Policy summary
Personal Data processed for the following purposes and using the following services:
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Access to third-party accounts
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Advertising
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Google Ad Manager
Personal Data: Tracker; Usage Data
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Clever Advertising, AdClear, Unity Ads, AdUnity, AppLovin, Vungle, InMobi, Facebook Lookalike Audience, AdColony, ironSource, Yandex, Mintegral, Pangle, Tapjoy and Meta ads conversion tracking (Meta pixel)
Personal Data: Trackers; Usage Data
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AdMob
Personal Data: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
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Beta Testing
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Beta by Crashlytics
Personal Data: app information; country; device information; device logs; email address; first name; Tracker; Usage Data; username
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TestFlight
Personal Data: app information; country; Data communicated while using the service; device information; device logs; email address; first name; last name; Tracker; Usage Data; username
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Content performance and features testing (A/B testing)
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Displaying content from external platforms
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Hosting and backend infrastructure
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Infrastructure monitoring
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Crashlytics
Personal Data: crash data; device information; Universally unique identifier (UUID)
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Bugsnag
Personal Data: app information; device information; email address; geographic position; screenshots; Tracker; Usage Data; username
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Firebase Performance Monitoring
Personal Data: various types of Data as specified in the privacy policy of the service
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Interaction with external social networks and platforms
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Managing landing and invitation pages
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Registration and authentication
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Registration and authentication provided directly by Brainy: Mind & Brain Training
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Remarketing and behavioural targeting
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Further information about the processing of Personal Data
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Frrepick
https://www.freepik.com
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Push notifications based on the User's geographic location
Brainy: Mind & Brain Training may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Brainy: Mind & Brain Training.
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Push notifications
Brainy: Mind & Brain Training may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Brainy: Mind & Brain Training, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Brainy: Mind & Brain Training.
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Owner and Data Controller
GRANGRAN LTD - Bulgaria, Sofia, Knyaz Boris I street, house 148, 1 floor
Owner contact email: hello@haby.academy
Full policy
Owner and Data Controller
GRANGRAN LTD - Bulgaria, Sofia, Knyaz Boris I street, house 148, 1 floor
Owner contact email: hello@haby.academy
Types of Data collected
Among the types of Personal Data that Brainy: Mind & Brain Training collects, by itself or through third parties, there are:
Tracker; Usage Data; app information; device information; device logs; email address; username; country; first name; Data communicated while using the service; last name; gender; city; Universally unique identifier (UUID); crash data; screenshots; geographic position; profile picture; User ID; various types of Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Application opens.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Brainy: Mind & Brain Training.
Unless specified otherwise, all Data requested by Brainy: Mind & Brain Training is mandatory and failure to provide this Data may make it impossible for Brainy: Mind & Brain Training to provide its services. In cases where Brainy: Mind & Brain Training specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Brainy: Mind & Brain Training or by the owners of third-party services used by Brainy: Mind & Brain Training serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Brainy: Mind & Brain Training.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Brainy: Mind & Brain Training (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Access to third-party accounts, Analytics, Interaction with external social networks and platforms, Advertising, Beta Testing, Commercial affiliation, Contacting the User, Content commenting, Content performance and features testing (A/B testing), Displaying content from external platforms, Infrastructure monitoring, Hosting and backend infrastructure, Registration and authentication, Managing landing and invitation pages, Information collection, Registration and authentication provided directly by Brainy: Mind & Brain Training, Remarketing and behavioural targeting and Handling payments.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by Brainy: Mind & Brain Training
Brainy: Mind & Brain Training may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Brainy: Mind & Brain Training to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Access private data, Basic information and Email.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows Brainy: Mind & Brain Training to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorisation by the User.
Facebook account access (Facebook, Inc.)
This service allows Brainy: Mind & Brain Training to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Access private data; Email.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
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Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Brainy: Mind & Brain Training, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside Brainy: Mind & Brain Training. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Google Ad Manager (Google LLC)
Google Ad Manager is an advertising service provided by Google LLC that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Brainy: Mind & Brain Training and User behaviour concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Clever Advertising (Clever Advertising, Lda.)
