Privacy Policy

Revision Date: 2024/8/20

Effective Date: 2024/8/20

 

We value your ("User", "you" or "your") privacy and recognize the sensitivity of your personal information (Personal Data). We are committed to protecting your Personal Information and using it only as appropriate to provide you with the best services, products and opportunities, as described in this Privacy Policy.

This Privacy Policy explains the online information practices of Improve (collectively, “we”, “us”, or “our”). We believe it is important to explain what information we collect, what we do with it, and describe the rights you have regarding your personal information that we process.

Please note that this Privacy Policy should be read in conjunction with our Terms of Use when using our App. By accessing our App, you acknowledge that the Privacy Policy and Terms of Use govern your use of the App.

Privacy and personal data protection principles vary from country to country. When you visit or browse a third-party website or application, you will be subject to the privacy policy of that website or application. Please read the third-party's privacy policy to determine the privacy practices that apply to the information or data maintained by that website or application.

I. What personal data do we collect and process

When you visit our Platform, you may provide us with the following types of personal data, which we may collect and process in accordance with the Privacy Policy as follows:

(I) Information you provide directly to us:

(1) Identifiers (such as name and email address);

(2) Commercial information (such as transaction data);

(3) Financial data (such as payment information);

(4) Internet or other network or device activity (such as browsing history or application usage);

(5) professional or employment-related data;

(6) Legally protected classifications (e.g., gender);

(7) Medical information (such as information you voluntarily provide to us in a survey);

(8) Physical characteristics or description;

and (9) other information that identifies you or can reasonably be associated with you.

(II) Information we obtain when you use our services:

(1) Corresponding data:

the Platform, when you contact us via the email addresses provided in this Privacy Policy and elsewhere on our website, and any opinions, comments and feedback you choose to provide in connection with the Platform and our services, including any comment facilities and message boards.

(2) Session data:

This includes your IP address, device unique identifier details, browser details (including version, device operating system, geographic location, time zone setting and time/date of access request), amount of data transferred and request provider. We may also capture other information about visits to our Platform, such as pages viewed and traffic patterns.

(3) Cookie data:

small files that are downloaded to your device when you visit our Platform. Most web browsers automatically accept cookies. For more details on our use of cookies, please see paragraph 4 below.

II. How do we use your personal information?

We will use the information we collect to:

(1) Provide, maintain, and improve our services, including debugging to identify and fix errors and developing new products and services;

(2) Processing transactions and fulfilling orders;

(3) send you transactional or relationship messages, such as receipts, account notifications, customer service responses, and other administrative messages;

(4) communicate with you about products, services, and events offered by Brainwaves and others, solicit feedback, and send news, gifts, or other information we think you may find interesting;

(5) monitor and analyze trends, usage, and activities related to our Services;

(6) Detect, investigate and prevent fraudulent transactions and other illegal activities, and protect the rights and property of Improve and others, including enforcing our agreements and policies. If you believe your transaction was rejected in error, please contact us at whaleriver666@outlook.com for assistance;

(7) Comply with laws, such as by processing transaction records for tax reporting and other compliance activities;

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

III. Retention of Personal Data

1. By using our Platform, you consent to us storing your personal data as required by law, regulation, finance and good practice.

2. The period for which we retain your personal data depends on the type of personal data collected, the purpose for which the personal data was collected, the applicable limitation periods for exercising legal rights, and whether there are any legal or regulatory obligations that require the retention of the personal data.

IV. Cookies and Trackers

1. We use cookies and other software development kits ("SDKs") and third-party libraries. Our platform uses the following categories of cookies:

Strictly Necessary Cookies:

Cookies that are necessary for the operation of the Platform. They include, for example, cookies that enable you to load a web page.

Analytical/Performance Cookies:

to our Platform and how they move around it. This helps us to improve the way our Platform works, for example, by ensuring that visitors are finding what they are looking for easily.

Functionality cookies:

These are used to recognise you when you return to our Platforms. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Tracking Device ID:

Each device has a unique tracking ID, which for iOS devices is called the Identifier for Advertising (IDFA). These tracking IDs enable app providers and advertisers to track user activity and serve ads to those users.

