EFFECTIVE DATE: March 1, 2021

 (“Company”, “we” or “us”) is committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect, use, disclose and store your Personal Information (defined below). It applies to all Personal Information collected via the website at www.brewco.ai (“Website”), as well as written, electronic, and oral communications with us.

Unless we define a term in this Policy, all capitalized terms used in this Policy have the meaning provided in our Terms of Service (“Terms of Service”), which you can view here. Please make sure that you have carefully read and understand the Terms of Service before you use our Website. By using our Website, you accept the Terms of Service and accept our privacy practices described in this Policy. If you do not feel comfortable with any part of this Policy or our Terms of Service, you must not use or access our Website.

We may modify this Policy from time to time. The date of change will be shown next to “Effective Date” at the top of this page. We encourage you to read this Policy periodically to ensure you have up-to-date knowledge of our privacy practices. By continuing to access or use the Website after changes to this Policy become effective, you agree to be bound by the revised Policy. If any changes are unacceptable to you, you may stop using our Website at any time.

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If you are a resident of an European Economic Area (“EEA”), this whole Policy applies to you. However, EEA residents should see Section 10 below, which will inform you in detail about the Personal Information we process, how we process it, for which purposes we process it, with whom we share it, on what legal basis we process and transfer your Personal Information and which rights you have regarding the processing of your Personal Information.

 

1.         Personal Information We Collect

We collect Personal Information when you use our Website and/or submit Personal Information to us. Personal Information is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual or household, including, but not limited to, a first and last name, email address, a home, postal or other physical address, and phone number. The types of Personal Information that we may collect about you are:

 

a. Information You Provide to Us

We collect information you give us when you post to or otherwise use our Website, when you participate in surveys or promotional activities, or when you otherwise choose to submit your information to us.

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b. Communications from You

When you use our Website, complete electronic forms, or contact us, by online chat, email, phone or text, we may collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction; and the action we took in response to your inquiry or request.

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c. Information from Others.

When using our Website, you and other users may post content that includes information about you (as part of posts or comments) on our services and products. We also may receive certain information from our third- party vendors and partners, including, but not limited to our resale partners and/or licensors.

 

d. Information Related to Your Use of the Services

We may automatically collect information about your use of the Website (we refer to this information as “Usage Data”). For example, we may collect:

• Device information, such as your hardware model, IP address (the Internet address of your computer), unique device identifiers, and other information such as your browser type and operating system.

• Website usage information regarding web page traffic patterns and activity. This may include the web page that you were visiting before accessing our Website and the pages or features of our Website you browsed to inform us which part of our Website you visit and how much time you spend there.

• Information about your preferences to make your use of the Website more productive through the use of cookies.

 

e. Location Information

When you use our Website, we may collect and store information about your general location by converting your IP address into a rough geo-location. If you do not want us to have your location information, you may disable the location sharing feature on your browser.

 

2.        Cookies and Other Tracking Technologies

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a. Cookies

A “cookie” is a small data file that certain websites write to your computer or smart device when you visit them. A cookie can’t read data off your hard disk or read cookie files created by other websites. We use session cookies that are deleted when you leave our Website and close your browser, and persistent cookies that can remain even after you leave. A cookie file can contain information such as a user ID that the website uses to track the pages you’ve visited. The cookies that are configured by our Website do not contain directly identifying information, such as your name or credit card number.
 

Generally, we use first-party cookies for the following purposes:

• to make our Website function properly;

• to provide a secure browsing experience during your use of our Website;

• to collect passive information about your use of our Website;

• to measure how you interact with our marketing campaigns and content;

• to help us improve our Website; and

• to remember your preferences for your convenience, as applicable.

 

Types of Cookies on Our Website. We use the following types of cookies:

• Strictly Necessary Cookies – These cookies are essential because they enable you to use our Website. For example, strictly necessary cookies may allow you to access secure areas on our Website, as applicable. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Website to work and they cannot be disabled.
   

• Functional Cookies – We use functional cookies to remember your choices so we can tailor our Website to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name and location. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Website.
   

