NoteIt Privacy Policy

Effective Date: July 14, 2023

Brainiac Labs Inc (“Brainiac Labs”, “we” or “us”. For personal information protection related issues, please contact us atlegalnotice@brainiac.so”) places great importance on and is committed to protecting the security of personal information and data of users  (“user” or “you”) who use NoteIt App, products and services (collectively, the “Services”). We may collect, use, store and disclose your personal information and data in your use of the Services. Therefore, we have established the NoteIt Privacy Policy (“Policy”). We promise to use commercially reasonable best efforts to protect your personal information and data by taking appropriate security measures in accordance with mature industry security standards.

Please see below to learn more about how we collect, use, and protect your personal information and data. We encourage you to read this Policy carefully and confirm that you fully understand this Policy (especially the contents in bolded, italicized, underlined texts, etc.) before your use of the Services and to make the choices you deem as appropriate. By clicking “Agree/Continue/Next” and etc. to continue using the Services, you agree that you have read and accepted this Policy and that we may collect, use, store, manage and disclose your personal information and data in compliance with any applicable laws and this Policy. We may amend this Policy from time to time, and such amendments shall constitute an integral part of this Policy with the same legal effect. Please read the amended Policy carefully. If you continue to use our Services after this Policy has been amended, it means that you have fully read, understood and accepted the amended Policy and are willing to be bound by it. If you do not accept this Policy or any amendments hereto made by us, you should immediately stop your use of the Services.

If you are under the age of majority as defined by applicable local law (“Minors”), please read this Policy with your parent or other guardian, and pay special attention to the terms and conditions regarding the Minors.

Capitalized terms used but not defined herein shall have the meanings given to them in the NoteIt Terms of Service.

This Policy includes the following:

I.        How We Collect and Use Personal Information

II.      How We Store and Protect Personal Information

III.     How We Entrust the Processing, Share, Transfer and Publicly Disclose Personal Information

IV.    Information Collected by Third-Party Services

V.      Your Rights

VI.    Protection of Minors

VII.   Notices and Amendments

VIII. Contact Us

IX.    Other

 

I.        How We Collect and Use Personal Information

We collect and use your personal information for the purposes, in the manner and within the scope of this Policy in accordance with the principles of lawfulness, legitimacy and necessity. If we intend to use your personal information for purposes other than those set out in this Policy, or to use your personal information for purposes other than those for which such information was collected, we will obtain your separate consent by page pop-ups, interactions, announcements or other reasonable means. Once you have consented to the additional purposes, such purposes will be considered as a part of this Policy, and this Policy will also apply to the additional processing of the personal information.

1.     Methods of Collecting and Using Personal Information

(1)     Information that you voluntarily provide. For example: information that you provide to us when you register for a Brainiac Labs account, or log in to and use the Services through your Brainiac Labs account; information that you upload and post publicly in your use of the Services; information stored by you in your use of the Services; information shared by you with third parties through the Services, etc.

Please note that if you publicly post, share or transmit personal information or other sensitive personal information to any other third party in your use of the Services, you should ensure that such information is in compliance with laws, regulations, and other applicable rules, and cautiously consider whether to post such information or not. You expressly understand that any information publicly posted, shared or transmitted through the aforementioned channels may be accessed by other third parties. Your public posting, sharing or transmission of any information shall constitute your consent to make such information publicly available. Please do not publicly post, share or transmit any information that you do not want any other third parties to know. You shall be solely responsible for the above acts. Brainiac Labs does not assume any responsibility or liability for any public disclosure or use of any personal information that you choose to publicly post, disclose, share, or transmit.

(2)     Information that we obtain from you. For example, log information, location information, device information that we collect and record in your use of the Services.

(3)     Information that are shared to us by third parties. We collect your information from third parties where we have obtained your consent, or where we are not required to obtain your consent under the exemptions stipulated by applicable laws or regulations.

2.     Purposes of Collecting and Using Personal Information

(1)     Register and Log Into an Account

In order to register and log into your Brainiac Labs account, we need to collect your email address. If you do not provide this information, you will not be able to register, log into your account or use any functions of the Services.