Clever Advertising is an advertising service provided by Clever Advertising, Lda.
Personal Data processed: Trackers; Usage Data.
Place of processing: Portugal – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AdClear (AdClear GmbH)
AdClear is an advertising service provided by AdClear GmbH.
Personal Data processed: Trackers; Usage Data.
Place of processing: Germany – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Unity Ads (Unity Technologies ApS)
Unity Ads is an advertising service provided by Unity Technologies ApS.
Personal Data processed: Trackers; Usage Data.
Place of processing: Denmark – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AdUnity (AdUnity Ltd)
AdUnity is an advertising service provided by AdUnity Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AdMob (Google LLC)
AdMob is an advertising service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AppLovin (AppLovin Corporation)
AppLovin is an advertising service provided by AppLovin Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Vungle (Vungle, Inc.)
Vungle is an advertising service provided by Vungle, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
InMobi (InMobi Pte Ltd)
InMobi is an advertising service provided by InMobi Pte Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: India – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Lookalike Audience
Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of Brainy: Mind & Brain Training or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
AdColony (AdColony, Inc.)
AdColony is an advertising service provided by AdColony, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
ironSource (ironSource Ltd.)
ironSource is an advertising service provided by ironSource Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: Israel – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Yandex (YANDEX, LLC)
Yandex is an advertising service provided by YANDEX, LLC.
Personal Data processed: Trackers; Usage Data.
Place of processing: Russian Federation – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Mintegral (Mintegral international limited)
Mintegral is an advertising service provided by Mintegral international limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: China – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Pangle (BYTEDANCE PTE. LTD.)
Pangle is an advertising service provided by BYTEDANCE PTE. LTD.
Personal Data processed: Trackers; Usage Data.
Place of processing: Singapore – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Tapjoy (Tapjoy, Inc.)
Tapjoy is an advertising service provided by Tapjoy, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Meta ads conversion tracking (Meta pixel)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta Audience Network with actions performed on Brainy: Mind & Brain Training. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilises the Data collected to track and examine the use of Brainy: Mind & Brain Training, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
MixPanel (MixPanel)
MixPanel is an analytics service provided by Mixpanel Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
Appsflyer (AppsFlyer Ltd)
Appsflyer is an analytics service provided by AppsFlyer Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: Israel – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
https://adapty.io
A tool used for marketing and product development.
This processing constitutes:
Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Brainy: Mind & Brain Training.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Beta Testing
This type of service makes it possible to manage User access to Brainy: Mind & Brain Training, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of Brainy: Mind & Brain Training in a personally identifiable form.
Beta by Crashlytics (Google LLC)
Beta by Crashlytics is a beta testing service provided by Google LLC.
Personal Data processed: app information; country; device information; device logs; email address; first name; Tracker; Usage Data; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: app information; country; Data communicated while using the service; device information; device logs; email address; first name; last name; Tracker; Usage Data; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
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Commercial affiliation
This type of service allows Brainy: Mind & Brain Training to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Brainy: Mind & Brain Training.
For details of which data are collected, please refer to the privacy policy of each service.
Effiliation (Effiliation SAS)
Effiliation is a commercial affiliation service provided by Effiliation SAS.
Personal Data processed: Tracker; Usage Data.
Place of processing: France – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Contacting the User
Mailing list or newsletter (Brainy: Mind & Brain Training)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Brainy: Mind & Brain Training. Your email address might also be added to this list as a result of signing up to Brainy: Mind & Brain Training or after making a purchase.
Personal Data processed: city; country; email address; first name; gender; last name.
Category of Personal Information collected according to CCPA: identifiers; biometric information.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Brainy: Mind & Brain Training.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of Brainy: Mind & Brain Training.