• Performance or Analytics Cookies – These cookies collect passive information about how you use our Website, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Website. We do not use these cookies to target you with online marketing. You can disable these cookies.

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How to Manage Cookies.  You will need to take the following steps:

• First-Party Cookies – If you prefer not to receive cookies while browsing our Website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by changing the settings in your browser. You do not need to have cookies turned on to use and navigate through many parts of our Website, although if you block or disable the cookie functions, you may not be able to access all portions or features of the Website. Please follow instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings) to disable first-party cookies.

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b. Web Beacons

Web Beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our Website to deliver or communicate with cookies, in order to track and measure the performance of our Website and to monitor how many web visitors we have. Unlike cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

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c. Analytics Technologies

Users of our Website who have JavaScript enabled are tracked using analytics technologies, currently Google Analytics. Unless the Analytics feature is blocked, it collects the following types of information from the user: type of user agent (web browser) used, software manufacture and version number; type of operating system; network location and IP address; country, city, state, region, county, or any other geographic data; hostname; bandwidth (internet connection speed); time of visit; pages visited; time spent on each page of the Website; referring site statistics; the website (URL) the user came through in order to arrive at our Website; search engine query used (example: typing in a phrase into a search engine, and clicking on a link from that search engine). The data collected by the analytics technology is primarily used to optimize the Website experience for our users. We also use this data for our own business purposes, for example, to analyse how many users we have, where visitors come from, and understand how they interact with us.

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3.         How We Use Your Personal Information

We will only use your Personal Information as described in this Policy or otherwise through your informed consent.

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a. To Provide Our Services to You

We will use your Personal Information to provide information that you request. We may also send your Personal Information to our partners, including SEO Engine, Inc. and its affiliates. If the applicable information is to be provided or performed by a third party, then we will disclose the applicable information to the third party providing the information or performing the applicable services. Your information may be available or provided to third-party service providers who are contractually obligated to protect your information as disclosed in this Policy. In the preceding twelve (12) months, we have not sold any Personal Information to any third party; provided, however, we may have received a referral fee for any lead we have provided to our partners when you have requested information on certain services – See Section 4(a) of this Policy for more information.

 

b. For the Operations and Administration of Our Business

We will use your Personal Information for the purposes of furthering our business, including creating, operating, delivering, maintaining, and improving our content, products, and services. We may monitor how our users use our Website including without limitation time spent using our Website, pages visited, and content viewed. Aggregated forms of this data may also be used for research and development purposes in order to offer new features, functionalities, products and services.

 

c. For Business Analytics Purposes

We analyse, and may engage third parties to analyse, your Personal Information and Usage Data to determine the usefulness of our Website. Analytics help us determine how effective our navigational structure is in helping users reach the information they seek, completing the task they wish to complete, etc., and to tailor features and functionalities to our users’ needs and preferences.

 

d. For Our Own Marketing Purposes

Marketing lets us grow our community and update you about new products and services. We process your contact information or information about your interactions on our Website or with us to: send you marketing communications and keep you updated about our products and services; provide you with informational content; and deliver targeted marketing to you. We may periodically send you free newsletters and e-mails that directly promote our services, and that we believe may be of interest to you. When you receive such promotional communications from us, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. We do need to send you certain administrative and transactional communications and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Policy.

 

e. To Provide Customer Support or Respond to You

We collect information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues, so we can address your needs and support your use and enjoyment of the Website and our services.

 

f. For Network Security Purposes

We care about keeping you secure and safe while using our Website. Keeping you safe requires us to process your Personal Information, such as your device information, activity information and other relevant information to proactively manage privacy and security risks. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.

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g. To Enforce Compliance with Our Terms and Agreements or Policies

When you access or use our Website, you are bound to our Terms of Service and this Policy. To ensure you comply with them, we process your Personal Information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Website. We also process your Personal Information to investigate, prevent or mitigate violations of our Terms of Service, agreements or policies.

 

4.         Information Sharing and Disclosure

Your Personal Information is not shared with third parties without your permission, except as described below.

