Privacy Policy

This notice outlines the basis on which any personal data we collect from you, or that you provide to us, in relation to your use of our IQ Test website, will be processed by us.

Who are we?

WinTech Digital LLC with an office located at 112 S. French Street, Suite 105, Wilmington, DE 19801, USA.
WTech Europe Limited with an office located at Villa Malitah, Mediterranean Street, The Village St. Julian’s STJ 1870 Malta
Ruby Labs ltd with an office located at 65 Compton Street, London, EC1V 0BN, UK

In this privacy notice, references to "we", "our", or "us" refer to Cerebrum.

For personal data collected from individuals in the European Union, United Kingdom, and Switzerland, we act as the controller of your personal data. This means that we are responsible for how we collect, store, and use your personal data. For personal data collected from residents in California, we serve as the business regarding your personal data. Accordingly, we decide the purposes and means of processing your personal data. “Personal data,” as utilized in this notice, is defined according to data protection laws and may also be referred to as “personal information” or “personally identifiable information.”

Should you have any inquiries regarding this privacy notice, or if you are a resident of Nevada or California seeking additional disclosures, please contact us using the details provided below.

Who does this privacy notice apply to?

This privacy notice applies to all users of Cerebrum. It does not form part of any contract to provide services. By using Cerebrum, you agree to this Privacy Policy. If you do not agree with our collection, use, and disclosure practices as described in this notice, please discontinue use of our services.

Given your specifications about the type of information collected from users, here's a refined section that more accurately describes data collection practices for Cerebrum:

Personal Data We Collect

Information you give us when registering with Cerebrum:

When you register on Cerebrum, we collect minimal essential information from you to create a personalized experience. This includes your first name and surname, which are used to generate your personalized certificate and report. Additionally, we require your email address to send you login credentials, ensuring you can access our services promptly. For your security and ease of access, your password is randomly generated and sent to you; we recommend changing it upon your first login for added security.

You will have the option to opt-in to receive communications from Cerebrum. Should you decide to opt-out of these communications at any time, you can easily do so by following the unsubscribe link provided in our emails or by contacting us directly to adjust your preferences.

Other information you provide to us:

If you reach out to our customer service with a query, we will collect your email address and any other information you provide during the interaction. Your proactive participation in communication channels like support or chat functions will involve the collection of the personal data you share.

Information we collect about you automatically as you use Cerebrum:

As you interact with Cerebrum, we automatically collect data concerning your access and usage. This includes technical information like your IP address, browser type, and version, which helps us improve your experience and ensure our service operates effectively on your device.

By engaging with Cerebrum, you entrust us with certain personal data to enhance your experience. It's our highest priority to protect and use this data responsibly, in line with this privacy policy.

Adapting the section about information collection by third parties for Cerebrum, while focusing on the website context rather than an app, would look like this:

Information Collected Automatically by Third Parties

On Cerebrum, third-party Software Development Kits (SDKs) and services from our website providers collect certain types of information instead of us directly. This includes:

Identifiers: Such as user IDs and device IDs to distinguish individual visitors and their devices.
Usage Data: Details about your interactions with Cerebrum, helping us understand user preferences and behavior.
Diagnostics: Information like crash logs, which helps with improving the stability and performance of our services.
Contact Information: Including your name and email, which is essential for personalized communication.

This data is shared with third-party services to enable the operation of Cerebrum, facilitate analytics, product personalization, and to conduct efficient marketing campaigns. For specifics on how these third parties utilize your information, we encourage you to review their privacy policies, to which we've provided links.

Analytics and Tracking Providers Include:

Google LLC (Analytics)
Amplitude (Analytics)
Adjust GmbH (Marketing Attribution)
Other third-party services like Braze (Notifications), mParticle (Customer Data Platform), Optimizely (Experimentation), and Firebase by Google LLC (Database and Analytics).

Payment Details

For any in-service purchases on Cerebrum, we rely on third-party payment platforms to ensure the secure and compliant processing and storage of your payment details. These platforms include Stripe, PayPal, and other Payment Card Industry Data Security Standard (PCI DSS) certified processors. We explicitly do not receive, process, or store any of your sensitive payment information directly. All transactions are securely completed through these third-party services, and while we are notified about the transaction's completion, the specifics of your payment information, such as credit card numbers, are securely managed by the payment providers.

Including Stripe and similar platforms emphasizes our commitment to security and the privacy of your financial details. For additional details on how these third-party services use and protect your data, we encourage reviewing their respective privacy policies.

