Privacy Policy

BRAIN Commons Privacy Policy

Last Updated March 2019

This website, located at www.braincommons.org (the “Site”), is provided by Cohen Veterans Bioscience, Inc. (“CVB,” “we,” “our,” or “us”), to the person accessing the Site (“you” or “your”).

Your access to, and use of, the Site is subject to the BRAIN Commons Terms of Use (the “ Terms of Use”). We have created this BRAIN Commons Privacy Policy (this “Privacy Policy”) to explain what information we gather when you visit or interact with the Site, how we and others may use your information, and the security approaches we use to protect your information. This Privacy Policy is incorporated into and made part of the Terms of Use. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms of Use.

By using the Site, or by signing below, you consent to the collection and use of your information in accordance with this Privacy Policy. If we decide to change this Privacy Policy, we will post the updated version on this page. Changes to this Privacy Policy will apply only to information collected after the date of the change.

Note Regarding Contributed Data on the Site: The Site is an online platform dataspace or “commons” to facilitate and encourage sharing and analyses of various datasets from research into brain disorders and diseases (collectively, “Data”). CVB strives to foster ethical, authorized and lawful Data sharing and use. CVB is responsible for managing the Site. Users are responsible for their use of the Data and related tools. We prohibit Users and other contributors from posting any raw Data to the Site, unless it is uploaded pursuant to and in accordance with a BRAIN Commons Data Contributor Agreement between us and the contributor of Data. Any such contributed Data must be de-identified in accordance with all applicable laws and regulations, and such Data must not include any personally identifiable information or other regulated personal information (collectively, “personal information”) of any patients, subjects or participants in the clinical studies through which the Data was generated or gathered. Please review the BRAIN Commons Data Use Policy for more information about contributing, using and sharing Data. We may access or use contributed Data for the purposes of operating, maintaining, monitoring, analyzing, improving, controlling, or customizing the Site, as contemplated by the Terms of Use or our other applicable Policies or agreements. We do not re-identify de-identified information.

1. What information is gathered?

We may collect and retain information from or about you when you register on the Site, seek authentication, send or respond to communications, or participate in another Site feature. Here are the types of personal information we gather:

  • Information You Give Us: When registering or seeking authentication, or otherwise communicating with us, we may ask you for your name, email address, mailing address, phone number, credentials or other similar information.
  • Automatic Information: We receive and store certain types of information whenever you interact with us, including IP addresses and session identifiers. Like many websites, we use “cookies” to enhance your experience and gather information about Users and visits to the Site. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them.
  • Information from Other Sources: For purposes such as authentication, monitoring, completeness or accuracy, we may receive information about you from other sources, including third parties you have authorized to share information with us, and we may add or relate such information to your account.
  • Contributed Data: As discussed herein, and in the Terms of Use and other applicable Policies, certain contributed Data may be available via the Site. Access to and use of contributed Data is subject to the Zone Rights applicable to such Data and all applicable Policies.

2. How do we respond to “Do Not Track” signals?

Because there is not yet a common understanding of how to interpret web browser- based “Do Not Track” (“ DNT”) signals other than cookies, we do not currently respond to, or provide Users with a different Site experience based on, undefined “DNT” signals to the Site.

3. How do we use your personal information?

We may use your personal information in any of the following ways:

  • To authenticate or update your information.
  • To administer your account or profile.
  • To respond to your support requests or otherwise communicate with you.
  • To provide or facilitate any services or transactions associated with your account.
  • To personalize and optimize your Site experience and to learn about your preferences.
  • To monitor your compliance with the Terms of Use and all applicable Policies.
  • To prevent or remedy any unauthorized or disruptive activity.
  • To administer a survey or other Site feature.
  • To operate, maintain, analyze, improve, control, or customize the Site.

4. Do we disclose the information we collect?

Except as otherwise described in this Privacy Policy, we do not sell, trade, or otherwise transfer personal information to outside parties unless we provide you with advance notice. We may disclose personal information as described below:

  • Agents and Contractors: We may contract with other companies and individuals to operate the Site and to perform functions on our behalf. Examples include maintaining and hosting the Site, analyzing data, and providing support. Our agents and contractors have access to personal information needed to perform their functions, but they must reasonably safeguard such information and they may not use it or disclose it for other purposes.
  • Authentication and Monitoring: We may disclose your personal information to third parties as reasonably necessary to authenticate you and your information, as applicable. To facilitate transparency and collaboration, we may use or facilitate monitoring tools that show us and other Users certain information regarding your conduct on the Site, including Data types or analysis tools accessed or contributed. You will have the ability to adjust certain privacy settings with respect to any such tools. Please click here for more information about such monitoring tools.
  • Business Transfers: In the event that we transfer our assets, or reorganize, merge or transfer our entity, we may provide your information to the purchaser to enable continued use of the Site. We will take reasonable steps to seek similar treatment of your information, but the purchaser might operate under a different privacy policy.
  • Protection of CVB and Others: We release personal information when we believe it is appropriate to comply with law; enforce or apply the Terms of Use or our other applicable Policies or agreements; or protect the rights, privacy, property, or safety of CVB, Users or others. We may share information regarding unauthorized or suspicious activity with affected Users, governance board for the BRAIN Commons, an independent Institutional Review Board or other ethics board, or institutional authorities, as applicable. We may assist Data contributors with their review submissions to an ethics or other review board.

Subject to applicable law, we may share aggregated and statistical information with third parties.

5. How is personal information corrected or updated?

You can correct or update your personal information by re-registering, updating your profile, or by contacting us at hello@braincommons.org. You can also request that we delete your personal information or remove you from our communications.

6. Do we use “cookies”?

Yes. We use web tracking tools such as cookies and web beacons. A cookie is a small data file that certain websites write to your hard drive when you visit those pages, but the only personal information a cookie can contain is information you supply yourself. We use cookies to track User traffic patterns when you click on various links throughout the Site to help us understand your preferences and to offer better experiences and tools on the Site.

We may contract with third party service providers to assist us in better understanding our Users. These service providers are not permitted to use the information collected on our behalf, except to help us conduct and improve the Site.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies, through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you might not be able to access or use certain Site services, features or functionality.

7. How secure is personal information?

We follow generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security, and properly use your personal information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of that information during its transmission or its storage in our systems.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are finished using the Site.

8. Discussion Forums and Third Party Links

The Site may include User-to-User communication functionality, such as discussion forums. If you choose to use any of these features, any information you disclose could be accessed and further disclosed by other Users.

In an attempt to provide you with increased value, we may include third party links on the Site. These linked sites have separate and independent privacy policies, which we encourage you to review. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of the Site and welcome any feedback about these linked sites (including if a specific link does not work).

9. Questions and Feedback

Any questions and feedback about the Site or this Privacy Policy should be directed to hello@braincommons.org.

10. Important Notices to Non-United States Residents

It is important to note that the Site is operated in the United States. If you are located outside of the United States, please be aware that any personal information you provide to us will be transferred to the United States. By using the Site and/or providing us with your personal information, you consent to this transfer.

11. Children’s Privacy

The Site is not directed to, and we do not knowingly collect personal information from, children under 13 years of age. If a child has provided us with personal information, a parent or guardian of that child may send an email message to hello@braincommons.org with “Request for Child Information Removal” in the subject line and the name and age of the child in the body of the message. After confirmation, we will make reasonable efforts to delete the child’s information from the database that stores information for the Site.