Privacy Policy
Last updated: 05 April 2022
This Privacy Policy describes how we process the data provided to us in connection with your use of our UniqU located here https://m.braincracker.org/ (hereinafter “Service”).
This policy uses the term “personal data” to refer to information that is related to an identified or identifiable natural person and is protected as personal data under Applicable data protection law.
This policy covers the data processing practices of Intelit Ltd.
In this policy, “we”, “us” and “our” refer to Intelit Ltd.
1. What information do we collect about you?
This section describes the various types of information we collect from and about you. This information is not collected in all situations, but only in specific situations. To understand the context in which collection occurs, see Section 2 (How do we use your information?). More information about some of the mechanisms we use to collect this information, such as cookies, is available in Section 4 (Tracking Technologies & Cookies).
1.1. Information you provide to us
● Account information. To use the Service, you need to create an account before you can access it. As part of registering for an account, we may collect information such as device ID (automatically), name of the operating system used, username, gender, age.
● Communications and submissions. You may choose to provide us with information when you communicate with us (e.g. via email for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, participate in promotions, or submit information through our Service.
1.2. Information collected when you use our services
● Usage information. We collect information about how you interact with our Service, such as what bandwidth you use, and when and for how long you use our Service.
● Device information. We collect information from and about the device you use to access our services. For example, we may collect device identifiers (Device ID/Android ID), browser types, device types and settings, operating system versions, mobile, wireless and other network information (internet service provider name, carrier name and signal strength), and Service version numbers.
● Location information. We may collect your location information based on a variety of sources, such as your device’s GPS or by calculating an Approximate latitude and longitude based on your IP address.
1.3. Information provided to us by third parties
● Third party accounts. Our Service allows you to register an account using a third party account (Google, Apple and Facebook account). If you do so, that third party may send us some of the information it has about you. For example, the following data will be automatically entered from Facebook into your profile in our Service: name, surname, gender, age, date of birth, email address and other information that you have specified in your Facebook profile. ATTENTION! The Service does not gain access to your accounts in third-party services, or to logins and passwords from them. Data exchange takes place on the side of a third-party service and the user only logs into the Service using the keys of the third-party service.
You generally do not have a duty to disclose personal data to us unless you have a contractual obligation to us to do so. However, we need to collect and process certain information that is necessary or legally required in order to provide the services to you or otherwise perform our contractual relationships with you.
We use the information we collect for various purposes described below.
● To provide, maintain, troubleshoot and support our services. We use your information for this purpose on the basis that it is necessary to fulfill our contractual obligations to you. Examples: Using Usage Information to troubleshoot a problem you are reporting with our Service and to keep it running properly.
● To communicate with users and potential users. We use your information to communicate with you, including responding to your requests and sending you information and updates about our services. We may do this to fulfill our contract with you because you have given consent to communicate or because we have a legitimate interest in providing you with information about our services.
● To improve our services. We want to offer you the best service and user experience, which is why we have a legitimate interest in continually improving and optimizing our services. To do this, we use your information to understand how users interact with our services. Examples: we analyze certain usage, device and diagnostic information to understand aggregated usage trends and user engagement with our services; we may use device information for threat tracking and scientific research to improve our threat detection capabilities; we review User feedback to understand what we could do better.
● To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use User feedback to understand what new services users may want.
● To market and advertise our services. We may use your information to provide, measure, personalize and enhance our advertising and marketing based on our legitimate interest in providing you with services that may be of interest. Examples: we may use information such as who or what referred you to our services to understand how effective our advertising is; we may use the information to manage promotional activities such as sweepstakes and referral programs.
● To comply with legal regulations. We use your information internally as required by Applicable law, legal process or regulation. To learn about our methods of transferring your information to third parties in order to comply with legal requirements, see Section 3.1 below. We also use your information to protect our legal rights and resolve disputes.
2. Who do we share your information with and why?
2.1. Mostly
We may disclose your information in the following cases:
● According to your instructions or consent. For example, some services may allow you to register for an account using a third party account (such as a Google,Apple, or Facebook account). If you choose to do this, we will share the information with a third party account provider.
● Affiliates and Third Party Service Providers. To help us provide some aspects of our services, we work with our affiliates and trusted third parties. To protect your data, we establish Appropriate privacy and data processing terms with these third parties, review their security practices, and restrict information sharing to what they help us. Examples of activities in which we are assisted by third parties include:
○ providing analytics about our services
○ providing sales and customer support
○ maintaining the infrastructure necessary to provide our services
○ providing our marketing and advertising content
○ display advertising content
● New owner. If we change ownership or control of all or part of our services, assets or business, we may transfer your information to a new owner.