Firebase Remote Config (Google LLC)
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Brainy: Mind & Brain Training and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google LLC)
Google Fonts is a typeface visualisation service provided by Google LLC that allows Brainy: Mind & Brain Training to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Google Site Search with AdSense (Google LLC)
Google Site Search is a search engine embedding service provided by Google LLC that allows Brainy: Mind & Brain Training to incorporate content of this kind on its pages.
Google Site Search may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Instagram widget (Facebook, Inc.)
Instagram is an image visualisation service provided by Facebook, Inc. that allows Brainy: Mind & Brain Training to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Handling payments
Unless otherwise specified, Brainy: Mind & Brain Training processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Brainy: Mind & Brain Training isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
RevenueCat (RevenueCat, Inc.)
RevenueCat is a payment service provided by RevenueCat, Inc. The service allows the Owner to monitor and analyse the User and their purchase history and can be used to keep track of User behaviour.
Personal Data processed: Application opens; device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; User ID.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: identifiers; internet information.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Brainy: Mind & Brain Training to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Brainy: Mind & Brain Training.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
DigitalOcean (DigitalOcean Inc.)
DigitalOcean is a hosting service provided by DigitalOcean Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Information collection
api.habyapp.com
This app is uploading users information to https://api.habyapp.com
This processing constitutes:
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Infrastructure monitoring
This type of service allows Brainy: Mind & Brain Training to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Brainy: Mind & Brain Training.
Crashlytics (Google LLC)
Crashlytics is a monitoring service provided by Google LLC.
Personal Data processed: crash data; device information; Universally unique identifier (UUID).
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
Bugsnag (Bugsnag Inc.)
Bugsnag is a monitoring service provided by Bugsnag Inc.
Personal Data processed: app information; device information; email address; geographic position; screenshots; Tracker; Usage Data; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information; geolocation data.
This processing constitutes:
Firebase Performance Monitoring (Google LLC)
Firebase Performance Monitoring is a monitoring service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Brainy: Mind & Brain Training.
The interaction and information obtained through Brainy: Mind & Brain Training are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Brainy: Mind & Brain Training isn’t being connected back to the User’s profile.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Instapage (Instapage, Inc.)
Instapage is a landing page management service provided by Instapage, Inc., that allows Brainy: Mind & Brain Training to collect the email addresses of Users interested in its service.
Instapage allows the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of the created landing pages.
Personal Data processed: email address; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
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Registration and authentication
By registering or authenticating, Users allow Brainy: Mind & Brain Training to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Brainy: Mind & Brain Training will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Instagram Authentication (Facebook, Inc.)
Instagram Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Instagram social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Facebook Authentication
Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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Registration and authentication provided directly by Brainy: Mind & Brain Training
By registering or authenticating, Users allow Brainy: Mind & Brain Training to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Brainy: Mind & Brain Training)
The User registers by filling out the registration form and providing the Personal Data directly to Brainy: Mind & Brain Training.
Personal Data processed: email address; first name; last name; profile picture; Usage Data; User ID; various types of Data.
Category of Personal Information collected according to CCPA: identifiers; internet information; sensorial information.
This processing constitutes:
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Remarketing and behavioural targeting
This type of service allows Brainy: Mind & Brain Training and its partners to inform, optimise and serve advertising based on past use of Brainy: Mind & Brain Training by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Brainy: Mind & Brain Training with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Further information about the processing of Personal Data
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Frrepick
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Push notifications based on the User's geographic location
Brainy: Mind & Brain Training may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Brainy: Mind & Brain Training.
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Push notifications
Brainy: Mind & Brain Training may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Brainy: Mind & Brain Training, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Brainy: Mind & Brain Training.