Interactions with Other Services

Cerebrum includes links that hyperlinks to websites, platforms, and other services not operated or controlled by us. We may embed software development kits (SDKs) to enable functionalities such as “liking” or “sharing” content through social media. Additionally, we might offer our content on social media platforms. Any information you provide to us when you engage with our content through social media (such as our brand page or chat functions) will be treated in accordance with this Privacy Notice. Furthermore, if you publicly reference Cerebrum on social media (e.g., by using a hashtag associated with Cerebrum in a tweet or post), we may use your reference on or in connection with our services. It's important to note that when you interact with external services, including upon leaving Cerebrum, those entities may independently collect information about you and may ask for information from you. The collection and storage of your information by these parties are subject to their own policies and practices, including what information they share with us, your rights and choices on their platforms, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Lawful Basis for Processing Personal Data

In alignment with applicable data protection laws, Cerebrum processes your personal data only when there is a lawful basis for its use, or for our business and operational purposes. These bases include: (i) when it is necessary to deliver services under the performance of the contract we have with you; (ii) when required by legal or regulatory obligations; (iii) with your consent; and (iv) when processing is in our legitimate interests, ensuring that such interests do not override your own rights, freedoms, and interests.

The purposes for which we (including our agents, processors, and employees) process your personal data, along with the lawful basis for such processing, are as follows:

Purpose

Our primary aim is to offer engaging and educational IQ testing and brain training services, including a comprehensive IQ test, personalized certificate generation, and access to a variety of brain training sessions aimed at enhancing your IQ level.

Lawful Basis

To deliver IQ testing and brain training services as part of our engagement with you: Necessary for the performance of a contract.
To create, administer, and manage your user account for a seamless experience: Necessary for the performance of a contract.
To verify your purchase and activate your access to our full range of services: Necessary for the performance of a contract.
To address and respond to your inquiries, requests, and feedback regarding our services: Necessary for the performance of a contract when related directly to our services; otherwise, it falls under legitimate interests to ensure your queries are promptly addressed.
To inform you about updates, upgrades, and enhancements to our services and platform, including changes to this privacy policy and any terms of service: Necessary for the performance of a contract.
To utilize information from your social media profiles (with your consent) to enhance your user experience and integration on our platform: Consent.
To conduct market research to better understand preferences and improve our services: Legitimate interests in refining our offerings based on customer insights.
To compile statistics on user engagement and service utilization for analytical purposes: Legitimate interests to gauge and enhance the performance and appeal of our platform and services.
To keep you informed of new features, services, and promotional offers related to our IQ test and brain training services, providing opt-out options for marketing communications: Legitimate interests for related services offers; consent for any broader marketing communications.
To document interactions with customer service for quality improvement purposes: Legitimate interests in ensuring high-quality customer support.
To feature your name, image, or success stories in our marketing material, subject to your express consent: Consent.
To safeguard against fraud, policy violations, and potential threats: Legitimate interests in protecting our services, customers, and assets.
To continuously enhance our web platform, marketing strategies, and overall service offerings based on user feedback and engagement trends: Legitimate interests in providing services that meet and exceed customer expectations.
To send you notifications and alerts via mobile devices, subject to your agreement: Consent.

In addition to the previously mentioned purposes, we will utilize the information we have collected about you to fulfill any other specified aim at your direction or where we have explicitly informed you and obtained your consent. When we permit third parties to collect and use your personal data for analytics and advertising purposes (this may include accessing a unique identifier for advertising on your devices or linking data collected from Cerebrum with other data for advertising reasons), such actions shall only occur with your permission via your device's system settings. You have the opportunity to modify these settings as explained in this notice.

Moreover, we may use information that does not personally identify you (including aggregated or de-identified data) for any purpose, barring any restrictions imposed by applicable law. For details on your rights and choices concerning how we manage information about you, please refer to the “Your rights over your personal data” section within this document.

If You Choose Not to Provide Personal Data

When we indicate that your personal data is necessary to execute a contract with you or to take preparatory steps for such a contract, we require you to provide the requested personal data. Failure to supply this data when requested may result in our inability to communicate, enter into a contract, or fulfill our contractual obligations to you. Should you have any queries regarding the need to provide your personal data, please reach out to us using the contact information provided.

You possess the right under data protection law to withdraw your consent at any time. It's important to note that we cannot delete portions of your profile data upon request; however, you can contact us to request the deletion of your entire profile.