After registration, you can log into your Brainiac Labs account with your email address and choose whether to submit your account name, avatar, password. We will not force you to provide such information.

When you register and create a Brainiac Labs account, we will send an email to you to verify that your identity is valid. If you forget your password, the email address that you provided in your profile will be used as the tool to verify your identity to retrieve your password. To better protect the security of your Brainiac Labs account, if you change your usual email address, we recommend that you update the email address in your profile in a timely manner. During the process of identity verification and security verification, we will send a notice (e.g., verification codes, etc.) to the email address that you provided during registration and login process to complete the verification.

You may also sign in to and use the Services with a third-party account (e.g., Apple ID and Google ID). If you choose to sign in through a third-party account, in order to verify your account and enable you to sign in to and use the Services, we will collect your account name and avatar with your consent and in accordance with this Policy and the privacy policy applicable to such third-party account (e.g., Apple Privacy Policy (https://www.apple.com/legal/privacy/en-ww/), Google Privacy Policy (https://policies.google.com/privacy?hl=en-US)).

(2)     Maintain Proper Operation of Basic Functions

l  Log data. When you use the Services, we collect log data to understand how you and others access and use the Services, as well as to collect information about your actions (including, without limitation, the creation and sharing of notes, the number of notes and the number of words, the number and size of images, audio and other files contained in notes, etc.). The data collected by us also includes tracking pixels and similar analysis techniques. Such information will help us to understand how you use the Services so we can provide you with better services.

l  Device operating system information. For purpose of product optimization and monitoring key functions' operation, we collect information about the number and type of devices that you use to connect to the Services and the information about the operating systems (e.g., iOS, Android, etc.) on such devices to ensure that the Services meet your needs. Upon your authorization, we will collect and use your information through your device access permission. You may choose to turn off some or all of these permissions at any time in the device's settings, thereby denying our further collection and use of the corresponding information

¡  If you use the Services on an Android device, we may collect your Android ID in your use of the Services or when the application runs in the background to maintain the normal operation of basic functions and track and record your actions in the use of the Services.

¡  If you sign in to the Services by using Google play, we will collect your device account data through the relevant third-party SDK (please see the “Information Collected by Third-Party Services” section below) and obtain the permission named “GET_ACCOUNTS” on your device.

l  When you use certain recognition function of the Services, we will collect and store the picture, text and voice information that you upload, and our relevant recognition program will process and analyze the data and return the corresponding text results;

l  Sharing Information. When you use the sharing function of the Services (such as sharing to emails, albums, or by systems), we will collect information regarding such sharing, including, without limitation, the time of sharing, the number of sharing, the platform where the contents are shared, your account name and avatar, the amount and size of the shared contents, etc. to help us understand how you use the sharing function and to provide you with better user experience. Meanwhile, we will check whether the shared contents are in compliance with relevant laws and regulations.

Please note that the above-mentioned information used to maintain the normal operation of the basic functions is the information which cannot be used to identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will de-identify such personal information unless we obtain your consent or otherwise permitted by laws or regulations. During the period of combined use, the above information will be treated and protected as your personal information in accordance with this Policy.

(3)     Help to Complete Your Order, Payment and Our Delivery of Services

l  When you purchase a specific service in the Services, we will generate an order for your purchase of such service through our system. During the order process, you will be required to provide at least your account number, payment status, etc. If you refuse to provide such information, we will not be able to complete the delivery of the relevant service.

l  In order to display the transaction information of your account and to ensure the transaction security, we will collect the information generated in your use of the Services (such as your purchased service information, order number, order generation time, transaction amount, invoice information, payment account information, etc.) to show you the order information and facilitate your management of orders.

