking about this Privacy Agreement. If we say ‘user terms’ we are talking about the rules for using each of the Sites and Services. Each Site and Service seeks consent to them separately to this policy.
3. We collect certain personal information about visitors and users of our Sites and Services.
4.The most common types of information we collect include things like: names, email addresses, IP addresses, other contact details, demographic information, assessment responses, payment information such as payment agent details, transactional details, support queries and web analytics data.
5. We collect personal information directly when you provide it to us, automatically as you navigate through the Sites and Services.
6. We collect your personal information when you provide it to us when you complete the Courageous Teams Index assessment and / or buy items and services through our Sites and Services, subscribe to a newsletter, email list, submit feedback, enter a contest, send us any type of media (including but not limited to video, photo and audio), fill out a survey or send us communication in any shape or form.
7. Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
a. Financial and / or transaction details from a payment provider, such as Stripe, in order to process a transaction on our website
a. To fulfil a transaction, or take steps linked to a transaction, in particular, in facilitating and processing transactions that take place on the Sites and Services, like where you purchase an item from our Sites and Services.
b. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
i. Operating the Sites and Services;
ii. Providing you with services described on the Sites;
iii. Verifying your identity when you sign into any of our Sites and Services;
iv. Responding to support tickets, and helping facilitate the resolution of any disputes;
v. Updating you with operational news and information about our Sites and Services, e.g. to notify you about changes to our Sites and Services, website disruptions or security updates;
vi. Carrying out technical analysis to determine how to improve the Sites and Services we provide;
vii. Monitoring activity on the sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites and Services’
viii. Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites and Services or asking for your feedback or whether you want to participate in a survey;
ix. Managing our legal and operational affairs (including managing risks relating to content and fraud matters);
x. Training The Breimer Group team members about how to best serve our user community;
xi. Improving our products and services
xii. Providing general administrative and performance functions and activities; and using demographic information solely for research purposes to understand trends and patterns at macro level. This information is only processed in a way which does not identify anyone.
c. Where you give us consent:
i. Providing you with marketing information about products and services which we feel may interest you; and
ii. Customizing our services and website– in order to provide a more personalized experience
d. For purposes which are required by law.
e. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation8. We will use your personal information:
9. We will disclose personal information to the following recipients:
a. Subcontractors and service providers who assist us in connection with the ways we use personal information (as setout above), in particular: website hosting providers; technical and customer support services; marketing and analytics services; and payment processing services;
b. Practitioners or associates who have been contracted by your organization for workshop or consultancy services;
c. Researchers who may use aggregate demographic information (but not data specific to any individual) to improve the survey and for research purposes;
d. Regulators and government authorities in connection with our compliance procedures and obligations;
e. Purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers ,in connection with the purchase;
f. A third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
g. A third party, in order to enforce or defend our rights, or to address financial or reputational risks;
h. A rights holder in relation to an allegation of intellectual property infringement or any other infringement; and Other recipients where we are authorized or required by law to do so
10. As a worldwide organization, TheBreimer Group collects information that may be processed internationally throughout our offices, subcontractors or service providers worldwide. We are based in Singapore, but some of the recipients we have described in section 9above, and to whom we disclose your personal information, are based outside of Singapore, for example in places like the European Economic Area, the United Kingdom, the United States of America, Southeast Asia, South Asia and Australia.
11. We transfer and store your personal information with these parties on the basis of your consent to this policy. These subcontractors and service providers process the data based on our instructions and in compliance with our Privacy Agreement and any other appropriate confidentiality and security measures. For example, we use service providers such as Amazon Web Services for cloud data storage. Any vendor or agent that we retain is not allowed to use Personal Information they receive from us for any other purpose than to perform the contracted services we have contracted them to perform. Like The Breimer Group, they will never barter, trade or sell access to your information.
12. We store personal information on cloud based secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location in Singapore or any of The Breimer Group’s offices worldwide. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication and data encryption where appropriate.
13. You have the right to make a request to access your personal information we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details at the end of this Agreement.
14. Where we have your consent to do so(e.g. if you have subscribed to one of our email lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel maybe of interest to you. You can ‘opt out’ of such communications if you would prefer not to receive them in the future by using the ‘unsubscribe’ facility provided in the communication itself.
15. If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user whether via our Sites and Services or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites and Services, ask them how they will handle your information. If you’re sharing via another website, check the privacy agreement for that site to understand its information management practices as this privacy agreement will not apply.
16. We retain your personal information for as long as it is necessary to provide the services to you and others, and to comply with our legal obligations. Once our service offering with you has ended, we remove all personal identifiable information within 6 months of ending our services with you. If you no longer want us to use your personal information or to provide you with The Breimer Group services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information, we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Agreement.
17. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. For these reasons, we suggest that users and visitors who may have specific concerns about the information being gathered and use of that information regularly view the Privacy Agreement on our site. The Breimer Group reserves the right to change the policy on use of information collected at any time.
17. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. For these reasons, we suggest that users and visitors who may have specific concerns about the information being gathered and use of that information regularly view the Privacy Agreement on our site. The Breimer Group reserves the right to change the policy on use of information collected at any time.
18. If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact our Privacy team in writing through privacy@courageousteams.comor Privacy Team of The Breimer Group, 531A Upper Cross Street #04-95 Hong Lim Complex Singapore 051531.
19. This Agreement is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Agreement.
This Privacy Notice for European Union citizens and residents supplements the information contained in The Breimer Group’s Privacy Agreement and applies solely to all visitors, users and others who are European Union citizens or residents. We adopt this notice to comply with the General Data Protection Regulation (the ‘GDPR’). The following rights also apply to you:
1. For the purposes of applicable EUdata protection law, including the GDPR, we are a ‘data controller’ of your personal information.
2. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have the rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
3. These rights are limited in some situations – for example, we can demonstrate that we have legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
4. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
5. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country:(i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Both personal information and personal data have the same meaning in the context of this Privacy Agreement and Privacy Notes.
COURAGEOUS TEAMS is created by The Breimer Group Pte. Ltd.
The Breimer Group is registered in Singapore under registration UEN201908908E
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