Privacy Policy

This Privacy Policy was last updated on April 12, 2023.

We spare no effort to provide you with high-quality data, analyses, and other content about the national and international market. The Brain Group, composed of Brain Inteligência Estratégica or "Brain", Global Talent, and GeoBrain ("Group"), respects the privacy of individuals who use the services of all companies within the group ("Users") and seeks transparency in how data is collected, used, and shared.

This Privacy Policy applies when the User visits or uses the website of one of the group's companies, purchases courses, enrolls in our online courses, registers on our application, contacts one of our consultants, visits landing pages, receives emails and newsletters, or uses any related services of the Brain Group ("Services").

By using our Services, the user agrees to the terms of this Privacy Policy. Do not use the Services if you do not agree with this Privacy Policy or any other agreement governing the User's use of the Services.

1. Types of Collected Data

The Group collects data entered by the User themselves, as well as registration and participation data from Users in the courses offered by Brain. We also collect automatic data, such as device information, language, location, and interactions or usage with the Group's Services. Below, we detail the ways in which data is collected from Users and the types of data collected.

1.1 Data Provided by the User

As Users utilize our Services, the Group may collect various types of data about them, either provided directly by the Users themselves or generated through their use of the services. Below, we outline the data that the Group collects when a User creates an account or uses the Services, including through third-party platforms. All the listed data is collected, processed, and stored by Brain, and is associated with the User's account.

1.1.1 Account Data

To utilize certain features of the Group's Services, such as downloading materials or enrolling in courses, the User must create a user account. When the User creates or updates their account, we collect and store provided data such as name, email address, phone number, and more. The collected data varies depending on the Service used by the User.

1.1.2 Shared Content

Some of the Group's Services allow interaction between Users or the sharing of content publicly, including posting questions, answers, or sending messages. This content may be publicly visible to others.

1.1.3 Course Data

When Users enroll in courses, their data is collected, including information about the course, start and completion dates, submitted forms, and other items necessary for Users to fulfill course requirements. For more details, refer to our Terms of Use.

1.1.4 Payment Data

During purchases, we collect certain User data such as the purchase date, User's name, and the purchase approval code, which are necessary for order processing. It's the User's responsibility to provide the required data for payment and billing completion, including name, credit card, billing address, and ZIP code, which are entered directly on our payment processing partners' platforms. For security reasons, Brain does not collect or store sensitive cardholder data, such as the full credit card number or card authentication data.

1.1.5 Surveys and Promotions

The Group may invite Users to participate in surveys, send emails with communications, or send promotions of the offered Services. If the User chooses to participate, we will collect and store provided data, such as name, email, profession, education level, experience level, state, city, phone number, and affiliation with organizations, among others. All data is subject to this Privacy Policy, unless otherwise specified explicitly in official rules or another privacy policy. When the Group uses a third-party platform for promotions, the third party's privacy policy will apply.

1.1.6 Communications and Support

If a User contacts the Group for support, to report an issue, or to clarify a question, regardless of whether they have created an account, information will be collected and stored. This may include contact messages, name, email, phone number, state, and other information that can be obtained through automated means, as highlighted in the section below. These data will be used to respond to the User and improve internal processes, respecting the terms and conditions of this Privacy Policy.

1.2 Data Collected Through Automated Means

When a User accesses the Group's Services, whether it's the website of one of the companies, the channel, products, courses, or landing pages, automated data is collected through tracking technologies, as detailed in the "Cookies and Data Collection Tools" section. The collected data is stored by the Group and associated with the User's account. Below, we detail what user data can be collected in an automated manner.

1.2.1 System Data

These are data about the User's computer or device, such as IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other system data and platform types.

1.2.2 Usage Data

Usage statistics about the User's interactions with the Services, such as accessed courses, time spent on pages or the Service, pages visited, used features, searches, click data, date and time, and other data related to the User's use of the Services.

1.2.3 Geographical Data

Approximate geographical location, including information such as country, city, and geographic coordinates, based on the User's IP address.

2. Collection and Analysis of User Data

The Group employs tools such as cookies (files that websites send to identify the User's browser or device or to store data in the User's browser), web beacons (small objects that enable measurement of actions taken by visitors and users utilizing the Services), analytics services, and advertising providers to gather the data listed in the section above. Some of these tools provide the User with the option to opt out of data collection.

