Privacy Policy

1. About this Policy

This Privacy Policy explains how BRAINYTRAINEE LTD ("Brainytrainee", "we", "us" or "our") collects, uses and discloses personal data when people use our mobile applications, visit brainytrainee.com, contact us or otherwise interact with our services (together, the "Services").

This Policy is a notice about our data practices. It does not make acceptance of our Terms of Use into consent where applicable law or a platform requires a separate choice. An app-specific notice or store privacy label may provide additional details for a particular build; if it is more specific, it supplements this Policy.

2. Who is responsible for your data

The controller responsible for the processing described in this Policy is:
BRAINYTRAINEE LTD
Company number: 12471634
Registered office: Office 34a, Business Centre, 9 Lydden Road, London, United Kingdom, SW18 4LT
Email: business@brainytrainee.com

3. Services covered and product differences

This Policy covers the website and the following General-Audience Apps. They are not directed to children and do not require a Brainytrainee account. Our current portfolio does not provide open chat or a facility for users to upload and publish user-generated content.

4. Personal data we process

4.1 Information you provide

• contact details, message content and attachments when you contact support or make a business enquiry;
• feedback or survey responses that you choose to send;
• purchase and entitlement information supplied by Apple or Google, such as product, transaction reference, subscription status and restoration status, but not full payment-card details; and
• information reasonably necessary to verify and answer a privacy request.

4.2 Information collected automatically

• device and app information, such as device type, operating-system version, app version, language, time zone and general region;
• online and app-scoped identifiers, such as IP address, installation identifier, IDFV and, only where permitted, IDFA or Android Advertising ID;
• usage events, such as app launches, sessions, screens or features used, progression, ad impressions and reward completion;
• diagnostic and performance information, including crash logs, error data and response times;
• acquisition and attribution information, such as campaign, referrer and install source; and
• leaderboard information supplied through an enabled platform service, such as display name, player identifier and score.

We do not intentionally collect precise GPS location, address-book contacts, photographs, microphone recordings or other sensitive device data through the current Services. If a future feature needs sensitive data, the App will provide a just-in-time notice and request any required device permission before access.

5. Advertising in the Obby Apps

Mega Obby and Prison Escape use AppLovin MAX to mediate interstitial ads and rewarded ads. Interstitial ads may appear at natural breaks in play. Rewarded ads are initiated by the player in exchange for the in-app reward described at the point of choice. Cat Simulator and Talking Dog do not display third-party advertising.

AppLovin and advertising partners enabled through MAX may receive or derive device and app information, IP address, advertising or app-scoped identifiers, approximate location inferred from IP, ad-request and impression data, interactions with ads, and fraud-prevention signals. They use this information to select and deliver ads, limit repetition, measure performance, detect invalid activity, report revenue and, where permitted by your choices and applicable law, personalise advertising.

Where consent is required, personalised advertising or access to advertising identifiers is not enabled before the required consent or platform permission. On iOS, tracking that falls within Apple AppTrackingTransparency is not conducted without the user’s authorisation. A refusal does not block gameplay that does not require tracking; contextual or otherwise limited ads may still be shown where lawful.

AppLovin’s current privacy notice is available at https://legal.applovin.com/privacy/. MAX can connect to additional ad networks. The partners actually enabled for a particular App and region may be shown in the in-app privacy/consent interface or store disclosure. Those partners act under their own privacy notices where they determine their own purposes.

6. SDKs, service providers and store controls

Depending on the App, platform and build, we use the providers below for advertising, analytics, attribution, reliability, distribution and support. A provider may act as our processor/service provider, as an independent controller/business, or in both roles depending on the service and jurisdiction. Consent-dependent SDK processing does not start until the required choice has been recorded. Advertising SDKs are enabled only in Mega Obby and Prison Escape.

We use analytics to maintain and improve the Apps, diagnose problems, understand feature use and assess marketing performance. We do not use analytics to make solely automated decisions that produce legal or similarly significant effects for an individual.

6.1 Opt-out and store controls

• Apple iOS: Settings > Privacy & Security > Tracking - disable tracking for the relevant App.
• Google Android: Settings > Privacy > Ads (wording may vary by device) - delete or reset the Advertising ID and manage ad-personalisation controls.
• In-App Privacy Choices: where displayed, reopen the privacy interface in the App settings to withdraw or change advertising, analytics or attribution consent.
• Store subscriptions: manage or cancel subscriptions through the Apple App Store or Google Play subscription settings. Deleting an App does not cancel a subscription.

A withdrawal prevents future consent-based processing by components we control after the choice is received. It does not invalidate processing already carried out lawfully. Refusing tracking or personalised advertising does not block gameplay that does not require that processing; contextual or otherwise limited ads may still be shown in the Obby Apps where lawful.

7. Website and communications

When you visit brainytrainee.com, our hosting and security providers may process IP address, browser and device information, requested pages, timestamps, referring page and security logs. The website does not require an account and does not process payments. Essential cookies or similar storage may be used to operate and secure the site. Non-essential analytics or advertising tags will not be activated before any consent required in your location.

When you email us, we process your email address, message, attachments and related technical information to respond, investigate problems, protect our rights and keep an appropriate record. Support may be managed through a service provider such as Freshdesk.

8. Purposes and legal bases

Where the UK GDPR, EU GDPR or a similar law applies, we rely on the legal bases below. The basis can vary with the context and jurisdiction.