(4)     When You Use Certain Service, You may be Required to Invoke Specific Access Permissions in Your Device to Enable the Collection and Use of the Required Information. Such Services Include, Without Limitation the Following:

l  We may access your camera so that you can take pictures, which allows you to upload pictures, use text recognition services, etc.

l  We may access your albums so that you can access and upload photos and pictures from your device, which allows you to change your avatar, insert pictures in your notes, create picture notes and use text recognition services functions, etc;

l  We may access your microphone to enable you to create voice notes or use the voice transcription function. We will collect the content of your recording to identify your specific needs;

l  We may access your photos, media content, files, etc., after you authorize us to invoke the storage permission in your device, which makes it easier for you to share and store your notes at any time;

l  We also employ some technologies to help you get the most out of the Services, improve our Services and enhance your user experience of the Services. Our systems automatically analyze your data to improve certain functions unique to the NoteIt App. Such collection and analysis are performed automatically by the system and are not viewed by any Brainiac Labs's personnel (except for troubleshooting purposes and for providing user support). We do not collect, analyze, or disclose any content to any third party for promotional purpose. Features and scenarios relating to this include “Search” function. When you search in the Services, this function will make it easy for you to find the information that you need.

When you need to turn off any permission, most mobile devices will support your request. Please consult or contact with the service provider or manufacturer of your mobile device for details. When you turn on a permission, you authorize us to collect and use the relevant personal information to provide you with the relevant services; when you turn off a permission, you cancel the relevant authorization and we will no longer collect or use the personal information based on such permission or provide you with the services relevant to such permission. Please note that your decision and action to turn off any permission will not affect our collection and use of personal information that have been carried out based on your earlier consent.

(5)     Your Personal Information that We Collect Indirectly

If you create, bind or sign in to your Brainiac Labs account through a third-party account (e.g., Apple ID, Google ID) to sign in to and use the Services, we will collect third-party account information (e.g., avatar, account name, email address, etc.) that is authorized by you to be shared, and we may use such third-party account information as Brainiac Labs account information. If you use third-party App or services authorized by Brainiac Labs through the Services, we or the relevant third party may send you emails or read the emails that you receive.

(6)     Provide Security and Compliance Management

In order to improve the security of your use of the Services, protect the personal safety and property safety of you or other users from damage, better prevent phishing sites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks, we may collect, use or integrate your Account Information, transaction information, device information, log information, as well as the personal information shared by our affiliates or partners upon your authorization or in accordance with the law, to verify identity, detect and prevent security incidents, and to take necessary recording, auditing, analysis and disposal measures in accordance with the law.

In order to protect your account and the functionality of the Services, our systems may analyze the emails that you send and receive from your Brainiac Labs account and the notes that you share, to detect spam, malicious emails or other potential security concerns. If we determine that any content constitutes a violation of the NoteIt Terms of Service, we may block the transmission or prohibit the sharing of such content in accordance with the spam filter feature in your inbox.

In order to provide troubleshooting, compliance management and customer support, we may need to access some of your information, such as the email address of your account, the third-party account associated with your account and information about your use of the Services.

When you share your Contents on the Services with your contacts in third-party account, you expressly agree that we will review the Contents shared by you through automated system review and necessary manual review, to implement the compliance management of sharing service required by relevant laws, regulations and policies.

You understand and agree that, after collecting your personal information, we will de-identify the data through technical means, and the de-identified personal information will not be able to be used to identify your identity, in which case we will have the right to use such de-identified personal information to analyze and use such user data for legitimate commercial use.

(7)     Reminder for Sensitive Personal Information

The information that you provide voluntarily or we collect from you may contain your sensitive personal information. Please provide your sensitive personal information with caution. We process sensitive personal information only for providing the Services and under the exemptions stipulated by applicable law.

 

II.      How We Store and Protect Personal Information

As a global company, our engineering, technical, and other support teams are based in our offices around the world (including China), which may access the data (including personal information) collected and generated in the use of the Services from time to time. The data (including personal information) collected and generated in the use of the Services will be stored within the United States and may be transmitted to China. We are committed to protecting the security of your information and take reasonable precautions to do so. We adopt standard Internet industry practices to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss. We will take all reasonably practicable measures to protect your personal information.

