FOCUS - TRAIN YOUR BRAIN PRIVACY POLICY

Last update: November 2020

This Privacy Policy explains how Focus- Train your Brain collects, uses, and discloses information about you when you access or use our websites, mobile application, and other online products and services, and when you contact our customer service team, engage with us on social media, or otherwise interact with us.

We value the trust that you place in us by sharing your personal data with us. Focus- Train your Brain takes your privacy seriously and is committed to handling your personal data in a way that is fair and worthy of that trust. Focus - Train your Brain will take all reasonable steps to protect your information from misuse and keep it secure.

We believe it is important to inform you about how we will use your personal data. Therefore, we encourage you to read this privacy policy carefully.

DATA WE COLLECT

If you do create an Account, we ask for certain information to process your registration, including an email address and password. If you subscribe to a paid Account, we request additional information, including your full name and payment method details.
We may also collect (1) name, (2) gender, (3) date of birth, (4) education level, (5) other demographic information, and (6) other information you voluntarily provide to us. Providing most of this information is optional. We also allow you select your preferences for training, language, and receiving email communications.

Information that is Passively or Automatically Collected

In addition to the information you provide directly to us, when you use Focus - Train your Brain, we automatically collect information about the computer, mobile device, or other devices you use to access Focus - Train your Brain and about how you use Focus - Train your Brain. For example, we receive data about the games you play and your performance in those games. We also receive information such as your browser type, IP address, language, the type of device you use, operating system version, unique device identifier ("UDID"), the date and time of your visit and files you viewed on our site (e.g., HTML pages, graphics, etc.), Internet service provider, clickstream data, the pages you view and the websites you visited immediately before and after visiting Focus - Train your Brain. In some cases, we link this automatically collected data to other information we collect about you. We do this to improve the services and marketing we offer you.

Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access Focus - Train your Brain. As described further below, we may collect and analyze information such as IP addresses, geolocation information (including general location inferred from IP addresses), unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed Focus - Train your Brain; and information related to the ways in which you interact with Focus - Train your Brain, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of Focus - Train your Brain, the amount of time spent on particular pages, the date and time you used Focus - Train your Brain, the frequency of your use of Focus - Train your Brain, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and Other Electronic Technology

Like many other companies, we and third parties that we work with use cookies and other web and mobile tracking technologies, like HTML5, web beacons, scripts, pixels, server logs, and tags. We use these technologies for authentication, to store your preferences or progress, for analytics, and to help us advertise Focus - Train your Brain. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of Focus - Train your Brain you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of Focus - Train your Brain and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods.

Information Provided by Social Networking Services and Others

We may supplement the information you provide to us with additional information gathered from other sources, such as publicly available information, or from third parties, such as marketers, partners, researchers and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other product or service we provide.
If you sign in to Focus - Train your Brain using your Facebook or other third party credentials, we will use that service to authenticate you. We may also receive other information that you have agreed may be provided by that third party, such as your username, name, e-mail address, photo, location, date of birth, gender, an ID associated with the applicable third party platform, user files like photos and videos, your list of friends, people you follow and/or who follow you, and/or your posts or "likes." We receive this information so that it can be used for the purposes explained in this Privacy Policy. If you do not wish to have this information shared by these third parties, do not use Facebook or another third party to access Focus - Train your Brain. We may also collect other information through other social networks that you make available to us. For a description on how social networking and other third party sites handle and share your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. We may combine information that we collect from or about you with information about you that we obtain from such social media and other content platforms and information derived from any other subscription, product, or service we provide.

Legal Bases For Use Of Your Personal Data

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them. For example, we handle personal data on this basis for our premium users.

Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent. Where you have provided consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing your consent. To withdraw your consent, please contact us at hello@tellmewow.com

No Disclosure to Third Parties for Their Own Marketing Purposes

We believe in protecting your privacy, and therefore do not provide your personal data to third parties for their own marketing purposes.