● Aggregated or anonymized data. We may use and share aggregated data and data that is anonymized so that it no longer reveals the identity of an individual user for regulatory compliance, research and analysis, our own marketing and advertising activities, and other legitimate business purposes.
● Comply with legal process and law. We strictly protect the privacy of our users. With this in mind, we may share your information if required:
- according to the current legislation;
- to comply with our legal obligations;
- to comply with the legal process;
- and to respond to valid law enforcement inquiries regarding a criminal investigation or suspected or suspected illegal activity that could subject us, you or our other users to legal liability.
If we share your information for these purposes, we will restrict the information transmitted to what is required by law and dispute information requests that we believe are illegal, overly broad, or invalid.
2.2. Display ads
We may serve ads to users in certain regions. The advertisements we display on our Service are provided either by advertisers with whom we have a relationship or by third-party ad networks such as Google. In order to display third-party advertisements in our Services, we integrate a software development kit (SDK), which consists of code provided by an ad network.
We share limited personal information about you with these third party ad networks to enable them to provide their services. For example, some of these ad networks may collect information through their SDKs, such as your cookies, IP address, and device information, in order to serve you “personalized” ads (ads that they think are more relevant for you) and measure your reaction to those ads.
Each ad network collects this information in accordance with its privacy policy. If the AdChoices logo Appears in an ad, you can click it to learn more about the ad network that served the ad, its privacy policy, and your choices to opt out of any personalized ad. If you opt out of personalized ads, you may still see non-personalized ads.
While we ask that you do not use ad blockers to prevent third-party ads from showing, because this is how we support our free services, our services may continue to work if you do use ad blockers.
2.3. Cloud service
We store your data using a cloud service provided to us by Yandex. Such storage is absolutely safe and protected as much as possible by encryption and other modern protection methods. Yandex maintains more security standards and certifications than any other cloud provider, and helps meet the requirements of virtually every regulatory authority around the world. Learn more about the Yandex cloud service here. Yandex's privacy policy is here. Learn more about how long we keep your data in section 7 of this Policy.
3. Tracking Technologies & Cookies
3.1. About tracking technologies
We use various technologies in our Service to help us collect information. For convenience, we call them "tracking technologies", although they are not always used to track people and the information collected is in an unidentifiable form that does not link to any personal information. Tracking technologies include:
Cookie
Cookies are small pieces of text that are stored on the device you use to access our services. Cookies allow us (or third parties that we allow to set cookies on your device) to recognize repeat users. Cookies can expire after a certain period of time, depending on what they are used for.
Pixel tags / page tags / web beacons / tracking links
These are small hidden images and blocks of code that are placed on web pages and in advertisements that allow us to determine if you are taking a specific action. When you open a page, ad, or click a link, these elements tell us that you have opened that page or clicked a link.
SDK
SDKs, or software development kits, are software code provided by our business partners that enables our software to interact with the services provided by those partners. For example, we may use the SDK to enable our Service to serve ads from the ad network. Sometimes, in this interaction, the business partner collects some information from the device running the software.
3.2. Why We Use Cookies
We use cookies:
● To provide our services. Some cookies are essential for our services to function properly. For example, cookies allow us to confirm who you are and whether you are eligible to access a resource.
● To save your preferences. Cookies can store your preferences, such as language preferences or the need to pre-fill your username on login forms. We may also use them to optimize the content we show you.
● For analytics. Cookies are used to inform us about how users interact with our services so that we can improve their experience as a legitimate interest (for example, which screens or web pages you access and how effective our advertising is).
● For advertising purposes. We advertise our services online with the help of third parties that display advertisements and marketing materials about us on sites on the Internet.
3.3. Third parties
We may allow our partners to host certain tracking technologies on our services. These partners use these technologies for the following purposes:
● For analytics. To help us understand how you use our services.
● For marketing. To help us promote and advertise our services to you, including on third party websites. Cookies are used in this regard to measure the effectiveness of our ads, correlate the actions you take with our ads with the actions you take in relation to our services, for retargeting ads (showing ads based on your past interactions with our services) and targeting ads to similar audiences.