1.     Technical Measures

(1)  Our Internet services employ industry-standard encryption technology to protect your data in transit, which is commonly referred to as Transport Layer Security (“TLS”) technology or Secure Sockets Layer (“SSL”) technology, to provide browsing services through https or other means to ensure the security of user data in transit. However, the Internet data transmission cannot be guaranteed to be 100% secure, and we cannot guarantee the absolute security of information in transit between you and us; therefore, please understand that due to technical limitations and the possibility of various malicious attacks, it is not always possible to guarantee 100% security of information in the Internet industry. You should be aware that the systems and communication networks that you use to access our Services may have problems due to factors beyond our control.

(2)  Once we receive your data, we will secure it on our servers through a combination of administrative, physical and logical security measures.

(3)  We adopt various data desensitization technologies, including content replacement and encryption desensitization, to enhance the security of personal information in use.

(4)  We establish a strict data use and access system and adopt strict data access rights control and multiple identity authentication technologies to protect personal information and avoid unauthorized use of data.

(5)  We adopt specialized data and technical security audits, take various measures including log audits and behavioral audits.

(6)  Our automated systems analyze the emails sent or received from your Brainiac Labs account which is used for the login and use of the Services, to detect spam, malware or other potential security issues and behaviors that may affect email delivery to protect your account and the functionality of the Service.

2.     Management Measures

(1)  We will only retain your personal information for the period necessary to achieve the purposes set forth in this Policy. However, we may extend such retention period to comply with applicable laws and regulations, court decisions or rulings and requirements of other authorities and to protect the public interests.

(2)  We have established internal systems such as data security management norms and data security development norms to manage and regulate the storage and use of personal information.

(3)  We strengthen security awareness education. We hold security and privacy training from time to time to enhance the awareness of employees of the importance of protecting personal information.

(4)  If we need to transfer the relevant users' personal information that we collect within the relevant jurisdiction to an organization located outside of such jurisdiction, we will comply with the applicable laws on the transfer of personal data across countries/regions to ensure that the user data is protected.

3.     Handling of Personal Information Security Incidents

(1)  In the event of a personal information security incident, we will, in accordance with the requirements of laws and regulations and taking into account the actual situation, promptly inform you of the basic information and possible impact of the security incident, the disposal measures we have taken or plan to take, the suggestions for you to prevent and reduce risks, the remedial measures for you, etc. by sending emails and/or push notification; meanwhile, we will also report the disposal of personal information security incidents in accordance with the requirements of regulatory authorities.

(2)  We will send notices to all users to remind them to change the password. We will promptly inform you of the relevant situation by email, push notification, etc. In cases where it is difficult to notify all subjects of personal information one by one, we will make announcements to avoid further data leakage in a reasonable and effective way.

It is important to note that, despite having taken reasonable and effective measures as described above and having complied with the standards required by the relevant laws, we still cannot guarantee the security of your personal information when it is exchanged through insecure channels. For example, the security of information stored in the Services depends on your use of security functions of your device. Therefore, we recommend that you take appropriate measures to ensure the security of your device that are used to use the Services, such as changing your account password periodically, not using the same password as for other services, and not disclosing your personal information (such as your account password, especially sensitive personal information) to others.

You understand and agree that the personal information protection measures that we provide under this section apply only to the Services, and that once you leave the Services to browse or use other websites, services and content resources, we have no ability or obligation to protect any personal information that you use or provide in any network environment outside of the Services, regardless of whether the network resources you log in to or browse are accessed through our links or guidance.

 

III.    How We Entrust the Processing, Share, Transfer and Publicly Disclose Personal Information

1.     Personal Information We may Entrust to Process

We will anonymize your personal information before we entrust it for processing. For companies, organizations and individuals entrusted by us to process personal information, we will enter into strict confidentiality agreements with them, obligating them to process personal information in accordance with our requirements, this Policy and other relevant confidentiality and security measures.