2.1 Cookies and Data Collection Tools

Cookies can be used to collect, store, and share data about User activities on websites, which enable the remembering of details about visits, such as preferred language, and facilitate the use of the site. The Group uses cookies to identify the User during a single browsing session or to identify the User over a longer period, such as when the User requests to stay logged in. Cookies are also used to personalize the User's browsing experience, facilitate the User's connection to the Services, or recognize a user upon their return. The Group and its service providers, such as Google Analytics, also use cookies and similar technologies, such as web beacons, pixel tags, or local shared objects ("flash cookies"), to identify if a page has been visited, ascertain if an email has been opened, and to conduct advertisements and campaigns more efficiently. The Group uses cookies: (1) preference cookies, which remember data about the user's browser and preferences when using the Services on the website, such as language; (2) security cookies, which allow Users to connect to the Services, protecting against fraudulent access; and (3) session state cookies, which track User interactions with the Services, enabling the Group to enhance the browsing experience and the purchase process, being essential for the proper functioning of the Services. Thus, if the User chooses to disable them, certain Services may become unavailable or not function properly. The Group recommends that the User configure their browser to notify them about attempts to place cookies on their computer, as well as to define their cookie settings, limiting or blocking them. The Group emphasizes that, in the latter case, it may not be possible to access some or all of the Services, and there may be disruptions in the User's experience when using the Services.

2.2 Online Advertising

The Group utilizes third-party services, such as Facebook, Google Ads, and other networks, to provide advertising about our Services. Ads may be based on known information about the User, such as usage data and User system data (as detailed in Section 1), and information that these advertising service providers know about the User based on their tracking data. Ads may be based on recent activities or activities over time and on other websites and services, tailored to the User's interests.

2.3 Analysis

The Group employs third-party data analysis, such as Google Analytics, which helps examine Users' use of the Services, including information like the User's originating third-party site, User visit frequency, events within the Services, and usage and performance data. The Group uses this data to enhance the Services, gain a better understanding of how the Services operate on different devices, and provide information that may be of interest to the User.

3. Purpose of User Data

The Group uses User data to provide the Services, communicate with Users, resolve issues, protect against fraud and abuse, improve and update the Services, analyze how Users use the Services, deliver personalized advertising, as required by law, or for safety and integrity purposes. Below, we've listed the purposes for which the Group utilizes User data:

  • Provide and manage the Services, including displaying personalized content and enabling communication with other Users.
  • Process User requests and orders for specific products, services, information, or features.
  • Communicate with the User about their account, responding to queries or questions, sending administrative information including potential changes to our Services, Terms, or Agreements.
  • Send User information via email, text message, or call, regarding their progress in courses, new Services, promotions, and newsletters (which the User can opt out of at any time).
  • Manage User account preferences.
  • Facilitate the technical operation of the Services, including troubleshooting, protecting the Services, and preventing fraud and abuse.
  • Request User feedback.
  • Disclose and manage surveys and promotions administered or sponsored by the Group.
  • Learn more about the User by linking their data to other data through providers or analyzing data with the help of analytics service providers.
  • Improve our Services and develop new products, services, and features.
  • Analyze trends and traffic, track purchases, Services, and usage data.
  • Advertise the Services on third-party websites and applications.
  • As required or permitted by law; or
  • As the Group, in our sole discretion, determines necessary to ensure the safety or integrity of our Users, employees, third parties, or our Services.
4. Sharing of User Data

The Group shares certain User data with companies that provide services to the Group, Group affiliates, business partners, data enrichment and analysis providers, companies that assist us in conducting promotions and surveys, and advertising companies that help promote our Services. The Group may also share User data as necessary for security purposes, legal compliance, or as part of a corporate restructuring. Finally, we may share data in other ways, if it is aggregated or de-identified, or if we obtain User consent. The Group may share User data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

