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BRAINBIT INC. PRIVACY POLICY

Effective date: December 19th, 2022 

It is a pleasure to see that you are using our products. Protecting your privacy and personal data while using BrainBit Inc.'s applications and our other products is very important to us. Therefore, we adhere strictly to the rules of data protection laws. We collect personal data only insofar as necessary for the use of our services. The following explanations help you understand how we ensure this protection and which data is collected and for what purpose. 

TYPES OF DATA COLLECTED 

Among the types of Personal Data that BrainBit Inc. collects, by itself or through third-parties, there are: General Activity Data, Movement Activity, Cookies and Usage Data. Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using BrainBit Inc. Any use of Cookies - or of other tracking tools - by BrainBit Inc. or by the owners of third-party services used by BrainBit Inc., unless stated otherwise, serves to identify Users, and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for BrainBit Inc. to provide its services. 

USE OF BRAINBIT INC. AND SHARING PERSONAL DATA 

We also collect information that you do not actively provide us with. We store data in an anonymous form that include the behavior of users when using our app. These include operating life, device and functions used. These analyses are available to us in anonymous form without reference to a specific user and only serve statistical purposes. A transfer of your data beyond the cases mentioned above will not take place. Also, we will not use your data for advertising purposes or let them be used by third-parties. Your personal information is not used by BrainBit Inc. for marketing and advertising or transferred to third-parties. 

MOTION AND HEALTHKIT DATA 

BrainBit Inc. accesses data from the Hardware Sensor “Callibri” in a read-only manner once you explicitly allow it (using the system-level OS permissions mechanism). The unique information you choose to send from Motion and HealthKit is not used by BrainBit Inc. for marketing and advertising or transferred to third-parties. 

LOCATION SERVICES 

If you allow these services we may detect your approximate current location. To achieve this, these services may use any of the following: Cell ID, GPS, Wi-Fi, or Bluetooth beacons. BrainBit Inc. does not store or analyze any location data to identify you. 

We use this information to provide location-based services. Location services are used to: 

  • get allowed contacts information about your location once you explicitly grant it; 
  • provide you with local search results; 
  • provide you content based upon your location; 
  • help improve recommendations. 

In addition, and as with most location-enabled applications, we and our third-party partners may access your location when you use BrainBit Inc.'s applications. Changes to these setting can be made through the Settings App. 

FACEBOOK 

If you decide to sign in with us using your Facebook account, we will receive your public profile information from Facebook such as username, your Facebook ID, profile photo and beyond this your e-mail address. You can have information displayed as to which Facebook friends are already registered with BrainBit Inc.'s applications, and you will be visible to your Facebook friends. By signing in via Facebook, your Callibri account will be permanently linked to your Facebook account. For further information on the use of data by Facebook, refer to the Facebook permissions documentation and to the Facebook privacy policy. Please note that your Facebook password does not come into our possession even after signing in with your Facebook account. 

The permissions asked are the following: 

  • Basic information 

By default, this includes certain User’s Data such as id, name, picture, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available. 

  • Public Profile 

Provides access to the 'Public Profile' section of the profile. 

  • Access Friend Lists 

Provides access to any friend lists the User created. 

  • Email 

Provides access to the User's primary email address. 

DATA DELETION REQUEST 

Users have the opportunity to request the deletion of personal data. A request to delete account data can be sent at any time in the form of a written application to e-mail: support@brainbit.com. 
Upon receiving the request, the mobile application database administrator deletes the application account and its associated data, namely: ID, name, picture, and user’s locale, friend list, results of sessions. 

After deleting the account and associated data, the user receives a confirmation email. 

FLURRY ANALYTICS 

BrainBit Inc. uses third-party service providers, such as Flurry Analytics in order to create accurate, real-time user data reports, so that BrainBit Inc. can continue to improve the user experience of BrainBit Inc.'s applications. This service collects and submits anonymous, aggregated data, which are anonymized via a secure hashing protocol, to analytics servers. This data includes information on which features are most frequently used. No personally identifiable information is collected. 

For more information on Flurry Analytics’ use of your information, please review the Flurry Analytics Terms of Service and the Flurry Analytics Privacy Policy. If you want to opt out from Flurry Analytics, you can do so here. 

HOW WE PROTECT INFORMATION 

We take several measures to safeguard the collection, transmission and storage of the data we collect. These steps depend on the sensitivity of the data that we collect, process, and store. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us, and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. Please, bear in mind that no system is 100% secure. 

BrainBit Inc. uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information. BrainBit Inc. engages a company that is an industry leader in online verification to strengthen the security of BrainBit Inc. BrainBit Inc. is registered with site identification authorities so that your mobile device can confirm BrainBit Inc.’s identity before any personally identifiable information is sent. 

METHODS OF PROCESSING DATA 

BrainBit Inc. processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. 

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to BrainBit Inc., in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (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 BrainBit Inc. at any time. 

PLACE 

The Data is processed at BrainBit Inc.'s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact BrainBit Inc. 

RETENTION TIME 

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that BrainBit Inc. suspend or remove the data. 

THE USE OF THE COLLECTED DATA 

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Handling activity data, Access to third-party accounts and Analytics. The Personal Data used for each purpose is outlined in the specific sections of this document. 

LEGAL ACTION 

The User's Personal Data may be used by BrainBit Inc. for legal purposes, in court, or in the stages leading to possible legal action arising from improper use of BrainBit Inc. or the related services. The User declares to be aware that BrainBit Inc. may be required to reveal personal data upon request of public authorities. 

SYSTEM LOGS AND MAINTENANCE 

For operation and maintenance purposes, BrainBit Inc. and any third-party services may collect files that record interaction (System logs) or use for this purpose other Personal Data (such as IP Address). Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from BrainBit Inc. at any time. Please see the contact information at the end of this document. 

THE RIGHTS OF USERS 

Users have the right, at any time, to know whether their Personal Data has been stored and can consult BrainBit Inc. to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to BrainBit Inc. at the contact information set out above. 

CHANGES TO THIS PRIVACY POLICY 

BrainBit Inc. reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using BrainBit Inc. applications and can request that BrainBit Inc. remove the Personal Data. Unless otherwise stated, the privacy policy in effect at the time applies to all personal data BrainBit Inc. has about Users. 

DISCLAIMER 

While BrainBit Inc. continues to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to BrainBit Inc. Transmitting personal information is done at your own risk. 

CONTACT INFORMATION 

BrainBit Inc., 100 U.N. Plaza, 7E New York, NY 1001 

info@brainbit.com 

Last modified: December 19th, 2022