For example, when we need to send you email notifications, we may entrust a push notification service provider to use your email address for sending you email notifications. In order to provide the Services, complete payment transactions, and fulfill your service requests (including sales, delivery and after-sales service), we may share your information with third-party service providers who process data on our behalf. These service providers will use your personal information only to the extent necessary to provide the Services.

2.     Personal Information We may Share

By using the Services, you allow us to record and use your relevant information (within the scope permitted by applicable laws, regulations and this Policy) for providing the Services. We will keep the information strictly confidential. We will not share such information with others, or sell, rent, or otherwise distribute it to others (except to the extent disclosed in accordance with this Policy). However, Brainiac Labs may share your information with external parties under the following circumstances:

(1)  When you use the sharing functions of the Services to share the Content stored in the Services with others, certain personal information that you provide to Brainiac Labs may be visible to other users. Such circumstances include, but are not limited to the following:

(a)  If you share a note, anyone who has access to such note will be able to see your user profile (if you have not added any profile information, you will only be identified by the email address associated with your Brainiac Labs account);

(b)  In addition, anyone who has access to a shared note will be able to see the content of the note, the note's creation location and time, relevant note history, tags, and reminders associated with the note, and to further share the shared content with others.

Please note that, for personal information related to the sharing function, if you do not actively delete such information, it may remain available in the public domain; even if you delete such information, such information may still be cached, copied, stored or kept in the public domain by other users or third parties which are not under the control of Brainiac Labs. Brainiac Labs is not responsible for the leakage of your personal information which results from any public disclosure or sharing of your personal information conducted by you through such public channels. Therefore, Brainiac Labs reminds and requests you to carefully consider whether to publicly disclose or share your personal information through the above channels.

(2)  In cases where you specifically request information from Brainiac Labs's business partners, the identity of the personal information collector and the applicable privacy statement will be clearly indicated at the time of information collection.

(3)  You have an online or offline (non-Internet) relationship with one of our affiliates or partners (and we have certain relationship with such affiliate or partner), or have visited that affiliate's or partner's website that links to or refers to the NoteIt App, and have registered for the Services through the procedures or website of such affiliate or partner.

3.     Personal Information that We may Transfer

We will not transfer your personal information to any company, organization or individual, except under the following circumstances:

(1)  With your explicit consent: we will transfer your personal information to other parties if you provide us with explicit consent to do so;

(2)  In the event of a merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to be bound by this Policy, or we will require such company or organization to reobtain your consent.

4.     Personal Information that We may Disclose Publicly

We will only disclose your personal information publicly under the following circumstances with the implementation of industry-standard security measures:

1.    If the information is specified by you and is disclosed in the manner of disclosure which you have expressly consented to, in accordance with your request;

2.    If we determine that you have committed a violation of law or regulation or have materially violated the NoteIt Terms of Service, it is necessary to disclose some of your information in order to investigate and/or disclose such violations or to implement the NoteIt Terms of Service;

3.    In accordance with legal requirements, mandatory administrative enforcement, or judicial requests, we may disclose your information if it is necessary to comply with such requests. Such disclosure will be made in accordance with the requested information types and disclosure methods. Subject to laws and regulations, when we receive a request for disclosure of information as above, we will require the recipient to present the appropriate legal documents such as subpoenas, letters of inquiry, etc. We firmly believe that the information that we are requested to provide should be as transparent as possible to the extent permitted by law. We will carefully review all requests to ensure that they have legal basis and are limited to the data that the law enforcement agencies have a legitimate right to access for specific investigative purpose.

4.    We may disclose your personal information to defend against legal claims and to comply with applicable law to protect and defend the rights, interests and safety of Brainiac Labs, its affiliates, users or the public, and the security of the Services.

 

IV.    Information Collected by Third-party Services

The Services may access or link to social media or other services provided by third parties (including websites, products or other services). In order to better provide you with these services, third parties may collect your personal information.

