Privacy Policy

Welcome to www.BlueOceanBrain.com (“Website”). The Rowing Team, LLC, a Virginia limited liability company (“We” or “Us” or “Blue Ocean Brain”), owner and operator of this Website, takes reasonable measures to protect your privacy. This document outlines Blue Ocean Brain’s privacy and data protection policy (this “Privacy Policy”). Blue Ocean Brain provides web-based micro-learning training applications to employees designated by employers (“Registered User”). Such employers have contracted for such training with Blue Ocean Brain (“Services”). Your access to and use of the Services is subject to this Privacy Policy. Please read it carefully.

  1. Information We Collect.
    1. If you become a Registered User, we may collect your name, address, postal code, email address, and certain information about the computer or mobile device from which you log in or use the Services.
    2. We may also collect voluntarily provided information about Registered Users, such as demographic data, and we may use and share that as well as other data collected about our Registered Users for the purposes of product research, product performance measurement and otherwise in an effort to improve our Services.
    3. We may also collect information about the computer or mobile device from which you access the website, even if you do not become a Registered User. We may use your email address to inform Registered Users of updates to the Website or the Services, to send Registered Users information about our company and services, or to contact Registered Users when necessary.
    4. If you wish to view, erase or rectify information collected about you, you may make such a request to TRT by emailing support@blueoceanbrain.com or calling 855-462-7238. If you seek to restrict or suspend processing of information about you, you may use the same email address and/or telephone number.
  2. How We Use Your Information.
    1. We may gather information from your computer or device used to access the Website or Services, such as number of visits to the Website, the time and date of a visit, type of browser used and a user’s IP address. We collect this information solely for purposes of site administration. We use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address may also be used to gather broad demographic information.
    2. We track user activity on the site, such as last login, session failures, search queries and number of results, and other information in order, among other things, to help us manage and improve our site. We may use such information, among other things, to analyze trends, promote and market our site, products and/or services, administer the site, track user’s movements across the Internet, and gather broad demographic information and for aggregate use at our site or otherwise. We may also share such activity information with third parties, including, without limitation, our business partners, vendors, and distributors.
    3. Website Cookies. Website cookies are pieces of information stored on the website browser of your computer’s hard drive (“Cookies”). The Website uses Cookies to track registered user IDs and passwords, to provide tailored content and to distinguish unique from returning visitors. The Website does not collect Personally Identifiable Information using Cookies. You may set your computer’s website browser to refuse Cookies or to alert you before accepting them.
  3. How we share your information.
    1. Registered User. Each Registered User will have a private, individualized My Account page reflecting his or her personal information and activity on the Website for his or her records and reflection. Aggregated and/or summarized macro level data, such as general Registered User usage of the Website, and other aggregated and/or summarized data, will be shared with said Registered User’s employer who has registered for Services with Us (“Company Sponsor”), in addition to limited personal information, in Blue Ocean Brain’s sole discretion. We collect email addresses, first and last name, and as applicable other limited personal information provided by the Corporate Sponsor in order to manage the credentialing process and provide accurate reporting.
    2. It is accurate to say: We share information with Contractors acting on behalf of TRT who are under professional services agreement and are therefore bound by privacy and confidentiality provisions identical to those enacted and agreed to by TRT.
    3. Disclosure to Third Parties. Other than as set forth herein, We do not disclose, sell, give or otherwise transfer any personally identifiable information about our users or Website visitors, unless in response to a subpoena, search warrant, court order, official government or regulatory investigation or other legal processes where TRT is required to do so by law.
  4. Public Message Board. Any and all information made available by you on any and all public message boards or other public online forums, i.e. the Gallery, will be publicly displayed. The Website allows posting of comments that may be viewable by other Registered Users. Any information that you choose to disclose by means of such features becomes public information over which We are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

  5. The Website may contain links to third party websites, which have separate and independent terms of use and privacy policies. Third party websites are not under our control, and We, therefore, are not responsible for any information collected thereon or any terms of use and privacy policies in connection therewith. Access these sites at your own risk.

  6. Services accessible to our Registered Users include reasonable security measures intended to protect against unauthorized acquisition of personally identifiable information under our control. No data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, we cannot ensure or warrant the security of any information you transmit to us or from our online services, and you do so at your own risk.

