Privacy Policy for Online Services

This Privacy Policy for Cerebrum Online Services (the “Privacy Policy”) forms a portion of Cerebrum’s Personal Data Privacy Policy (1.20) and may change from time to time. In certain countries and depending on applicable law, significant changes, e.g. those affecting the scope of the Personal Data we process about you, may be specifically brought to your attention. We may do this by posting a notice of such changes on a page of the Cerebrum web or social media site or app (“Cerebrum Online Services”) prior to implementing the change, or by providing you with notice in other ways, such as by email. If we require additional consents from you for the processing of your Personal Data, we will request such consents.

Personal Data and Non-personal information

Personal Data is information that identifies you as an individual or from which you can be identified.

Non-personal information is information that does not reveal your specific identity either directly or through reference to other information. We may collect, use and disclose non-personal information for any lawful purpose. In addition, see Data anonymization and aggregation below.

What Personal Information may be collected

The following Personal Data may be collected from you through the Cerebrum Online Services:

  • your name, job title and contact information (including business email address, business address, business telephone number, your employer company and your country) should you choose to provide such details;

  • details of products and/or services of particular interest to you based on how you use the Cerebrum Online Services and your preferences (see Tailored Marketing Emails in the Terms of Use);

  • records of any correspondence we have with you, including records of “Live Chat” sessions (see Live Chat in the Terms of Use);

  • your details as relevant to your employer company’s method of payment for our products or services, such as your name as it appears on your corporate credit card (see Ordering below) should you choose to provide such details; and

  • data regarding the use, condition, performance and/or functionality of a system or machine (“Usage Information”) when and where using Cerebrum Online Services associated with the monitoring or functionality of that system or machine (i.e., Internet of Things type services (“IoT Applications”)). Usage Information may include an identifier of the product, system or machine being used in addition to other relevant information.

Do not provide personal contact or payment details or any Personal Data which relates to you in your personal or private capacity. Cerebrum wishes to collect only your business contact details and, when you purchase products and/or services using the Cerebrum Online Services, payment details which relate to your employer company’s payment facilities.

Disclosure and Use of Personal Information

In order to serve you better, Personal Data that you provide while using, or which is obtained from your use of, the Cerebrum Online Services may be used, held or shared by Cerebrum and its distributors, agents, consultants, advisors or other business partners in order to facilitate delivery of products, services, and/or the Cerebrum Online Services to you. In addition, Cerebrum and its distributors, agents or contractors may use your Personal Data for the following purposes:

  • to notify you of changes to the Privacy Policy, Terms of Use or associated information regarding Cookies which affect the scope of the Personal Data we process about you;

  • to provide you with services;

  • to tailor direct marketing by email of information relating to products and/or services of particular interest

to you in your business capacity (see Tailored Marketing Emails in the Terms of Use);

  • to respond to any specific request or enquiry you make, including through live web-based chats (see Live Chat in the Terms of Use) and through the “General Inquiries Form” on the “Contact Us” pages of our pages, sites or apps;

  • where necessary, as part of any restructuring of Cerebrum and their business or assets, or as part of a sale of a portion of Cerebrum or its assets; and

  • to provide Usage Information or to provide third party manufacturers, integrators or sellers’ of products, systems or machines with associated Usage Information in IoT Applications.

In addition, your Personal Data may be shared with providers of legal and other professional services and with vendors and subcontractors retained to perform functions on behalf of Cerebrum, such as vendors of email marketing services; vendors operating the “Live Chat” facility, and vendors of data storage and back up facilities, among others.

Your Personal Data may also be disclosed:

  • as necessary to comply with applicable laws;

  • in response to a court order, or a request for cooperation from a law enforcement or other government agency;

  • to establish or exercise legal rights and/or to defend legal claims;

  • to identify or bring legal action against someone who may be violating our conditions of use and terms of service;

  • to enforce or apply the terms of any of our user agreements;

  • to protect the rights, property or safety of Cerebrum, and its distributors, agents, consultants, advisors, customers, staff, suppliers or others;

  • as necessary for responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations;

  • when disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing;

  • to credit card providers if relevant to your chosen method of payment for our products or services(see

Ordering below); and/or

Neither Cerebrum nor its distributors, agents, consultants, advisors or other business partners will sell, trade or rent to others your Personal Data obtained via the Cerebrum Online Services (except in the sale and/or restructuring of all or part of Cerebrum, as mentioned above).