Third-party service providers are responsible for the operation of their services. Your use of such third-party services and any information you provide to such third parties, are governed by those third parties' terms of service and privacy policies (rather than this Policy), so please read the relevant terms of service and privacy policies carefully. This Policy applies only to the personal information collected in the Services. If you discover any risks associated with third-party services, we recommend that you stop using the relevant services to protect your legitimate rights and interests.

The third-party services used in the Services and your personal information collected by third parties are as follows:

 

Type of Third Party

Name of Third Party

Purpose of Use

Collection Method

Type of Personal Information

Privacy Policy of Third Party

Content Sharing Service Provider

Facebook

Allow users to share contents to Facebook

Direct collection by integrated client-side SDK

Device identifiers, device model and screen dimensions, CPU core, storage size, SDK version, OS and app versions, the name of the mobile operator or ISP, language, time zone, and IP address.

https://developers.facebook.com/terms/#privacypolicy

Google Mobile Service Provider

Google

Allow users to use mobile services provided by Google through Android phones

Direct collection by integrated client-side SDK

Device unique identifier, operating system, mobile network information (including carrier name and phone number),  and application version number

https://policies.google.com/privacy?hl=en-US

Mobile Statistics Service Provider

Microsoft

Provide collection service of mobile platform crash log

Direct collection by integrated client-side SDK

Operating system, mobile network information (including carrier name and phone number) and application version number, language and country/region

https://learn.microsoft.com/en-us/Appcenter/sdk/data-collected

Mobile Statistics Service Provider

Countly

Provide statistical services for mobile platforms

Direct collection by integrated client-side SDK

Encrypted user ID, device unique identifier, IDFA or Google Ad ID

https://count.ly/legal/privacy-policy

 

V.      Your rights

You may exercise your right to know, access, correct, delete or appeal for information we have collected about you by submitting a request to us in accordance with the contact details set out in this Policy. You may also directly access, correct your personal information, change the scope of your consent, or close your account through the settings within the NoteIt App.

To protect your legal rights and interests, we may need to verify your identity when you submit a request (e.g., requesting the email address that you used to register your account) to determine your identity and support your request, but we will not place unnecessary or unreasonable conditions or obstacles to your request.

We have designed corresponding settings in the NoteIt App to facilitate your exercise of rights in your use of the Services. You can refer to the following guidelines for operation.

1.     Access and Correct Your Personal Information

In the use of the Services, you can access and correct your account name, avatar, email address in the following way: log in to the NoteIt App - click avatar - click “Settings”.

2.     Delete Your Personal Information

You may choose to no longer use the Services and/or to delete your Contents stored in the Services at any time. If you delete any Contents stored in the Services, you and other individuals who have access to that content will no longer be able to access it.

If you choose not to use the Services anymore and wish to delete the personal information that we have collected about you, please send an email to “legalnotice@brainiac.so”. We will deal with your request within thirty (30) days after verifying your identity.

3.     Change the Scope of Your Consent

Except as otherwise provided herein, you can generally change the scope of your consent to our collection and use of personal information or withdraw your consent, by turning off functions of your device, adjusting the “privacy settings” on your device, etc.

Please note that each service function requires certain basic personal information in order to run properly. If you withdraw your consent, we may not be able to continue providing the services associated with the withdrawn consent. However, the withdrawal of your consent will not affect any personal information processing conducted based on your previous consent.

4.     Close Your Account

You can close your account in the following way: log in to NoteIt App - click your avatar - click “Settings” – click Close Account”.

If you close your Brainiac Labs account, we will cease providing the Services to your account and delete or de-identify the relevant personal information and data. However, please note that due to legal requirements, the operation and continuous data backup and archiving features of electronic devices, residual copies of the content you delete may continue to be retained in the backup and archival systems of the Service for up to one year.

5.     Obtain a Copy of Your Personal Information

You have the right to obtain a copy of your basic personal information and personally identifiable information in accordance with laws and regulations. You can contact us in accordance with the contact details set out in this Policy to request a copy of your personal information.