  7. Opt-Out. If you do not wish to receive information and promotional material from us, you may use our “Unsubscribe” feature on any email you receive from us.

  8. Notwithstanding the foregoing, We may transfer, sell or assign information concerning your use of this Website, including without limitation, personally identifiable information, to third parties, as a result of the sale, merger, consolidation, and change in control, transfer of substantial assets, reorganization or liquidation of TRT and/or the Website. In the event of such transfer, sale or assignment, notice will be given in accordance with Section 17 below.

  9. The Rowing Team, LLC complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. The Rowing Team, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. The Rowing Team, LLC commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources and non human resources data transferred from the EU and Switzerland in the context of the employment relationship.
  10. Privacy Shield Recourse, Enforcement & Liability. In compliance with the Privacy Shield Principles, The Rowing Team, LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact The Rowing Team, LLC at: support@blueoceanbrain.com or by calling 855-462-7238.
  11. The Rowing Team, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent recourse mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus (“BBB”), which is based in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This service is provided free of charge. If your compliant cannot be resolved through the above channels, under certain conditions, Data Subjects may invoke binding arbitration for some residual claims not otherwise resolved by other redress mechanisms. For more information about binding arbitration, visit https://www.privacyshield.gov. The Federal Trade Commission has jurisdiction over The Rowing Team’s compliance with the Privacy Shield.
  12. Access. Data Subjects whose Personal Data is covered by this Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: support@blueoceanbrain.com.
  13. Choice. If Personal Data covered by this Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, The Rowing Team, LLC will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: support@blueoceanbrain.com. If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, The Rowing Team, LLC will obtain the Data Subject’s explicit consent prior to such use or disclosure.
  14. Accountability for Onward Transfer.  The Rowing Team, LLC will not disclose Personal Data to a third party, except as stated below:

    The Rowing Team, LLC may disclose Personal Data to subcontractors and third-party agents who assist The Rowing Team, LLC in providing Services to its customers and prospective customers. Before disclosing Personal Data to a subcontractor or third-party agent, The Rowing Team, LLC will obtain assurances from the recipient that it will: (a) use the Personal Data only to assist The Rowing Team, LLC in providing the Services; (b) provide at least the same level of protection for Personal Data as required by the Principles; and (c) notify The Rowing Team, LLC if the recipient is no longer able to provide the required protections. Upon notice, The Rowing Team, LLC will act promptly to stop and remediate unauthorized processing of Personal Date by a recipient. The Rowing Team, LLC will remain liable for onward transfers to its subcontractors and third-party agents.

    The Rowing Team, LLC may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. To the extent permitted, The Rowing Team, LLC will inform its relevant customer or prospective customer before making such disclosure and provide it with a reasonable opportunity to object to such disclosure.

  15. Children’s Policy. TRT does not target the Website to children under the age of thirteen (13) nor does it knowingly collect information from children under the age of thirteen (13). Thus, TRT requests that individuals under the age of thirteen (13) do not provide TRT with any information via the Website or any other form of communication. TRT remains committed to protecting the privacy of children and therefore encourages parents and guardians to utilize any and all parental tools available to monitor children’s online activities.

  16. California Residents. California residents who provide personal information to TRT have a right to request, once per calendar year, information about TRT’s disclosure of personal information to third parties pursuant to California law. If requested, TRT will provide a list of the personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of the third parties. All such requests must be submitted to TRT via email at support@blueoceanbrain.com or by calling 855-462-7238. TRT reserves its right not to respond to requests submitted to addresses and phone numbers other than those specified in this paragraph.

  17. Modification of Privacy Policy. We may modify, delete or otherwise alter this Privacy Policy in our sole discretion at any time. In the event of such a modification, TRT may send you an email introducing the new Privacy Policy and making it available to you. Such modifications shall be effective immediately upon being posted. You are responsible for regularly reviewing this Privacy Policy. Continued use of the Website thereafter shall constitute your consent to any modifications hereto.

  18. Contacting Us. If you have any questions or concerns regarding this Privacy Policy or the Website, please email us at, info@BlueOceanBrain.com, or write to us at: 4435 Waterfront Drive, Suite 300, Glen Allen, VA 23060.