Privacy Policy


This is the privacy policy (“Privacy Policy”) that governs how we, Brodmann17 Ltd (“Brodmann17”,
“we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about
individuals in connection with the use of: (i) the website and the Brodmann17
and any other website that we operate (each, together with its sub-domains, content and services, a

1. Introduction. We have implemented this Privacy Policy because your privacy, and the privacy of other
users, is important to us. This Privacy Policy explains our online information practices and the choices
you can make about the way your Personal Information is collected and used in connection with the
Services. “Personal Information” means any information that may be used, either alone or in
combination with other information, to personally identify an individual, including, but not limited to, a
first and last name, a personal profile, an email address, a home or other physical address, or other contact

2. Terms of Use. This Privacy Policy forms part of our Terms of Use (“Terms”).

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

3. Physical Security. We do not ourselves host any of the services- all hosting is done by third party service
providers that we engage. Regardless of where our third-party service providers are located, their servers
may be located anywhere in the world. Where we transfer your Personal Information outside of EU/EEA
(for example to third parties who provide us with services), we will generally obtain contractual
commitments from them to protect your Personal Information.

4. Consent and Modification. You are not legally obligated to provide us Personal Information, and you
hereby confirm that providing us Personal Information is at your own free will. By using the Services, you
consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal
Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not
access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy
at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on
the Site, and your continued use of the Services thereafter means that you accept those changes.

5. What Personal Information We Collect and How We Collect It. We do not currently require you to
provide Personal Information in order to have access to general information available on the Site. But, we
do receive and/or collect Personal Information from you in the following ways:
5.1. ‘Contact Us’ Information. If you send us a “Contact Us” request, whether by submitting an online form
that we make available or by sending an email to an email address that we display, you may be required
to provide us with certain information such as your name and email address.
5.2. Log Files. We may make use of log files. The information inside the log files includes internet protocol
(IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages,
clicked pages and any other information your browser may send to us. We may use such information to
analyze trends, administer the Services, track users’ movement around the Services, and gather
demographic information.
5.3. Cookies and Other Tracking Technologies. Our Services may utilize “cookies”, anonymous identifiers
and other tracking technologies in order to for us to provide our Services and present you with
information that is customized for you. A “cookie” is a small text file that may be used, for example, to
collect information about activity on the Services. Certain cookies and other technologies may serve to
recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow
you to control cookies, including whether to accept them and how to remove them. You may set most
browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
5.4. Google Analytics. The Site may use a tool called “Google Analytics” to collect information about use of
the Site. Google Analytics collects information such as how often users visit this site, what pages they
visit when they do so, and what other sites they used prior to coming to this Site. We use the information
we get from Google Analytics to maintain and improve the Site and our products. We do not combine the
information collected using Google Analytics with personally identifiable information. Google’s ability to
use and share information collected by Google Analytics about your visits to this Site is restricted by the
Google Analytics Terms of Service, available at, and
the Google Privacy Policy, available at You may learn more

about how Google collects and processes data specifically in connection with Google Analytics at You may prevent your data from being used by
Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on,
available at

6. The Way We Use Personal Information. If you submit or we collect Personal Information through the
Site, then we may use such Personal Information in the following ways, via any applicable
communication channel, including e-mail, SMS, etc.:
6.1. We will use your Personal Information to provide and improve our Services, to send you
marketing/advertisement communications that we believe may be of interest to you, to contact you in
connection with the Services and certain programs or offerings that you may have registered for, and to
identify and authenticate your access to the parts of the Services that you are authorized to access.
6.2. We may use your designated email address to: (i) send you updates or news regarding the Services and
our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your
6.3. We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for
the purpose of storing or processing such information on our behalf. Such information may be transferred
to other countries. We require that these parties agree to process such information in compliance with our
Privacy Policy.
6.4. We may share your Personal Information with our third-party service providers and partners, but only to
assist us with our business operations and to provide our Services to you and other users. Such
information may be transferred to other countries. We use commercially reasonable efforts to only engage
or interact with third party service providers and partners that post a privacy policy governing their
processing of Personal Information.
6.5. We may disclose your Personal Information or any information you submitted via the Services if we have
a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply
with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms,
including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or
security issues; or (iv) protect against harm to the rights, property or safety of Brodmann17, our users,
yourself or the public.

