Last updated: 26 February 2019
The Apps are free to download (and contain optional in-game-purchases), and in order to maintain the high-quality training and a great game experience we process information from your game progress and performance, along with any personal information you provide us, to improve the entire experience in the App, to support internal operations and to enable research on cognitive development, rehabilitation and performance.
Collection of information
Information you provide to us
Information we collect automatically through the apps
When you access or use the App, we automatically collect general information about you, including:
- Age, gender and country: we log your age, gender and country as indicated by you in the optional age gate upon creating an account.
- Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times and your IP address.
- Device Information: We collect information about the device you use to access the App, including information about the device’s software and hardware, unique device identifiers (i.e. Device ID and advertising ID), device tokens for push-messages, mobile network information and time zone.
- Usage Information: We collect information relating to your use of the App, including your cognitive performance, cognitive development, game progress, scores and achievements and information you provide regarding feedback, mood, mental state and other questionnaires offered in the apps.
- Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make with real currencies and the reception of virtual goods in-game.
Information we collect from the website
When you access our website, we automatically collect general information about you through cookies and contact forms, including:
- Personal identifiable information: In relation to contact forms, competitions or social media – we may ask for personal information such as name, age, education, place of work and phone number. We do not collect this information without your express consent usually acquired by you providing us with this information yourself
- Use of website: We automatically collect information on how you use our website, the topics that interest you, the pages you visit during your visit and prior to your visit, the type of browser you use and the access times and duration of your visit.
Information we collect from other sources
If you log into the App using a third party site or platform such as Facebook, Apple Game Center and Google Sign-In, we access information about you from that site or platform, such as your screen name, profile information and friend lists, in accordance with the authorization procedures determined by such third party site or platform provided that you have given the third party site in question such consent.
If you log into the App using a third party site or platform, you represent and warrant that (i)) your access and use of such features in connection with the App will comply with the applicable terms and policies of such site or platform; and (ii) that you are over the minimum age limit that is prescribed for such third party site or platform by the legislation in the individual jurisdictions.
Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
Age, gender and country
Are being processed:
- To identify and compare cognitive performance and usage trends related to demographics in order to ensure the best possible training and rehabilitation efficacy and enable accurate scientific conclusions.
Our processing for the above purposes is justified by our legitimate interests in providing relevant cognitive performance progression and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as “the balancing-of-interest rule”) and the article 6(1)(e) of the GDPR (regarding processing related to public interest)
Log-, device-, usage-, and consumption information
Are being processed:
- to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
- to provide and maintain the App, website and the game experience; and
- to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR.
- to analyze cognitive performance and development to support scientific research initiatives and cognitive rehabilitation and training;
Our processing for the above purpose is justified by our legitimate interests in providing relevant cognitive performance progression and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as “the balancing-of-interest rule”) and the article 6(1)(e) of the GDPR (regarding processing related to public interest)
- to provide news and information about the App that we think will be of interest to you;
- to personalize and improve the App and provide tailored content and features;
- to monitor and analyze trends, usage and activities in connection with the App and website;
Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as “the balancing- of-interest rule”).
Information from other sources
Are being processed:
- to provide and deliver the products and services you request and send you related information;
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR.
- to link or combine information we get from others to help understand your needs and provide you with better service; and
- to provide news and information about the App we think will be of interest to you;
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR.
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Storage of information
Brain+ will store your personal data for as long as necessary in order to provide you with the App or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
Sharing of information
We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above):
- Our research partners (see www.brain-plus.com/healthy-brain-project), for the purpose of analysis of cognitive performance and development. We disclose anonymized data about app usage, cognitive performance and cognitive development.
- Should you contact customer support, your information will be shared with Zendesk, with whom Brain+ has a written Data Processor Agreement.
- if you sign up for one of our newsletters, our service provider, MailChimp, with whom Brain+ has a written Data Processor Agreement. MailChimp is based in the USA and in compliance with Privacy Shield.
- Third parties if we are required to disclose your personal data by applicable law, rule, regulation, legal process or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of Brain+ or others;
- Other players in order to provide certain in-app features, such as leaderboards, if you log into the App using a third party service, such as Facebook or Apple Game Center;
- Advertising network companies in order to serve contextual advertisements (the data include your IP-address, Device ID and advertising ID).
In connection with our processing, we use data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers.
The App is for a general audience aged 13 and up. In order to comply with the legislation, you will be presented to an age screen, when creating an account. When presented with this age screen, it is important that you state the correct age or, in case of children, you ensure that you have consent from the holder of parental responsibility.
Based on your age information and your device settings, Brain+ does not process personal data of children under the minimum age limit for behavioral advertisement. If such personal data have been processed without Brain+’s knowledge, Brian+ will, after having become aware of the incident, immediately take reasonable measures to stop such processing and promptly delete any such data from Brain+’s records.
If you have additional questions about brain+’s privacy practices related to children under the applicable minimum age, please contact us at firstname.lastname@example.org.
Transfer to third countries
In connection with the processing, we will in certain circumstances transfer your personal data to recipients in the U.S which has been declared an unsafe third country by the European Commission.
Consequently, the transfers will only occur based on the following safeguards:
- If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework (“Privacy Shield”) (you can view the entities certified under Privacy Shield at www.privacyshield.gov), or
- If we have entered into standard data protection clauses adopted by the Commission with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting Brain+).
Brain+ takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
If you wish to use any of the rights described below, you may contact us at any time by emailing us at email@example.com.
We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.
Right to request access
You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:
- the purposes of the processing
- the categories of personal data concerned
- the recipients or categories of recipient to whom the personal data have been or will be disclosed
- the envisaged period for which the personal data will be stored
Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.
The right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data by Brain+ for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Please note that if you exercise this right, your user license to use the app will cease automatically
Right to rectification and erasure
You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
- If you have withdrawn your consent and there are no other legal grounds for the processing,
- If you have objected to the processing and there are no overriding legitimate grounds for the processing,
- The personal data have to be erased for compliance with a legal obligation in Union or Member State law,
- The personal data have been unlawfully processed or
- The personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims or if the data is necessary for the performance of a task carried out for reasons of public interest.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest. Please note that if you exercise this right, your user license to use the App will cease automatically.
The right to withdraw consent
If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.
Please note that if you withdraw your consent, your user license to use the App will cease automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
The right to data portability
You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.
We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.
Contact and complaints
Brain+ has the following contact information:
Address: Njalsgade 76, 3rd Floor, 2300 Copenhagen S, Denmark
If you wish to make a complaint over the processing of your personal data, you have the right to lodge a complaint to the relevant supervisory authority.
 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data