● To display ads. Advertising networks may use these technologies to serve ads that they believe will be more relevant to you. For more information, see the "Displaying Ads" section above.
3.4. Your choice
● Our Cookies: Most web browsers and some mobile devices give you the ability to manage your cookie preferences, including deleting cookies and blocking the installation of cookies on those browsers or devices. Please visit the Help section on your mobile device to find out what controls it provides over cookies. Please note that deleting or blocking certain cookies may adversely affect the proper functioning of our services.
● Third party advertising cookies and mobile IDs. For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:
○ Network Advertising Initiative opt-out page
○ Digital Advertising Alliance opt-out page
○ Your choice on the Internet (for Australian residents)
○ Your choice on the Internet (for EU residents)
To opt out of personalizing Google ads, visit the Google Ads Settings page . These opt-out mechanisms are not provided by us and we are not responsible for their availability or performance. Please note that after opting out of personalized ads, you may still see non-personalized ads.
● We are also constantly working to improve our Service, in connection with which we use third-party services to analyze your activity, these are services such as:
Amplitude - link to privacy policy
4. Security
We use a range of administrative, organizational, technical and physical security measures designed to protect your data from unauthorized access, loss or alteration. We are constantly working to improve these guarantees.
5. International data transfer
We may transfer your personal data to countries other than the one in which you reside. We do this to facilitate our operations, and recipients include service providers and partners. Laws in other countries may differ from those that apply where you live. For example, personal data collected in Switzerland, the United Kingdom or the European Economic Area (EEA) may be transferred and processed outside Switzerland, the United Kingdom or the EEA for the purposes described in this policy. However, we use appropriate security measures to help ensure that such data receives an adequate level of protection. You can contact us if you need more information about such guarantees.
6. Data storage
As a rule, we keep your personal data for as long as it is necessary to provide you with the services, or for as long as you have an account with us. We may also store personal data when required by law or in our legitimate interests, such as detecting and preventing abuse and protecting against legal claims. Residual copies of personal data can be stored in backup systems as a security measure to prevent data loss. Subject to the foregoing, when your personal data is no longer required, we will ensure that it is safely deleted or stored in such a way that we can no longer use it.
7. Your rights
Depending on your country of residence, you may have certain legal rights with respect to the personal information we hold about you. Subject to the exceptions and limitations provided by applicable law, these may include the right to:
● access and obtain a copy of your personal data;
● correct your personal data;
● restrict the processing of your personal data;
● object at any time to the processing of your personal data;
● delete your personal data;
● data portability;
● withdraw any consent that you have previously given to the processing of your data (for example, opt-out of marketing communications);
● lodge a complaint with a data protection authority;
● request that we provide you with the categories of personal information that we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose of collecting or selling your personal data; and the categories of third parties with whom we share personal data. This information can also be provided in this Privacy Policy.
Please note that your rights and choices depend on your location and some information may be excluded from certain requests in accordance with applicable law.
If you wish to exercise any of these rights, you can contact us using the information provided in the Contact Us section below. In accordance with the law, we may ask you to verify your identity before taking further action on your request.
8. Your California Privacy Rights
This section applies exclusively to California residents.
8.1. Do not track signals
We do not currently respond to Do Not Track signals sent by browsers or mobile Services due to a lack of standardization on how this signal should be interpreted. Learn more about Do Not Track.
8.2. Third Party Disclosure Requests
California law permits California-based users to request and receive from us, once a year, free of charge, a list of third parties to whom we have disclosed their "personal information" (if any) as defined in California Civil Code 1798.83 for their direct marketing purposes in the previous calendar year, and the type of personal information disclosed to those parties. See the Contact Us section below for where to send such requests. Please note that we do not share personal information with third parties for their own direct marketing purposes without your prior consent.
8.3 Cancellation of sale
You may have the right to opt-out of the "sale" of your personal information as defined in the California Consumer Privacy Act (CCPA). The CCPA defines “sale” broadly and may include allowing third parties to receive certain information, such as cookies, to deliver personalized advertisements on our services.
We do not “sell” (as defined by the CCPA) your personal information, except in the context of certain versions of our products that are supported by personalized advertising. Advertising, including personalized advertising, allows us to provide some of the features of our product for free, to provide offers related to you. Personalized ads allow you to show ads that are more relevant to you.