Our platform may offer interactive features such as a chat functionality for providing personalized guidance services. While our specialists may have access to your profile information to tailor their assistance, you are not obliged to provide any additional specific information, even if prompted. The choice of what further information you disclose remains entirely up to you.

Automated Decision-Making and Profiling

We do not engage in automated decision-making using your personal data. Information you provide to Cerebrum is utilized to create a general profile for personalized content delivery. However, this content is intended for entertainment purposes only and should not be relied upon for making critical decisions.

Changing Purposes of Data Use

We commit to using your personal data solely for the purposes outlined herein or for purposes that are compatible with the original intentions. Should there be any change in the purpose for which your personal data is used, this privacy notice will be accordingly updated. For inquiries about how new purposes align with the initial ones, please contact us.

Should we wish to use your personal data for a purpose unrelated to those initially stated, we will directly notify you, providing an explanation of this new purpose and the legal justification for its use.

Data Retention

Your personal data is retained only as long as necessary for the purposes stated in this Notice, including fulfilling our contract with you and enabling your continual use of Cerebrum. Your profile information will remain active until you choose to delete it. Note that unsubscribing from our services or deleting your profile does not automatically trigger a request to unsubscribe.

Following an unsubscribe action, we may keep your personal data for a period to satisfy legal, accounting, and reporting requirements, generally not exceeding six years. In such instances, we will ensure your personal data continues to be treated in accord with this Notice.

Who We Share Your Personal Data With

We share your personal data with personnel who require this information to perform their functions within Cerebrum (such as our team members) and other trusted service providers who support Cerebrum (such as those involved in website infrastructure and customer support services). When we do this, we ensure a contract is in place that obligates them to process your personal data based on our instructions and in compliance with data protection laws.

Your personal data may be disclosed under the following circumstances, but only where we have determined it is permissible under applicable data protection law:

To our professional advisors who require this information to advise us.
To our partners involved in co-branded services, product sales or distribution, or joint marketing efforts.
To law enforcement bodies with a reasonable need to access your personal data.
To potential purchasers of our business or investors.
To our group companies that require access to personal data to assist in Cerebrum service provision.
To defend our legal rights or to protect the rights, property, life, health, security, and safety of our website, its users, or the public.
To comply with your requests for sharing information with another entity.
To enforce our legal rights.

We may also share information, with your notice and consent, that does not personally identify you (including aggregated or de-identified information), except as prohibited by law. For information on your rights and choices regarding how we share your personal data, please see the “Your rights over your personal data” section below.

Sharing Your Personal Data for Analytics and Advertising Purposes

We collaborate with advertising and analytics partners to serve personalised advertisements to you and to understand how users interact with Cerebrum. This involves the use of tracking technologies on our website and in our communications, as well as on advertisements displayed on other websites and services. These technologies may track your activities across different services for the purpose of associating the various devices you use, and delivering Interest-based Advertising to you.

We also employ audience matching services to connect with individuals who have visited Cerebrum or who are identified in our databases (“Matched Ads”). This involves uploading a customer list to a third party or incorporating a third party’s pixel or SDK into Cerebrum, aiding in the matching of common factors between our data and theirs. For example, we might use the Facebook SDK to share your email address with Facebook as part of utilizing Facebook Custom Audiences.

Transfers of Your Personal Data Outside the UK and EEA

For our users in the UK and European Economic Area (EEA), note that your personal data will be transferred outside the UK/EEA to the US. We ensure the protection of your personal data through:

Transfers to jurisdictions recognized by the UK and/or European Commission as having adequate data protection.
Use of standard contractual clauses approved by UK law and/or European Commission decisions.
Transfers to companies with approved binding corporate rules.

How We Keep Your Personal Data Secure

We implement suitable security measures to prevent your personal data from being lost, used, accessed, altered, or disclosed without authorization. Access to your personal data is restricted to those who have a legitimate business need.

Procedures are in place to address any suspected data security breaches, and we will notify you and any applicable regulator of a breach if it poses a risk to you.

Occasionally, we may request proof of identity before disclosing personal data to ensure security.

