PRIVACY POLICY

Last modified: April 2025

BRAINYTRAINEE LTD (hereinafter collectively referred to as "we," "us" or "our") is committed to respecting your privacy and the privacy of children who use our services. This Privacy Policy ("Privacy Policy") outlines our data protection practices and describes the types of information we may collect and process when you install and/or use our mobile applications (the "Apps", "our Apps").

When we refer to "personal data" (or "personal information"), we mean any information that relates to an identified or identifiable natural person, particularly through reference to identification numbers or one or more factors specific to that person's physical, physiological, mental, economic, cultural, or social identity.

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).

BRAINYTRAINEE LTD complies with the Children's Online Privacy Protection Act (COPPA), a U.S. law designed to protect the online privacy of children.

If you have any questions or comments about how we treat children's information or our compliance with COPPA, please contact us at support@brainytrainee.com.

For the purposes of the General Data Protection Regulation (GDPR), we act as the data controller, unless otherwise specified.

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW YOUR PERSONAL INFORMATION MAY BE PROCESSED. BY USING OUR APPS OR WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE READ THE FOLLOWING IMPORTANT NOTICE.

Under the California Consumer Privacy Act of 2018 (CCPA), California residents have the right to request the following information regarding their personal information:

- The categories of personal information that we process;

- The categories of sources from which personal information is obtained;

- The purposes for which we process user personal data;

- The list and categories of third parties with whom we may share your personal information;

- The specific pieces of personal information that we may have collected about a particular user, provided that the information submitted in the request is sufficient to identify the user.

Please note that all third parties engaged in processing user data are service providers who use such information based on contractual agreements and as necessary for legitimate business purposes.

OPT-OUT OPTIONS

If you wish to stop us from processing your personal information or your child's personal information, please reach out to us at support@brainytrainee.com. Please note that in many instances, the continued functionality of the App may be affected without the necessary operational data; as a result, we may recommend that you uninstall the App from your device.

If you prefer not to share device identifiers and geolocation data with our service providers, you can adjust your device settings to opt out of this data sharing. Keep in mind that opting out may limit certain features or services within the App. We are committed to respecting your privacy and providing you with transparent options for managing your information. If you have any further questions or need assistance, please do not hesitate to contact us.

REQUESTS

If you would like to submit a verifiable request regarding your personal data—whether for access, portability, or deletion—please reach out to us at support@brainytrainee.com. When contacting us, kindly include the phrase "Your rights to maintain confidentiality in the state of California" in your request.

To facilitate your request, please ensure that you are prepared to:

- Verify Your Identity: Provide sufficient information that helps us verify that you are the individual about whom we've collected personal information or an authorized representative.

- Detail Your Request: Describe your request with enough detail to help us understand, evaluate, and respond appropriately.

Please be aware that if we are unable to verify your identity or authority to make a request, or if we cannot confirm that the personal information pertains to you, we may be unable to fulfill your request.

EQUAL RIGHTS POLICY

We are committed to upholding equal rights and ensuring non-discrimination in the handling of your requests. This means that regardless of your choices regarding your personal information, we will maintain consistent pricing, product offerings, and service quality for all our customers. However, please be aware that in certain situations, the deletion of your personal information from our records may limit our ability to provide specific services.

DATA SALES POLICY

We are committed to protecting your privacy and ensuring that your personal data remains secure. We want to assure you that we do not sell, trade, or otherwise transfer your personal information to any third parties. Your data is used solely for the purposes outlined in our privacy policy, and we take every precaution to safeguard it.

INFORMATION WE PROCESS

We process various categories of information when you use our Apps. The information we collect is essential for fulfilling our contract with you. Without this information, we cannot provide the full functionality of our Apps or perform the services you have requested.

1. Functional Information

When you or your child engage with our Apps, we request and process the following types of information:

- User Content (i.e., text you type into a message box, PDFs you attach and submit to the Apps, and any text and other content created by artificial intelligence using the Apps)

- Contact Information: We collect information that you provide when you contact us via email or a support form.

We do not collect more personal information from children than is reasonably necessary to use our Apps. If you are a parent or guardian and believe that we have collected your child's personal information in violation of COPPA, please contact us at support@brainytrainee.com, and we will remove such information to the extent required by COPPA.

2. Automatically Processed Information

With your permission, we employ third-party automatic data processing technologies (such as advertising or analytics tools) to analyze information transmitted from your device through our Apps (Identity For Advertisers).

We may also process certain information regarding your device and user behavior based on our legitimate interests. This information, generally considered non-personal (as it does not directly identify any individual), is accessed in aggregated form. We use this information to enhance our Apps and ensure the best possible user experience.

Device Details

When you access our Apps via a mobile device, we may collect details about your device, including unique identifiers known as device identifiers. These small data files or similar structures stored on your mobile device allow us to identify your device without associating it with your identity. Device identifiers enable generalized reporting and personalized content and advertisements from third parties.

What Data Can Be Processed:

- Device Information: Includes device type, operating system and version, model and manufacturer, screen size, screen density, audio volume, battery status, loading time, latency, framerate, and memory usage.

- Internet Connection Information: Contains details such as mobile carrier, network provider, network type, IP address, timestamp, session duration, and browsing speed.

- Location Information: May include your IP address, country code/region/state/city associated with your SIM card or device, language settings, time zone, and nearby commercial points of interest (e.g., coffee shops).

- Other Identifiers: May comprise user identifiers set up by the app developer.

3. Payment Information

Our e-commerce provider (Apple/Google) is accountable for billing, processing, and charging for in-app purchases. They handle your personal information with the utmost security and confidentiality. This information is processed as part of executing the contract between you and us. We do not have access to your credit or debit card information.