When We Share Your Personal Information With Third Parties

We may share the categories of personal information for business purposes (as defined by applicable law) or as required by applicable law. More specifically, we may share your personal information in the following situations:

Service providers and agents

We may share your information with certain third parties selected by us to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer support requests. In addition, we may share limited personal data to third parties that help us market or advertise Focus - Train your Brain. These third parties may have access to your information only for purposes of performing these tasks on our behalf and we contractually require them to protect your information consistent with this Privacy Policy.

Business transfers

We may sell, transfer, or otherwise share some or all of our assets in connection with an actual or contemplated merger, reorganization, business transaction, or in the event of bankruptcy. In such scenarios, your information may be one of the assets transferred. We will post a notice or otherwise notify you and collect your consent, as may be required by law, before the information is transferred and becomes subject to a different privacy policy.

Compliance with law and law enforcement requests, and protection of our rights.

We may disclose your information when we have a good faith belief we are required to do so by law, or in response to a court order, or other legal mechanism. We may also disclose your information when we have a good faith belief that disclosure may prevent fraud and abuse of Focus - Train your Brain or its users or protect our property rights.

Consent

We may disclose your information when we believe we have your consent to do so, such as when you contact customer support and ask us about your Account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your Account. If you have expressly agreed to participate in a research study with us or with a third party that incorporates your personal data collected by Focus - Train your Brain, we also may disclose your information for the purpose of facilitating the research to which you have consented.

Online Analytics

We may use third-party web analytics services on Focus - Train your Brain, such as those of Google Analytics. These service providers use technology to help us analyze how users use Focus - Train your Brain, including by noting the third-party website from which you arrive, how often you use our app, the events that occur within our app, where the app was downloaded from, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of Focus - Train your Brain. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

Data Subject Rights And Your Choices

Account Review
You may access, review, correct, and delete certain of your personal data by logging into your Account.

Your Legal Rights
In addition, individuals in the European Union and some other jurisdictions outside the United States have certain legal rights to request that we:

confirm whether we hold personal data about them,

provide access to personal data we hold about them (including, in some cases, in portable form),

update, amend and/or correct personal data we hold;

delete certain personal data in appropriate circumstances;

transfer personal data to a third party provider of services;

To exercise any of the above rights (or any other rights under applicable law), please contact us via email: hello@tellmewow.com.
In addition, individuals in the European Union and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data or exercise legal rights to withdraw consent, though such actions typically will not have retroactive effect. To exercise any of the above rights (or any other rights under applicable law), please contact us via email: hello@tellmewow.com.
The rights described herein are subject to limitations and exceptions under applicable law. In situations in which we process personal data on behalf of our research partners, we may refer the request to the relevant research partner and cooperate with their handling of the request, subject to any special contractual arrangement with that research partner.
In addition to the rights above, residents of the European Economic Area also have the right to lodge a complaint with your relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.
Marketing
You can opt out of receiving marketing emails by following the unsubscribe instructions included in each email. Please note you may not opt out of certain transactional emails, such as when we email you to confirm transactions, address Account issues, or communicate about customer support.
Push Notifications
From time to time, we use push notifications in our mobile applications to send you messages about Focus - Train your Brain or your Account. You may opt out from receiving push notifications through your device settings.

Retention Of Personal Data And Security

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Children

Focus - Train your Brain is not directed to individuals under 13 years old. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13, children under the age of 14 in Spain or South Korea, or from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as required by law. As appropriate under applicable law, parents or legal guardians with questions or requests regarding their children’s personal data may contact at hello@tellmewow.com

Change Policy

This Privacy Policy may be updated from time to time. If we make material changes, we will provide notice to you either by email, by posting a notification on Focus - Train your Brain or by posting an updated privacy policy on Focus - Train your Brain 45 days in advance of the effective date of the updated Privacy Policy. Please note that, for existing users, unless otherwise provided by applicable law, your continued use of Focus - Train your Brain following the effective date means that you agree with, and consent to be bound by, the updated Privacy Policy.

Contact Information

We welcome inquiries or comments about our Privacy Policy via email: hello@tellmewow.com. You may also send a letter to the following address:

Tellmewow Studios, S.L.

Alameda Mazarredo 69, 3ª planta

48009 Bilbao

Spain