Your Rights Over Your Personal Data

Data protection legislation affords you a series of rights concerning your personal information that we handle. Although these rights may vary by jurisdiction, if you are in the UK or the EEA, your rights include, but are not limited to:

The right to seek confirmation from us on whether we are processing your personal data and, if so, to obtain a copy of that data.
The right to have inaccurate personal data rectified.
The right to receive your personal data in a structured, commonly used, and machine-readable format, and have this data transferred to another controller.
The right to object to processing based on our legitimate interests. There may be circumstances under which we will continue processing your information, but we will explain these exceptions.
The right to erasure of personal data in specific scenarios, such as when the data is no longer necessary for the purposes it was collected, or your consent is withdrawn.
The right to withdraw consent at any time, for processing based on consent.
The right to understand the logic in automated decision-making processes that significantly affect you.
The right to lodge a complaint with your local data protection authority.

If you are uncertain about your rights or concerned about how your data may be processed, you are welcome to contact us. For residents of California and Nevada, additional disclosures regarding your rights are provided below.

To act upon your rights, you may contact us. Note, while we aim to accommodate requests concerning your rights, they are not absolute. This means there could be circumstances where we may not fulfill your request entirely.

Upon receiving a request regarding your rights, we may require proof of identification and further clarification of your request. Our goal is to respond within one month of verifying your identity. For repetitive or unfounded requests, we reserve the right not to respond.

Additional Rights and Choices

Analytics and Advertising

You have options to control or limit how we and our partners use data for analytics and advertising purposes:

Google Analytics: Google offers tools to opt out of data collection by Google Analytics. More information is available at Google Analytics opt-out and settings for Google ads Ad Settings.
Interest-Based Advertising: You can opt out from receiving targeted ads from participants of the Digital Advertising Alliance (“DAA”) at DAA opt-out and the Network Advertising Initiative (“NAI”) at NAI opt-out.Opting out from these participants means they should no longer deliver specific targeted ads to you, but does not remove all targeted content and/or ads.
Matched Ads: To opt out of us using your data for Matched Ads, please specify your wish to opt out of such ads by contacting us directly.

Please note, opting out through these methods only applies to the specific browser or device from which you opt out. Effectiveness and compliance of these opt-out options or programs are not guaranteed by us.

For any questions or if you wish to exercise any of your rightsmentioned, please contact directly.

Opting out of Promotional Emails

You can opt out of receiving promotional emails from us at any time by following the instructions provided in emails to click on the unsubscribe link. Please note, you cannot opt out of receiving non-promotional emails related to your account, transactions, servicing, or our ongoing business relationship.

Our Policy Toward Children

Cerebrum is intended for a general audience and is not directed at children. We do not knowingly collect personal data from children in violation of applicable laws. Users must be 18 years old or older to use Cerebrum.

If you are a parent or guardian and believe we have collected information in violation of the U.S. Children&'s Privacy Protection Act ("COPPA"), please contact us as detailed below. We will remove the information in accordance with COPPA. Additionally, we do not knowingly "sell" as defined under the CCPA, the personal information of minors under 16 years old who are California residents.

Changes to This Privacy Notice

We routinely review our privacy policy, and future modifications will be posted on this page. We encourage regular review of our privacy policy for any updates or changes. Significant changes will be effectively communicated, possibly including email notification, for material adjustments.

How to Contact Us

For any inquiries about this privacy notice or how we handle your personal data, please reach out to our support team via our Help Centre. We've made efforts to ensure this privacy notice is accessible. If you encounter any difficulties accessing the information, please contact us for assistance.

Additional Disclosures for Nevada Residents

Nevada law provides residents the right to opt out of the sale of certain personal information. If you are a Nevada resident wishing to exercise this right, please contact us through our Help Centre.

Additional Disclosures for California Residents

The CCPA grants California residents additional rights regarding the use of their personal information. Here's a summary:

Notice of Collection: We've outlined the categories of personal information we've collected in the past 12 months and their purposes in the sections above.
Right to Know and Delete: You have the right to know the specifics of personal information collected, used, disclosed, or sold, and the right to request deletion of your personal information.
Right to Opt-Out: If we sell personal information as defined by the CCPA, you have the right to opt out of such sales.
Authorized Agent: California residents can designate an authorized agent to make these requests on their behalf.
Right to Non-Discrimination: Exercising your CCPA rights will not result in discriminatory treatment by us.

Shine the light

California residents may request information once a year about personal information shared for direct marketing purposes.

To exercise these rights, please submit a request through our Help Centre or by contacting us directly. Verification of identity will be required. For requests via authorized agents, written proof of authorization and verification of identity are needed.

For further assistance or to address any concerns, you're encouraged to contact us.