9. Service providers and disclosures

We disclose personal data only as reasonably necessary for the purposes described in this Policy and subject to appropriate safeguards. The current SDKs, platform providers and support providers are identified in Section 6. Other recipients may include hosting, cloud and security providers; professional advisers, auditors, insurers, courts, regulators and public authorities where legally necessary; and a purchaser, successor or reorganised entity in a corporate transaction, subject to applicable notice and protection requirements.

We do not disclose personal data to data brokers. We do not sell personal data for money. Some advertising disclosures may be treated as a "sale", "sharing" or targeted advertising under certain U.S. state laws even when no money changes hands; where those laws apply, we provide the required opt-out control.

10. International transfers

We are established in the United Kingdom. Providers may process data in the United States, European Economic Area and other countries. Where required, we rely on an adequacy regulation or decision, the UK International Data Transfer Agreement or Addendum, the European Commission Standard Contractual Clauses, or another lawful transfer mechanism, together with supplementary measures where appropriate.

11. Retention

We keep personal data only for as long as reasonably needed for the relevant purpose, legal compliance or legal claims. Actual periods may be shorter where a provider or user setting deletes data earlier.

Backups are protected and overwritten on a defined cycle. If immediate deletion from a backup is not practicable, the data is isolated from ordinary use until overwritten, unless restoration is required for security or disaster recovery.

12. Security

We use administrative, technical and organisational measures appropriate to the nature of the data and risks, including access controls, data minimisation, secure development and vendor review. We use encryption in transit where supported and appropriate protection for stored data. No system is completely secure, so we cannot guarantee that unauthorised access or loss will never occur.

13. Your choices and controls

• Change device permissions and advertising settings through iOS or Android settings.
• On iOS, change tracking permission under Settings > Privacy & Security > Tracking.
• Use the privacy choices shown in the App to change consent or opt out where available.
• Purchase ad-free access where offered; this removes in-App advertising but does not necessarily remove essential diagnostics or purchase processing.
• Withdraw consent at any time without affecting processing that occurred lawfully before withdrawal.

14. Your privacy rights

Depending on where you live, you may have rights to request access, correction, deletion, restriction, portability, objection, withdrawal of consent, and information about disclosures. You may also have a right to opt out of sale/sharing or targeted advertising, appeal a decision, and not be discriminated against for exercising a privacy right.

Send a request to business@brainytrainee.com with enough information to identify the relevant App, device, purchase or support interaction. We may request information reasonably necessary to verify the request. An authorised agent may act where permitted by law, subject to proof of authority.

UK users may complain to the Information Commissioner’s Office at https://ico.org.uk. EEA users may complain to the supervisory authority where they live or work. We encourage you to contact us first so that we can try to resolve the issue.

14.1 ADDENDUM FOR EEA RESIDENTS (EU GDPR REPRESENTATIVE)

If you are a resident of the European Union, the EU General Data Protection Regulation (EU GDPR) applies to the processing of your personal data.

BRAINYTRAINEE LTD, a company organized and existing under the laws of the United Kingdom (the Data Controller), has appointed its affiliated EU entity as its designated representative in the European Union in accordance with Article 27 of the EU GDPR.

If you have any questions about how we handle your personal data, or if you wish to exercise your data subject rights (such as the right to access, delete, or restrict your data), you can contact our EU Representative directly:

EU Representative Name: JMH DEVELOPERS OÜ

Postal Address: Vesivärava tn 50-212, Kesklinna linnaosa, Tallinn 10152, Harju maakond, Estonia

Dedicated Email Address: support@jmhdevelopers.com

Our EU Representative is authorized to act on our behalf and serve as a direct point of contact for EU users regarding all matters related to EU GDPR compliance.

15. Children’s privacy

The Apps covered by this Policy are General-Audience Apps and are not directed to children under 13 or the higher minimum age that applies in a user’s location. A low or family-friendly content rating describes content suitability and does not mean that an App is child-directed. We do not knowingly ask a child to create a Brainytrainee account or submit personal data to us.

If we learn that we collected personal data from a child without the authorisation required by law, we will disable the relevant adult-only processing and delete the data as required. A parent or guardian may contact business@brainytrainee.com. If an App is later marketed or configured as child-directed, we will apply child-protective defaults and update this Policy and relevant store disclosures before that change.

16. United States state disclosures

If a U.S. state privacy law applies to Brainytrainee and the relevant processing, residents may exercise the rights provided by that law. In the preceding 12 months, we may have collected identifiers, internet or electronic-network activity, commercial information, approximate location and limited inferences about app use. We obtain these categories from users, devices, stores and the providers described above for the purposes in Section 8.

We do not knowingly sell or share the personal information of consumers under 16. For adults, disclosures to advertising partners in the Obby Apps may constitute sharing or targeted advertising under some state laws. Where applicable, the in-App privacy control or a request to business@brainytrainee.com can be used to opt out. We honour legally recognised opt-out preference signals for browser-based activity where required and technically applicable.

17. Changes to this Policy

We may update this Policy to reflect changes in the Services, providers, data practices or law. We will update the effective date and provide appropriate advance notice of material changes where required. We will obtain consent before using personal data for a materially new purpose where law requires it.

18. Contact us

Questions, privacy requests and complaints may be sent to business@brainytrainee.com or by post to BRAINYTRAINEE LTD, company number 12471634, Office 34a, Business Centre, 9 Lydden Road, London, United Kingdom, SW18 4LT.

Related

• Privacy policy
• Terms of use and end user licence agreement
• Information for parents
• Contact