 

a. Information Shared with SEO Engine and Partners 

When requesting services through the Website, we will refer users to SEO Engine, Inc. and track referrals which result in sales. We will share leads with our reseller partners for users that request such services and may receive a referral fee in certain instances.

 

b. Information Shared through our Services

The Website allows for the uploading, viewing and sometimes sharing of information. For example, when you upload User Content or comment on it, that information, including any Personal Information included therein, can be viewed by the public. We recommend that you do not post on or through the Website any information that you do not want to make available to the public generally.

 

c. Information Shared with Our Employees, Services Providers

We may engage employees and third-party service providers to work with us to administer and provide the Website or to promote our Website and services (e.g. marketing, analysis, development, and customer support). These employees and third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.

 

d. Information Disclosed in Connection with Business Transactions

If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. Any information you submit or that is collected after a transfer, however, will be subject to a new privacy policy adopted by the successor entity.

 

e. Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information about you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate: (i) to enforce our Terms of Service, (ii) to respond to claims and legal process (including subpoenas); (iii) to protect the property, rights and safety of a third party, our users, or the public in general; (iv) to protect our property, rights and safety; (v) to stop any activity that we consider fraudulent, illegal, unethical or legally actionable; and (vi) as required by applicable local, state or federal laws.

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5.         Data Security

We safeguard the security of the information you provide to us with physical, electronic, and administrative procedures. While we strive to protect your information, we cannot guarantee the security of the Internet, and cannot ensure the security of the information that is transmitted through the Internet. Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. We recommend that you do not post on or through the Website any information that you do not want to make available to other users or the public generally. You assume all responsibility for any loss of privacy or other harm resulting from information you post publicly.

 

6.         Responding to Do Not Track Signals

We do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Policy.

 

7.         Children and Privacy

Protecting children’s privacy is important to us. We do not direct the Website to, nor do we knowingly collect any personal information from, children under the age of 13. If we learn that a child under the age of 13 has provided Personal Information through the Website, we will use reasonable efforts to remove such information from our files and servers.

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8.         Links to Third Party Sites

We may contain links to other sites that are owned or operated by third parties. We are not responsible for the content, privacy or security practices of any third parties. To protect your information, we encourage you to learn about the privacy policies of those third parties.

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9.         Your Choices

a. Information You have Provided

You may update certain  information you provide to us by contacting us at hello@neuraldigital.com.au. Please note that we retain certain information when required or permitted by law. We also retain cached or archived copies of information about you for a certain period of time.

b. Promotional Communications

You may opt out of receiving promotional emails from us by following the instructions in those emails or communications. If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations, as applicable.

 

10.       International Transfer

Your information is stored on controlled servers with limited access and may be stored and processed in the United States or another country where our service providers are located. If you are located outside the United States and choose to provide your Personal Information to us, please note that we may transfer your Personal Information to the United States or another country where our service providers are located, and such countries may not provide the same data protection. Those who choose to access and use the Website from outside the United States do so on their own initiative, with this understanding.

 

a. Legal Basis for Processing

When we process your Personal Information, we will only do so in the following situations:

• As necessary and when we have your consent to provide you with information that you have requested;

• When we have a legitimate interest in processing your Personal Information, including to help secure and improve our Website (including to prevent fraud) and to analyse use of our Website; and

• As necessary to comply with our legal obligations.

 

b. Data Retention

We retain Personal Information for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.

 

c. Data Subject Requests

Subject to certain limits and conditions provided under law, you have the following rights:

• You have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, erased, or made available in a portable form.

• You also have the right to object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).

• When we ask for your consent, you may withdraw that consent at any time.

• You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. 

• If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

• If you are in the United Kingdom, please see this site for contact details: https://ico.org.uk/global/contact-us/

If you would like to exercise any of these rights, you may contact us as indicated below.

 

11.       Contact Us

If you have questions or concerns about our collection, use, or disclosure of your Personal Information, please email us at hello@neuraldigital.com.au Or write to us at: Privacy Officer, Neural Digital, 404 Bowen Terrace, New Farm, QLD 4005.