Privacy Policy

Last Modified JULY 11, 2024

Mastermind Cognitive Training (“us,” “our,” or “we”) respects your privacy and the privacy of your children. This privacy policy (the “Privacy Policy” or “Policy”) describes the types of information we collect, how we use this information, and the choices that you can make about how we collect and use your information.

Please read this Policy carefully to understand our policies and practices regarding your information and the information that you provide when you: (a) use our websites (the “Websites”) and/or mobile application (the “App”), (b) enroll in the Mastermind Cognitive Training Program (the “Program”), or (c) when you interact with us via email or phone, opt for financing program offered by Mastermind Cognitive Training’s third-party financial partner (with financing program, ” Services”).

This Policy is part of the agreement that you may have entered with us, such as Services Agreement (the, “Agreement”). Any term not defined herein will have the same meaning as ascribed to it the Agreement. From time to time, we reserve the right to modify or amend the terms of our Policy. You will be notified of such changes by notifications on our Website, by e-mail notification informing you of such changes, or by any other reasonable means as required by applicable law. You should check this Policy frequently for any changes. Your continued use of our Website, App, Program and/or our Services following the posting of changes to this Policy will mean that you accept those changes.

1. What types of information do we collect?

Information You Provide to Mastermind COGNITIVE TRAINING

We collect Personal Information and information that is not Personal Information (“Non-Personal Information,” together with Personal Information, “Information”). “Personal Information” means the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a person or a household. We may combine Non-Personal Information with Personal Information, and in those circumstances, we will treat the combined information as Personal Information.

Information Collected Automatically

Mastermind Cognitive Training collects information about the Program and Services you use and how you use them. When you visit our Website or download our App we automatically receive your computer’s internet protocol (IP) address, your operating system and browser type, the web pages you visit on our Website, geolocation information, and the address of any referring website. This information is used to operate, maintain, and manage our online services in order to improve our website.

Analytics:
Mastermind Cognitive Training uses third-party service providers, such as Google Analytics, which uses cookies and other similar technologies to collect and analyze information about how our website is used. You can learn more about Google Analytics at https://www.google.com/policies/privacy/partners/ and https://www.google.com/analytics/terms/us.html, and you may choose to opt-out by visiting https://tools.google.com/dlpage/gaoptout.
Cookies:
We may also use cookies to collect the above information. Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all of our other cookie uses.

We or our third-party service providers may use the following types of cookies:

Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of users and to see how users move around our Websites when they are using it. This helps us improve how our Websites work by, for example, ensuring that users can easily find what they need on our Websites. These cookies generate aggregate statistics that are not associated with an individualized profile, and these stay on your computer until you delete them.
Functionality cookies. These cookies enable helpful but non-essential Website functions that improve your Website experience. By recognizing you when you return to our Websites, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences. These cookies generate aggregate statistics that are not associated with an individualized profile, and these stay on your computer until the duration of their use.
Advertising, tracking or targeting cookies. These cookies enable different advertising related functions. They may allow us to record information about your visit to our Websites, such as pages visited, and links followed so that we can make our Website and the advertising displayed on it more relevant to your interests.

Except for strictly necessary cookies, all first-party cookies set by this website will expire when you block or delete these cookies. Third-party cookie expiration periods are set by their respective owners.

Information Collected From Third-Parties

Third-Party Assessment Tools Providers: We may obtain completion reports from our third-party assessment tool providers (“Assessment Tool Providers”). Any report that we obtain from our Assessment Tool Provider is in de-identified and aggregated form. In some instances, you may have to establish a separate account. Mastermind Cognitive Training does not receive any login information from Assessment Tool Providers. Please read the terms and privacy policies of the Assessment Tool Providers carefully before establishing an account with them. Mastermind Sports has no control over how these Assessment Tools Providers collect, process, and transfer Information, including Personal Information.
External Call Centers: We may obtain Information from external call centers that we have engaged to provide services to us.
Third-Party Payment and Financing Partners: We may obtain your de-identified financial information from our payment processing partners, financing partners and other third-parties, such as, credit bureaus, and identity verification services.
Social Media: You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (such as Facebook and Twitter). The information we have access to varies by site and is controlled by your privacy settings on that social media site and your authorization. By associating an account managed by a third party with your Mastermind Cognitive Training account and authorizing Mastermind Cognitive Training to have access to this information, you agree that Mastermind Cognitive Training may collect, store and use this information in accordance with this Privacy Policy.

2. How do we use this information?

Mastermind Cognitive Training may use your Information in the following ways:

To Provide and Improve Our Programs

Mastermind Cognitive Training may use your information to aid enrollment or registration, prepare and administer a personalized plan for your child, facilitate any events, services or resources offered, and to process your payment. We also use your information to improve your experience while visiting our Website and App, and accessing our Programs and Services.