Transfers of Personal Data outside local countries

Cerebrum is part of a global group of companies headquartered in the United States of America and, the Cerebrum Online Services have users all over the world. Subject to applicable law, any information you supply or which is collected through your use of the Cerebrum Online Services may be transmitted outside of your own country and may be used, stored and processed outside of the country where it was entered. This may include transfers to particular members of Cerebrum; to agents, distributors and/or other persons in their supply chain; and to vendors and contractors retained to perform functions on behalf of Cerebrum. In particular, European Union and Swiss based users should note that their Personal Data will be transferred to countries or territories outside the European Economic Area. Cerebrum seeks to ensure the protection applied to your Personal Data as processed in those other countries or territories is adequate in accordance with applicable law. For transfers to the United States, Cerebrum subscribes to the Privacy Shield Framework, which has been determined to provide adequate protections for the transfer of Personal Data of European Union and Swiss residents.


IF YOU CHOOSE TO USE THE CEREBRUM ONLINE SERVICES, WE WILL COLLECT PERSONAL DATA ABOUT YOU, AS DESCRIBED BELOW. In certain countries, you may be required to provide your express consent to this Privacy Policy and its associated Terms of Use, and information regarding Cookies before being able to use the Cerebrum Online Services.


YOU FURTHER CONSENT TO YOUR PERSONAL DATA BEING TRANSFERRED BY CEREBRUM OUTSIDE YOUR OWN COUNTRY (INCLUDING OUTSIDE THE EUROPEAN ECONOMIC AREA). Please do not use the Cerebrum Online Services, or provide your Personal Data through any of the Cerebrum Online Services, unless you consent the transfer of your Personal Data by Cerebrum outside your own country (including outside the European Economic Area). This is explained in more detail in this Privacy Policy, in particular see Transfers of Personal Data outside of local countries below.

Your attention is specifically drawn to data transfers which happen when you use the “Live Chat” feature on Cerebrum pages, sites or apps such as www.cerebrumllc.com. Please do not choose to use “Live Chat” unless you consent to your Personal Data being transferred outside your own country (including outside the European Economic Area, as relevant) to:

  • Cerebrum and its distributors, agents, consultants, advisors or other business partners in order for them to respond to your enquiries, and

  • the third party vendor operating “Live Chat”.

In certain countries and depending on applicable law, you may be asked to tick a box or make other affirmative indications that you accept this Privacy Policy and its accompanying Terms of Use and information regarding Cookies and that you provide your consent as set out in these documents.

Please note that there may be justifications other than consent on which Cerebrum will rely for the collection, use and/or transfer of your Personal Data.


Certain Cerebrum Online Services may allow you to place orders for Cerebrum products or services. When you place an order using a Cerebrum Service, the credit card or payment information that you submit will be transmitted in a secured format using secure server software (SSL) which encrypts this information. Of course, your credit card information will be submitted to the credit card institution for processing.

Data anonymization and aggregation

Cerebrum may use certain information gathered from the Cerebrum Online Services to compile anonymized aggregated demographic data about their users, sales, traffic patterns, and related site information, such as which pages of a website are used most frequently (see also IP Addresses in the Terms of Use). Cerebrum may use that information to help develop, deliver, and improve their products, services, content, and advertising. If provided to third parties, this data will include no Personal Data. The anonymized aggregated demographic data may also be used for statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs and charges in relation to products and services of Cerebrum.

We may use Cookies to create user profiles under pseudonyms for marketing and market research purposes and to adjust our pages, sites or apps to our users’ needs. Unless you have consented by becoming a registered user, the usage profiles will not be merged with Personal Data about the holder of the pseudonym and, the information will not be used to identify the user of our pages, sites and apps. See Cerebrum’s document on Cookies for more information regarding the management of your cookies.

Location-Based Services

Some of the Cerebrum Online Services include location-based services that require your Personal Data for the feature to function. To provide location-based services, Cerebrum may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Unless you have consented by becoming a registered user, the location data is collected anonymously in a form that does not personally identify you and is used by Cerebrum to provide and improve location-based products and services. For example, Cerebrum may share geographic location with application providers when you opt in to their location services.

Links to Third Party Sites

The Cerebrum Online Services may include links to pages, sites or apps operated by third parties (“Linked Sites”). The Linked Sites may not be under the control of Cerebrum and, Cerebrum is not responsible for the content of any Linked Site or of other links located in a Linked Site. Cerebrum provides links to the Linked Sites for convenience only and, the inclusion in the Cerebrum Online Services of any such links does not imply an endorsement by Cerebrum of the Linked Sites. Please note that the Linked Sites will have different policies than those of Cerebrum and, Cerebrum is not responsible for the privacy practices of such other site operators. When visiting a Linked Site, you should read the privacy policy of such site carefully before use.