Depending on the services you use and how you use them, we may “sell” (as defined by California law) the following categories of personal information for such advertising purposes:
● Identifiers (eg advertising IDs and cookies).
● Approximate geolocation information.
To opt out of our use of your information for such purposes, please visit: Don't Sell My Personal Information. Please note that we do not knowingly sell personal information to minors under the age of 18.
8.4 Additional rights
California law may authorize you to require us to:
● provide you with the categories of personal information that we have collected or disclosed about you in the past twelve months, the categories of sources of such information, business or commercial purposes for collecting or selling your personal information, and the categories of third parties with whom we have shared personal information. Information about this is available in this section;
● provide access to or a copy of certain information we hold about you;
● delete certain information we have about you.
You may also have the right to be informed about the financial incentives we offer you (if any) and the right not to be discriminated against (as provided in the CCPA) for exercising certain of your rights.
Certain information may be excluded from such requests in accordance with applicable law. For example, we need certain types of information in order for us to provide you services and comply with applicable laws.
When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (for example, verifying your email address). If you ask us to remove certain information, you will no longer be able to access or use our services.
You are also allowed to designate an authorized agent to make certain requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with a signed written authorization or power of attorney to make such requests. We may also contact you to verify your identity before processing an authorized agent request.
If you would like more information about your statutory rights under California law, or would like to exercise any of them, please contact us at the address provided in the Contact Us section below.
8.5. A brief description of how we process your personal information
The California Consumer Privacy Act (CCPA) requires us to disclose certain information to California residents, including the categories of personal information we collect, the purposes for which we use that information, the categories of sources of personal information, and the categories of third parties with whom we share personal information. This section sets out this information in the manner prescribed by the CCPA, but does not differ substantially from the information in the rest of this policy.
Sources of personal information
All categories of personal information that we collect comes from the following categories of sources:
● You (either by voluntary submission or automatically, for example, when you use our services)
● Third parties (such as service providers, other users, or marketing partners who may refer you to our services)
The categories of personal information we collect and who we share it with
● Identifiers (such as name, account username, email address).
● Geolocation information (e.g., your city and state based on IP address).
● Demographic and statistical data (such as age and gender)
● Customer service information (such as support requests)
● Answers to surveys and other research information
● Other information that identifies you or may reasonably be associated with you.
Categories of third parties to whom we share your personal information
The categories of collected personal information, as described above, may be transferred to the following categories of third parties:
● Our partners
● Third-party service providers that provide services on our behalf (for example, Facebook through which you registered on our Service)
● Third party ad networks (e.g. Google)
● Third parties for legal purposes (for example, in response to a lawsuit)
● Others with your consent or at your direction.
The categories of business and commercial purposes for which we use your personal information
The categories of personal information collected, as described above, are used for the following categories of purposes:
● To provide, maintain, troubleshoot and support our services.
● To communicate with users and potential users.
● To improve our services.
● Develop new services.
● Promote and advertise our services.
● To avoid injury or liability.
● To comply with legal regulations.
Additional information on these categories, including use cases, is available in Section 2 above.
9. Age restrictions.
Our services are not intended and cannot be used by minors. In this context, minors are persons under the age of 18 (or under the age that may apply in the jurisdiction). We do not knowingly collect personal data from minors and do not allow them to use our services. If we find that we have collected personal data from a minor, we may delete such data without prior notice.
10. Updates to the privacy policy.
We may update this Privacy Policy from time to time in accordance with this section for reasons such as changes in laws, industry standards, and business practices. We will post updates on this page and update the "Last Updated" date above. If we make updates that materially change your privacy rights, we will also use reasonable efforts to notify you in advance, such as via email or the Service. If you do not agree with this update of this policy, you can close your account in the Service. If you do not cancel your account by the date the update becomes effective, your continued use of our services will be governed by the updated Privacy Policy.
11. Deleting data
In the event that you wish to permanently delete all of your data and terminate your participation in the Service, all you have to do is email us at goodbye@braincracker.org and your data will be permanently deleted from the Service no later than 30 days after you send the email. It is important to indicate in the letter your intention to delete the profile and your data, as well as indicate to which email address the profile is linked in the Service.
12. Contact us
We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you have any questions or complaints about our privacy policy, you can contact us using the following details:
INTELIT LTD
Reg. number NOT 390165
Address: Ioanni Chakket, 44 MERIKA BUILDING 6045, Larnaca, Cyprus
E-mail address: hello@braincracker.org