With your permission and applicable releases, Mastermind Cognitive Training may use information relating to your experience with the Program. This information may be used in marketing, such as the testimonials featured on our website. We will ask your permission before using your information for this marketing or outreach purpose and you may choose to opt-out of this use of your information at any time. To opt-out, please see Section 6 below titled Access and Control of Your Personal Information.

To Send Transactional Information

Mastermind Cognitive Training uses your Information to send you invoices and other transaction related information.

To Communicate With You

Mastermind Cognitive Training uses your Information to respond to you via email, phone call, text, social media platforms (including chat message), Google applications, and other forms of communication when you contact us and to keep you informed when you inquire, assess or enroll. We also use your information to communicate with you via email, phone call, text, social media platforms (including chat message), Google applications, and other forms of communication about our products, services, resources, and marketing that we believe may interest you.

Mastermind Cognitive Training is committed to providing you with the choice not to receive marketing information. To opt-out, please see Section 6 below titled Access and Control of Your Personal Information.

Research Purposes

Mastermind Cognitive Training may use de-identified or anonymized Information for scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws.

3. How is this information shared?

Third Parties

If it is necessary, Mastermind Cognitive Training may share your Personal Information with third parties to perform services on our behalf such as, providing technical services, communicating with you, sending emails, processing your credit card, providing Programs or Services, or sending marketing emails. These third parties may only use the personal information that is necessary to perform the function required and may not use it for any other purpose.

To Comply With Legal Obligations

We may access, preserve, use, or disclose your Information if we have a good faith belief that the law requires us to do so, or that it is reasonably necessary to detect, prevent, and address security, technical issues, or fraud.

Business Use

We may access, preserve, use, or disclose your Information in order to protect the rights of the business, its property, its employees and others, or to enforce Mastermind Cognitive Training’s billing or contracts.

In the unlikely event that Mastermind Cognitive Training is involved in a merger, acquisition, sale or other change in ownership, our customers’ information may be among the transferred business assets.

Research Purposes

Mastermind Cognitive Training may share de-identified or anonymized Information with third-party researchers for scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws.

4. Children’s Privacy

Mastermind Cognitive Training is committed to protecting children’s privacy and safety on the Internet. We never intentionally collect or maintain any Personal Information about anyone under the age of 13, other than as needed to enroll your child, and to obtain appropriate information to plan and assess your child’s progress in the program. We will obtain verifiable parental consent before knowingly collecting Personally Information from anyone under the age of 13.

5. Opt-Out

Notifications

If you no longer wish to receive notifications about our Programs or Services, you may click the unsubscribe button, which is in the footer of our emails. Alternatively, you may be able to indicate your preference by logging into your account and adjusting your preferences or by following the directions provided with the communication. You will not be able to log out of “transactional” emails.

SMS Messaging

When you complete a form on our website or request more information, you agree to receive SMS messages. You may opt out of receiving SMS messages by replying STOP at any time or by adjusting your settings in your account through Mastermind Cognitive Training's portal. By opting not to receive SMS messages, your enjoyment of the Program may be impacted.

Access Your Information

You can review and edit your personal information at any time by logging in to your account or by contacting us at info@mastermindsports.com.

6. California Do Not Track Disclosure

Do Not Track is a privacy preference that can be set in a web browser. At this time we do not respond to Do Not Track browser settings or signals.

7. California Shine The Light Law

Mastermind Cognitive Training does not disclose or sell personally identifiable information to third parties for direct marketing purposes. Should this practice change, we will update our Policy and provide you with appropriate notice.

8. Security

Mastermind Cognitive Training cares about the security of your Personal Information. The Information you submit is encrypted and stored with reputable third parties (vendors include but are not limited to HubSpot, Amazon Web Services, and Google) to reduce the risk of unauthorized access. While no transmission over the Internet or method of electronic data storage is 100% secure, we take reasonable precautions to prevent unauthorized access, use, or disclosure of your information. Our vendors also use appropriate administrative, technical, organizational, and physical security measures to protect our users’ and visitors’ information and data against accidental or unlawful destruction, loss, and alteration, and against unauthorized disclosure and access. They use standard industry practices to protect visitor and user information, including firewalls, SSL encryption, limiting storage of financial information to a PCI compliant third party provider, system redundancies, and co-location at a 24/7 secured, controlled environment.

9. Changes To Our Privacy Policy

From time to time it may become necessary to update or change our Privacy Policy. Mastermind Cognitive Training encourages you to periodically check here for the most current version of our Privacy Policy. If significant changes are made, Mastermind Cognitive Training will provide you with appropriate notice, which may include email notification.