7. Use of Anonymous Information. We may use Anonymous Information (as defined below) or disclose it
to third party service providers to improve our Services and enhance your experience with the Services.
We may also disclose Anonymous Information (with or without compensation) to third parties, including
advertisers and partners. “Anonymous Information” means information which does not enable
identification of an individual user, such as aggregated information about the use of our Services.

8. Opting Out. You may choose not to receive future promotional, advertising, or other Services-related
emails from us by selecting an unsubscribe link at the bottom of each email that we send or by sending us
an email. Please note that even if you opt out of receiving the foregoing emails, we may still send you a
response to any “Contact Us” request as well as administrative emails (for example, in connection with a
password reset request) that are necessary to facilitate your use of the Services.

9. Choice. At all times, you may choose whether or not to provide or disclose Personal Information. If you
choose not to provide mandatory Personal Information, you may still visit parts of the Services but you
may be unable to access certain options, programs, offers, and services that involve our interaction with

10. Aggregated information. We may use the information we collect to compile aggregated, anonymized, or
de-identified information. We may share such anonymized or de-identified information with any other
third party, at our sole discretion.

11. Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain
accurate Personal Information. If you would like to delete or correct any of your other Personal
Information that we may be storing, you may use the tools that we make available on the Services or you
may submit an access request by sending an email to Your email should
include adequate details of your request.

12. Links to and Interaction with Third Party Products. The Services may enable you to interact with or
contain links to your Third-Party Account and other third-party websites, mobile software applications
and services that are not owned or controlled by us (each a “Third Party Service”).

We are not responsible for the privacy practices or the content of such Third-Party Services.

Please be aware that Third Party Services may collect Personal Information from you.

Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third-Party

Service that you choose to use or interact

13. Children’s Privacy. The Services are not structured to attract children under the age of 13 years.
Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13
years. If we learn that we have collected Personal Information from a child under 13 years, we will delete
that information as quickly as possible. If you believe that we might have any such information, please
contact us at

14. Security. The security of Personal Information is important to us. We follow generally accepted industry
standards, including the use of appropriate administrative, physical and technical safeguards, to protect
the Personal Information submitted to us. However, no method of transmission over the Internet, or
method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable
means to protect your Personal Information, we cannot guarantee its absolute security or confidentiality.
If you have any questions about security on the Service or you find any bug or security issue on our
platform or website, please let us know about it by sending an immediate email to

15. Merger, Sale or Bankruptcy. In the event that we are acquired by or merged with a third-party entity, or
in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal
Information in connection with the foregoing events.

16. California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are
California residents to request certain information regarding our disclosure of Personal Information to
third parties for their direct marketing purposes. To make such a request, please send an email to . Please note that we are only required to respond to one request per customer
each year.

17. Our California Do Not Track Notice.
We do not track consumers over time and across third party websites and therefore do not respond to Do
Not Track signals. We do not allow third parties to collect personally identifiable information about an
individual consumer’s online activities over time and across different web sites when a consumer uses the

18. Deletion of Content from California Residents. If you are a California resident under the age of 18 and
a registered user, California Business and Professions Code Section 22581 permits you to remove content
or Personal Information you have publicly posted. If you wish to remove such content or Personal
Information and you specify which content or Personal Information you wish to be removed, we will do
so in accordance with applicable law. Please be aware that after removal you will not be able to restore
removed content. In addition, such removal does not ensure complete or comprehensive removal of the
content or Personal Information you have posted and that there may be circumstances in which the law
does not require us to enable removal of content.

19. Commitment. We are committed to protecting your privacy. Protecting your privacy online is an
evolving area, and we are constantly evolving our Service to meet these demands. If you have any
comments or questions regarding our Privacy Policy, or your Personal Information that we may be storing
and using, please contact us at

20. Updates or amendments to the Privacy Policy. We may revise this Privacy Policy from time to time, in
our sole discretion, and the most current version will always be posted on our website (as reflected in the
“Last Revised” heading).

21. Contact Us. If Users have any general questions about the Services or the information that we collect
about them and how we may use it, they may contact us at

Last revised: December 2021