6.     Other Rights

If you are a California resident and the exemption under California Consumer Privacy Act (“CCPA”) does not apply to you or your personal information, you have the right to:

(1)     Request us to disclose to you free of charge the following information covering the 12 months preceding your request:

l  the categories of personal information about you that we collected;

l  the categories of sources from which the personal information was collected;

l  the purpose for collecting personal information about you;

l  the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

l  the specific pieces of personal information we collected about you;

(2)     Request us to delete personal information we collected from you, unless an exemption applies pursuant to CCPA; and

(3)     Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or deny goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within forty-five (45) days pursuant to the CCPA. If necessary, extensions for an additional forty-five (45) days will be accompanied by an explanation for the delay.

Please note that in order to protect your information, we will need to verify your identity before responding to any request to exercise your rights. In some cases, we may need to collect additional information to verify your identity.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. For requests by an authorized agent, we may require you to directly verify your identity with us, and confirm with us that you provided the authorized agent the permission to submit such requests.

 

VI.    Protection of Minors

Brainiac Labs attaches great importance to the protection of personal information of Minors. If you are a Minor, please use the Services only under the direction, supervision and consent of your parents or other guardians. If you are the guardian of a Minor, you may contact us if you have questions regarding the personal information of the Minor in your custody.

We do not intend to collect personal information from the Minors. The Minors are not allowed to use the Services for any purpose without first obtaining parental or other guardians' consent to this Policy. We do not knowingly collect any personal information from a Minor without the consent of parents or other guardians. If we become aware that personal information has been collected from a Minor without the consent of his/her parents or other guardian, we will delete such information. If you believe that we have collected any personal information from a Minor, please contact us in accordance with the contact details set out in this Policy so that we can promptly investigate and delete such personal information.

 

VII.  Notices and Amendments

You can review this Policy in the following way: log in to NoteIt App - click your avatar - click “Settings” – click “Privacy Policy”. We encourage you to review this Policy each time you use the Services.

This Policy may be amended or updated from time to time, and you should review it regularly to understand our practices and procedures for protecting the personal information that we collect. When amendments are made to this Policy, we will notify you in one or more of the following ways as appropriate:

l  Send emails to the email address you associated with your account that you have provided to us;

l  Send you notification of amendments when you log in to the NoteIt App, update the App version, or in your use of the Services, etc.

For significant changes, we will also provide more prominent notice (including sending notifications via email for certain services describing the changes to this Policy in detail). Significant changes of this Policy include, but are not limited to:

l  Significant changes in our service model, such as the purposes for which personal information is processed, the types of personal information processed, and the methods of using personal information;

l  Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc;

l  Changes in the primary target recipients of personal information sharing, transfer or public disclosure;

l  Significant changes in your rights in the processing of personal information and how you exercise those rights;

l  Changes in the department responsible for the security of personal information, our contact information and complaint channels;

l  Personal information security impact assessment report indicates high risks.

You have the right to accept the updated Policy, stop using the Services or close your account, but please note that your actions and activities are still governed by this Policy until you suspend or terminate your use of the Services. If you continue to use the Services, you will be deemed to have accepted the updated Policy.

 

VIII.       Contact Us

If you are unable to fully understand your rights to your personal information in this Policy, or if you have any questions, suggestions or comments regarding this Policy, please contact us at “legalnotice@brainiac.so”.

To ensure the security of your personal information, we may require you to provide a written request or otherwise to prove your identity. Except as otherwise provided herein, in general, we will process your request within fifteen(15) business days after we receive your request and verify your identity or within the period as specified by laws and regulations. In principle, we do not charge a fee for your reasonable requests, but for repeated or excessive requests beyond reasonable limits, we will charge a fee as appropriate. We reserve the right to reject requests that are repeated without cause, require excessive technical means, pose a risk to the legal rights of others or are highly impractical.

 

IX.    Other

External Links

The Services may contain links to third-party websites. Brainiac Labs is not responsible for the privacy policies or practices, information, or content on those websites, products, or services which these links direct to. This Policy applies only to the information collected in the Services and does not apply to third party websites, products or services.