10. Additional Requests And Contact Information

For questions about our privacy policy, to make choices about receiving marketing or promotional communications, or if you have a request to access, correct or delete any Personal Information, please contact info@mastermindsports.com.

Children's Privacy Policy

Mastermind Cognitive Training (“we” or “us”) is committed to protecting the privacy of children.

What Information We Collect

We require account holders to be 18 years of age or older and all users to be 13 years of age or older. If we determine that a child under 18 created a primary account, we will immediately suspend access to the account and delete any personal information associated with the child.

We only collect as much information about a child as is reasonably necessary for the child to use our services, and we do not condition the child’s participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly

We may collect the following information from children: name, age, sex, email address, and a unique username the child creates for their profile. We will also be tracking the time spent within applications and the results from training.

Automatic Information Collection

In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use our services. The information we collect through these technologies may include:

Analytics: Mastermind Cognitive Training uses third-party service providers, such as Google Analytics, which uses cookies and other similar technologies to collect and analyze information about how our website is used. You can learn more about Google Analytics at https://www.google.com/policies/privacy/partners/ and https://www.google.com/analytics/terms/us.html, and you may choose to opt-out by visiting https://tools.google.com/dlpage/gaoptout.
Cookies: We may also use cookies to collect the above information. Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all of our other cookie uses. We or our third-party service providers may use the following types of cookies:
- Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of users and to see how users move around our Websites when they are using it. This helps us improve how our Websites work by, for example, ensuring that users can easily find what they need on our Websites. These cookies generate aggregate statistics that are not associated with an individualized profile, and these stay on your computer until you delete them.
- Functionality cookies. These cookies enable helpful but non-essential Website functions that improve your Website experience. By recognizing you when you return to our Websites, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences. These cookies generate aggregate statistics that are not associated with an individualized profile, and these stay on your computer until the duration of their use.
- Advertising, tracking or targeting cookies. These cookies enable different advertising related functions. They may allow us to record information about your visit to our Websites, such as pages visited, and links followed so that we can make our Website and the advertising displayed on it more relevant to your interests.
Except for strictly necessary cookies, all first-party cookies set by this website will expire when you block or delete these cookies.

If you have questions about opting out of certain information collection, email us at support@mastermindsports.com.

How Personal Information is Used

We use the personal information we collect from you about your child, or that we collect directly from your child once you set up their account, to register the child to use our services, communicate with the child about activities of features of our services that may be of interest, track the child’s performance through use of the services, [and [describe other]].

We use the information we collect automatically through technology and other non-personal information we collect to improve our services and to deliver a better and more personalized experience by enabling us to track usage patterns for our services, store information about the child’s preferences which allows us to customize the content according to individual interests, and speed up searches.

We will use the email address to send reminders, tips, and other messaging related directly to their training program to all participants. We will distribute marketing and promotional materials via email, but those materials will only be distributed to individuals who are at least 18 years old.

The username for each child may be displayed on leaderboards within the game. No other personally identifiable information will be displayed, and other users will not be able to access any additional information through any of our systems. The username is a unique identification for gameplay purposes only created by each user, and does not require any portion of the username to contain personal information. There is no chat or interaction feature between users to ensure protection of children, and we will only send surveys to primary accounts, not to a child’s account.

Our Practices for Sharing Children’s Information

Our web services and database partners will be responsible for data storage, and both organizations have strict policies and enforcement around limiting access to personally identifiable information. They are allowed to use information we share with them only for the limited business purposes for which we have engaged them. Neither organization is allowed to distribute or sell any customer information that is stored in either system. Our web services partner is Alternova and they can be reached at 500 Beale Street, Unit 310, San Francisco, CA, 94105; +57 3122957389; or info@alternova.co.

Please direct inquiries about Alternova’s privacy practices and use of children’s information through the contact information provided above.

We also have the right to disclose a child’s personal information where we are required to do so by law or legal process, such as to comply with any court order or subpoena, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mastermind Cognitive Training and its related parties, including to protect the safety of a child, protect the security of our services, or enable us to take precautions against liability.

If we are involved in a merger, acquisition, restructuring, reorganization, dissolution, or other sale of transfer of some or all of our assets, we may transfer the personal information we have collected to the buyer or other successor.

Parent/Guardian Rights

We want to ensure parents/guardians are familiar with their rights related to their child(ren):

The company will limit collection of information to only what is necessary to measure outcomes of the program.
Parents/guardians have the right to review their child’s personal information, direct us to delete it, or request that we stop collecting any additional information.
Parents/guardians have the right to agree to the collection of information, but can request that it not be shared with third parties.

If a parent/guardian would like to communicate with the company about exercising their rights, they should send an email with their request to support@mastermindsports.com.