Cookie Policy
Brainy: Mind & Brain Training uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running Brainy: Mind & Brain Training and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymised personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorised by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Brainy: Mind & Brain Training and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Identifiers
Personal Information collected or disclosed:
Email, Access private data, Tracker, app information, device information, device logs, email address, Usage Data, country, first name, Data communicated while using the service, last name, gender, city, Universally unique identifier (UUID), crash data, screenshots, geographic position, profile picture, User ID, various types of Data, Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Application opens
Sensitive Personal Information collected or disclosed ℹ️:
username
Purposes:
- Access to third-party accounts
- Beta Testing
- Contacting the User
- Infrastructure monitoring
- Managing landing and invitation pages
- Registration and authentication provided directly by Brainy: Mind & Brain Training
- Advertising
- Remarketing and behavioural targeting
- Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Facebook, Inc., Google LLC, Apple Inc., Bugsnag Inc., Instapage, Inc., Meta Platforms, Inc., RevenueCat, Inc.
Service providers or contractors: Brainy: Mind & Brain Training
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Email, Access private data, Tracker, Usage Data, app information, device information, device logs, email address, country, first name, Data communicated while using the service, last name, various types of Data as specified in the privacy policy of the service, Universally unique identifier (UUID), crash data, screenshots, geographic position, profile picture, User ID, various types of Data, Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Application opens
Sensitive Personal Information collected or disclosed ℹ️:
username
Purposes:
- Access to third-party accounts
- Analytics
- Interaction with external social networks and platforms
- Advertising
- Beta Testing
- Commercial affiliation
- Content commenting
- Content performance and features testing (A/B testing)
- Displaying content from external platforms
- Infrastructure monitoring
- Hosting and backend infrastructure
- Registration and authentication
- Managing landing and invitation pages
- Further information about Personal Data
- Registration and authentication provided directly by Brainy: Mind & Brain Training
- Remarketing and behavioural targeting
- Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Facebook, Inc., Google LLC, X Corp., Apple Inc., Effiliation SAS, Bugsnag Inc., DigitalOcean Inc., Instapage, Inc., MixPanel, AppsFlyer Ltd, Clever Advertising, Lda., AdClear GmbH, Unity Technologies ApS, AdUnity Ltd, AppLovin Corporation, Vungle, Inc., InMobi Pte Ltd, Meta Platforms, Inc., AdColony, Inc., ironSource Ltd., YANDEX, LLC, Mintegral international limited, BYTEDANCE PTE. LTD., Tapjoy, Inc., Meta Platforms Ireland Limited, RevenueCat, Inc.
Service providers or contractors: Brainy: Mind & Brain Training
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Biometric information
Personal Information collected or disclosed:
email address, first name, last name, country, gender, city
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: Brainy: Mind & Brain Training
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Geolocation data
Personal Information collected or disclosed:
Tracker, Usage Data, email address, device information, screenshots, geographic position, app information
Sensitive Personal Information collected or disclosed ℹ️:
username
Purposes:
- Infrastructure monitoring
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Bugsnag Inc.
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Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
Usage Data, first name, last name, email address, profile picture, User ID, various types of Data
Purposes:
- Registration and authentication provided directly by Brainy: Mind & Brain Training
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: Brainy: Mind & Brain Training
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Brainy: Mind & Brain Training.
For example, you directly provide your Personal Information when you submit requests via any forms on Brainy: Mind & Brain Training. You also provide Personal Information indirectly when you navigate Brainy: Mind & Brain Training, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Brainy: Mind & Brain Training and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Brainy: Mind & Brain Training.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Brainy: Mind & Brain Training or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Brainy: Mind & Brain Training may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Brainy: Mind & Brain Training and any third-party services may collect files that record interaction with Brainy: Mind & Brain Training (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Brainy: Mind & Brain Training and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through Brainy: Mind & Brain Training (or third-party services employed in Brainy: Mind & Brain Training), which can include: the IP addresses or domain names of the computers utilised by the Users who use Brainy: Mind & Brain Training, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Brainy: Mind & Brain Training who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Brainy: Mind & Brain Training. The Data Controller, unless otherwise specified, is the Owner of Brainy: Mind & Brain Training.
Brainy: Mind & Brain Training (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Brainy: Mind & Brain Training as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Brainy: Mind & Brain Training, if not stated otherwise within this document.