BRAINYTRAINEE LTD (“Company”, “we”, “us”, or “our”) respects your privacy and the privacy of children using our services. This Privacy Policy (“Policy”) explains what personal data is collected and further processed by us, the sources (if any) of personal data, and to whom personal data is disclosed. This Policy applies to our mobile applications (“Apps”) and our website.
We comply with applicable privacy laws, including the Children’s Online Privacy Protection Act (COPPA), the EU/UK General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA), where applicable.
This Privacy Policy applies to all users, including children and parents or guardians, who access our Apps or website (“Users”). Whenever we refer to children in this Privacy Policy, we mean children under the age of 13 (or, if outside the U.S., under the age of digital majority).
1. What Data is Collected?
We may collect the following personal data through our Apps and website:
Contact details (name, email address) when you contact support or create an account in non-kids products.
Location (city, country), device language, and time zone.
Technical and activity data (IP address, device type, OS version, app version, crash logs, in-app events).
Device identifiers (e.g., IDFV, IDFA/GAID), collected only with consent and not used in kids’ apps except as permitted by COPPA/Store rules.
Purchase information (processed by Apple App Store / Google Play; we do not receive full payment card details).
Cookies and similar technologies on our website for analytics and service improvement (not used for behavioral advertising in kids’ apps).
Cookies: We use cookies and similar technologies on our website to analyze trends, personalize the experience, and improve our services. For details on cookies, please contact us at privacy@brainytrainee.com.
You are responsible for any third-party personal data obtained, published, or shared with us and confirm that you have obtained the third party’s consent to provide the data to us.
2. Processing Children’s Data
Our Apps in the Kids category do not collect personal data without verifiable parental consent.
We do not use behavioral targeting or interest-based advertising in kids’ apps.
If we learn that personal data has been collected from a child without the required consent, we will promptly and securely delete it.
Parents or legal guardians may request access to or deletion of their child’s data by emailing privacy@brainytrainee.com.
Parental Consent & Verification: For children under 13 (or applicable age), we obtain verifiable parental consent before collecting any personal data. Methods include email verification, in-app parental gates, or other lawful means as required by applicable law.
3. Why Do We Use Your Data?
To enable registration and manage accounts (in non-kids products).
To respond to inquiries and provide support.
To process in-app purchases via app stores.
To improve our Apps, conduct testing, research, and analytics (aggregated/non-personal where possible).
To send essential service communications.
To comply with legal obligations and protect rights.
4. How We Protect Your Data?
We endeavor to process your personal data in a safe environment by preventing any unauthorized or unlawful processing, accidental loss, destruction, or damage. Security measures include:
Encryption in transit and at rest, where applicable.
Strict access controls based on the need-to-know principle.
Regular security reviews and testing.
5. Disclosure of Your Data
We share personal data with external parties only as necessary to operate our services and under appropriate data processing agreements and safeguards. These parties are not used for behavioral tracking of children.
Examples of external parties:
Analytics: AppMetrica (Yandex LLC) — anonymized analytics; Adjust GmbH — install attribution and analytics; COPPA-compliant mode in kids’ apps.
Payments: Apple App Store / Google Play — payment processing for in-app purchases.
Amazon Fire: Settings > Device Options > Advertising ID — limit ad tracking.
Our kids’ apps do not use interest-based advertising regardless of device settings.
Compliance: SDK configurations in kids’ apps align with COPPA, Google Play Families Policy, and Apple Kids Category requirements. We do not sell personal data and follow data minimization and purpose limitation.