You may review the applicable in-app purchase rules and policies directly from the respective app stores.

PURPOSES OF PROCESSING YOUR PERSONAL DATA

Our mission is to continuously enhance our Apps and provide you and your child with innovative experiences. To achieve this, we process your personal information for the following purposes:

- To make our service available

- To improve, test and monitor the effectiveness of our Apps

- To provide you and your child with interest-based (behavioral) advertising or other targeted content

- To communicate with you

- To prevent fraud and spam, to enforce the law

Should any new purposes for processing your personal data arise, we will inform you by updating this Privacy Policy to reflect the new processing activities.

SHARING OF YOUR INFORMATION

We will share your information with third parties only in the manners described in this Privacy Policy. We adhere to the U.S. Digital Advertising Alliance's Self-Regulatory Principles for the Mobile Environment and applicable children's privacy laws, such as the Children's Online Privacy Protection Act (COPPA).

Please note that while we integrate external services, we select third parties that can ensure the implementation of all necessary technical and organizational measures to protect user personal data.

To help us provide you with the best service, we work with third party analytics providers AppMetrica and Adjust in our apps for children.

Respective Privacy Policy can be found at https://metrica.yandex.com/about/info/privacy-policy and https://www.adjust.com/terms/privacy-policy/

Our applications may contain links to third-party websites or services, or you may access our applications from a third-party site. We are not responsible for the privacy practices of these third-party sites or services, including the information or content contained within them.

INTERNATIONAL DATA TRANSFERS

We operate in a cross-border context and provide our Apps to Users worldwide.

Both we and third-party organizations that supply automated data processing technologies for our Apps, as well as our advertising partners, may transfer automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions globally.

If you are located in the European Union or in regions with data processing laws that differ from U.S. law, please be aware that we may transfer information, which may include personal data, to countries or jurisdictions that do not have equivalent data protection laws as those in your jurisdiction.

DURATION OF PERSONAL DATA RETENTION

We retain your personal information for as long as necessary to provide the functional services of the Apps and to fulfill our legal obligations. If you wish to discontinue our use of your information that we physically access and store, you may request the deletion of your personal information and the closure of your account.

However, certain data may continue to be retained for a specified period (not exceeding the necessary duration for its intended purpose) if it is required to comply with legal obligations (such as taxation, accounting, and auditing) or to maintain safety measures, backup configurations, and to prevent fraud or other malicious activities.

EXERCISING YOUR RIGHTS

Under applicable data protection laws, you have specific rights concerning your personal information. You have the following options regarding your personal data that we have collected, including that of your child:

Right to Access

You have the right to request access to the personal data that we process about you and your child.

Right to Data Portability

You have the right to receive the personal data you have provided to us, which we process in a structured, commonly used, and machine-readable format.

Right to Rectification and Erasure

You have the right to have inaccurate personal data rectified. Further, you have the right to request the erasure of your personal data under certain circumstances.

Right to Object

You have the right to object to our processing of your personal data on grounds relating to your particular situation.

Right to Withdraw Consent

If we have requested your consent for the processing of your or your child's data, you have the right to withdraw that consent at any time.

To exercise any of the rights described above, please contact us at support@brainytrainee.com. Please note that we can ensure the rights mentioned above only with respect to the information that we physically access and store.

HOW TO OPT OUT

Opt-out of marketing tracking

You can manage your activity tracking permissions. If you do not want third-party service providers to use the personalized ads on the basis of your or your child's interests please follow the instructions below:

For Apple: Go to Settings > Privacy & Security (or "Privacy" in earlier versions of iOS) > Tracking, then tap to turn off or turn on permission to track for a specific app.

For Google: Go to Settings > Privacy > Ads, then you can choose either to "Reset advertising ID" or to "Delete advertising ID".

For Amazon: Go to Settings > Device Options > Advertising ID > Limit Ad Tracking.

SECURITY

The security of your personal information and your children's information is of paramount importance to us. We adhere to generally accepted industry standards to safeguard the personal information you provide, both during transmission and after it has been received. We employ reasonable and appropriate measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the associated risks and the nature of the personal information involved.

We implement suitable technical and organizational measures designed to effectively uphold data protection principles, such as data minimization, and to integrate necessary safeguards into our processing activities. We endeavor to ensure that your personal data is encrypted using robust and reliable encryption algorithms, with hashing employed where feasible.

However, it is important to note that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data to the best of our ability, we cannot guarantee its absolute security. In the event of a security breach that compromises your personal information, we will promptly notify you in accordance with applicable laws.

If you have any questions or concerns regarding the security of our applications, please do not hesitate to contact us at support@brainytrainee.com.

CHILDREN'S PRIVACY

We are committed to safeguarding the privacy of children. We do not collect or solicit any personal information from individuals under the age of thirteen (13) without the prior consent of a parent or guardian. If your child is between the ages of thirteen (13) and eighteen (18), they may use our Apps with parental or guardian consent and supervision.

If we become aware that we have inadvertently collected personal information from a child under the age of thirteen (13) without obtaining the necessary consent from a parent or guardian, we will take immediate steps to delete that information. If you believe that we have collected information from or about a child under thirteen (13) without the necessary consent, please contact us at support@brainytrainee.com.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy is subject to regular updates.

In the event of any changes to this Privacy Policy, we will post the revised version on this Privacy Policy and in other locations we deem appropriate. We may also provide additional notice of modifications or updates as warranted by the circumstances.

HOW TO CONTACT US

If you have any questions about this Privacy policy, please feel free to contact us at support@brainytrainee.com.