FocusBrain (“us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of applications (“Apps”) and other products, services and features thereof (the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of FocusBrain). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.

Collection of Information

• Information You Provide to Us

  We collect information when you register for an account, participate in promotion, make a purchase, request customer support, or otherwise communicate with us. The information you may provide includes your name, email, password, goals, payment method information, feedback, and other information about you included within your messages to us. we process that information consistent with the purpose for which it was provided.

• Other Information About Your Use of the Services

  When you use our Services, we collect the following information about you:

  Usage Information: Whenever you use our Services, we collect usage information, such as the sessions you use, tracks you listen to, what screens or features you access, and other similar types of usage information.

  Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product description, price, subscription or free trial expiration date, and time and date of the transaction.

  Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region).

  Information we Generate: We generate some information about you based on other information we have collected. For example, like most platforms, we use your IP address to derive the approximate location of your device. We also use your first name to make an educated guess about your gender and use information about your activity to help determine the likelihood of you continuing to use our Services in the future (which we hope will be the case!).

• Information We Collect from Other Sources

  We also obtain information about you from other sources, including transaction information from third-party app stores you use to install our app or purchase a subscription. Additionally, if you create or log into your account through a social media service account, we will have access to certain information from that account, such as your name and other account information, in accordance with the authorization procedures set by that social media service.

Use of Information

• We use the information we collect to:

  Provide, maintain and improve our Services, including debugging to identify and repair errors, and develop new products and service;

  Process transactions and fulfill orders;

  Send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages;

  Communicate with you about products, services, and events offered by FocusBrain and others, request feedback, and send news, gifts or other information we think will be of interest to you;

  Monitor and analyze trends, usage, and activities in connection with our Services;

  Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of FocusBrain and others, including to enforce our agreements and policies. If you feel your transaction was declined in error, please contact us for assistance at [email protected];

  Comply with the law, such as by processing transactional records for tax filings and other compliance activities;

  Personalize your online experience and the advertisements you see on other platforms based on your preferences, interests, and browsing behavior.

• Confidentiality and security

  The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at [email protected]. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law.

• Where we store your personal data

  All data you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on FocusBrain’ servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.

  Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

• Disclosure of your data

  We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

  We may also disclose your personal data to third parties as follows:

  In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.

  In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.

  If FocusBrain’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require the data to provide services to FocusBrain, FocusBrain requires each of its service providers to agree to maintain the confidentiality and security of your personal data.

  In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

  If FocusBrain or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.

  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of FocusBrain, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.

  With third parties, such as Facebook, in order to serve FocusBrain advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.

• Deletion of personal information

  You can contact Brainwaves and require deletion of personal information by emailing [email protected].

• Data retention

  We retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.

• Withdrawal of consent for processing activities

  To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing [email protected].

• Changes to our privacy policy

  We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.

• Contact Information

  If you have any questions about this Privacy Policy, please contact us at: [email protected].

Last update: 09/10/2021