  • With other Users: Based on User settings, shared content may be publicly viewable if a User comments or asks a question in courses or on the Brain website.
  • With service providers, contractors, and agents: We share User data with third-party companies that provide services to the Group, such as payment processing, fraud prevention, marketing and advertising services, and email services. These service providers may access User data and are required to use it only as directed by the Group, solely for the purpose of providing the requested service.
  • With Group companies: User data may be shared with Group-related companies under common ownership or control to enable or support the provision of the Services.
  • With data analytics services: The Group utilizes third-party analytics tools, including but not limited to Google Analytics, to share contact information, system data, usage data (as detailed in Section 1), or de-identified data as necessary. De-identified data refers to data from which identifying information, such as the User's name and email address, has been removed. The goal is to communicate with the User in a more effective and personalized manner.
  • To enable social media features: Social media features embedded in the Services (such as the Share button for LinkedIn, but not limited to it) may allow the social media provider to collect information such as the User's IP address and the specific page on the Services the User is visiting, and set a cookie to enable the feature. User interactions with these features are governed by the privacy policy of the third-party company.
  • To administer promotions and surveys: We may use User data to administer, market, or sponsor promotions and surveys that the User chooses to participate in, as required by applicable law or in accordance with the rules of the promotion or survey.
  • For advertising: If we decide to offer advertising in the future, we may use and share certain system data and usage data with advertisers and third-party networks to display general demographic and preference information among our Users. We may also allow advertisers to collect system data through data collection tools (as detailed in Section 2.1) and use that data to provide targeted advertisements in order to personalize the User experience and perform web analytics. Advertisers may also share with us the data they collect about the User. To opt out of receiving advertising from participating ad networks, please refer to Section 6 (User Rights) below.
  • For security and legal compliance: We may disclose User data to third parties if (at our sole discretion) we believe, in good faith, that disclosure is:
    • Permitted or required by law;
    • Requested as part of an investigation, court order, or governmental or legal process;
    • Reasonably necessary as part of a valid subpoena, warrant, or other legally valid request;
    • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    • Necessary to detect, prevent, or address cases of fraud, abuse, misuse, potential violations of the law (or rules or regulations), or technical or security issues; or
    • Reasonably necessary, in our opinion, to protect against imminent harm to the rights, property, or safety of the Group, our users, employees, members of the public, or our Services.
    • We may also disclose user data to our auditors and legal consultants to assess our disclosure obligations and rights under this Privacy Policy.
  • In cases of change of control: If the Group undergoes a business transaction, such as a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a partial or total sale of assets, we may share, disclose, or transfer all user data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
  • After aggregation/removal of identification: We may disclose or use aggregated or de-identified data for any purpose.
  • With user permission: With the User's consent, we may share data with third parties beyond the scope of this Privacy Policy.
5. Security

The Group employs appropriate security mechanisms commensurate with the type and level of confidentiality of the data stored. These mechanisms aim to protect against unauthorized access, alteration, disclosure, or destruction of User data that is collected and stored. However, given that no system can be entirely safeguarded, the Group cannot guarantee that communications between the Group and Users, the Services, or any information collected or provided to the Group are entirely free from unauthorized third-party access.

6. User Rights

It is the User's right to determine how their data is processed and used concerning email communications, cookies, and analytics service providers. The User can contact the Group to clarify questions regarding the storage and usage of their personal data. Below, we've listed the User's options regarding the use of their data: (Note: The translation is incomplete. Please provide the remaining text you'd like me to translate, and I'll be happy to assist!)

  • Receipt of Promotional Emails: The User can choose not to receive promotional emails, newsletters, or communications and surveys from any of the Group's companies. To do so, the User can use the unsubscribe option available in the emails sent. The Group emphasizes that even with the opt-out from receiving emails, it will still send transactional and relationship-related communications about the Services, such as order and payment confirmations, course deadlines, Service updates, or Privacy Policy communications. These are examples, but communications are not limited to these. We will share with the User all necessary communications to ensure proper use of our Services and compliance with Service-related obligations.
  • The User can manage the use and permissions of cookies in their browser.
  • In the case of advertisements, if the User opts out of viewing them, they should access the Google Display Network in the Google Ads settings page.
  • If the User chooses not to share their information with Google Analytics, they should change their settings via the Google Analytics Opt-out Browser Add-on.
  • The User also has the right to access, update, or delete their data stored with Brain. To do so, they should send an email to [email protected]. The Group informs that its Services are not intended for use by individuals under 13 years of age. Individuals aged between 13 and 18 years must obtain permission from their parents or guardians to use the Services. If the Group becomes aware that it has obtained data from individuals under 13 years of age, or from individuals aged between 13 and 18 years without proper authorization, the Group will delete the data from its records. In cases where parents or guardians find unauthorized use of the Services, they should contact us via email at [email protected] to request the claim and/or deletion of User data. If the User has any questions about their rights, data collection, storage, or usage, they should contact us via email: [email protected]. The response time is 30 days. For security reasons, verification of the User's identity may be requested. The Group emphasizes that it may retain data when it has a legal right to do so, such as for mandatory record keeping as determined by law.
7. Privacy Policy Updates and Contact Information

The Group may update its Privacy Policy. In such cases, the User will receive notification by email and in the forms required by law, along with a summary of the key changes made. The changes will become effective on the day of their publication, unless explicitly stated otherwise. By continuing to use the Group's Services, the User accepts the rules and changes in the Privacy Policy, agreeing to abide by and follow the terms that are bound to it. The revised Privacy Policy supersedes all previous Privacy Policies. If the User has any doubts, questions, conflicts, or wishes to seek clarification about our Privacy Policy, they should contact us via email: [email protected].