2. Please note that third parties (for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

3. You can block cookies by updating the relevant settings on your device or browser to refuse the setting of some or all types of cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our website.

V. Who we share your personal data with

We may need to share your personal data with selected third parties in the following circumstances:

1. Third-party service providers:

This may include certain systems and service providers we use to host, manage and maintain our Platform, such as the servers used to host our Platform.

The following is a list of platforms

(1) Sensors Data SDK

Information obtained and purpose: device information; used to provide data analysis, data-driven, improve product quality, and optimize user experience

Website link: https://manual.sensorsdata.cn/sa/latest/zh_cn/ios-sdk-1573911.html

2. Third-party service providers for marketing purposes:

If you have explicitly consented to any marketing from us, certain personal data may be shared with third-party service providers that we use to help us with marketing, such as third-party marketing automation platforms.

The following is a list of platforms

(1) AppsFlyer, a renowned provider of analytics, segmentation, and mobile measurement services, to gain insights into our user base. AppsFlyer's services facilitate our analysis of how users engage with our app, Improve. This includes tracking the third-party website that directed you to us, monitoring your app usage frequency, capturing in-app events, and identifying the app's download source. These insights enable us to enhance the precision and effectiveness of our advertising campaigns without compromising your personal identity.For a comprehensive understanding of how AppsFlyer conducts its services, kindly refer to this link: https://support.AppsFlyer.com/hc/en-us/articles/21677433322641-Privacy-Manifest. It provides detailed information on data collection, processing, storage practices, and the privacy measures in place to safeguard your information.

3. Comply with legal or regulatory requirements:

We may share your personal data with regulators or law enforcement agencies if we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation.

VI. Third Party Websites

Our Platform may contain links to third-party websites. If you follow a link to a third-party website, please note that this Privacy Policy does not apply to those websites. We are not responsible for the privacy policies or practices of those websites, so please check their policies before submitting any personal data to those websites.

VII. Security

1. We take data security very seriously. We implement and maintain appropriate technical and organizational measures, including resilient security systems and protocols, to protect the personal data we store.

2. We have put in place procedures to deal with any suspected data security breach and will notify you and the applicable regulator of a suspected breach where there is a potential risk to you.

3. Our security procedures mean that we may occasionally request proof of identity before we disclose personal data to you.

VIII. Access to your personal data and your rights

Because we collect and process your personal data, you have the following legal rights:

a. access the personal data we hold about you;

b. If your personal data is inaccurate or incomplete, you can ask us to correct it;

c. to delete your personal data if there is no compelling reason for us to continue processing it in your particular situation;

d. Receive the personal data that you, as a data controller, have provided to us in a structured, commonly used and machine-readable format, the processing of which is based on:

(i) your consent;

(ii) it is necessary for us to perform a contract to which you are a party;

or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;

e. object to or restrict our processing of your personal data in certain circumstances;

f. If we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;

g. If we are using your personal data based on legitimate interests, you may object to us using it for these purposes by explaining your specific situation and we will consider your objection;

h. including profiling, that produces legal effects or is likely to significantly affect you;

i. If we process your personal data with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, or processing of your personal data conducted in reliance on lawful processing bases other than consent. You can do this by contacting us;

j. lodge a complaint with the data protection supervisory authority, currently the Information Commissioner’s Office.

IX. Subscription Service Agreement

1.   Subscription Plans

Improve 's basic version is available for free. To access Improve 's premium features, including (but not limited to) personalized training, access to all games, access to advanced statistics, you must pay through an auto-renewing subscription. Improve's premium features are available for purchase through Apple's App Store. Therefore, when you purchase these features, you are also subject to the App Store 's Terms of Service.

2.   Automatic renewal and cancellation of subscription

Improve is purchased through the App Store auto-renewable subscription, which means that your subscription will automatically renew at the end of the subscription period. However, if you decide not to use our services anymore, you can modify or cancel your subscription at any time by changing the settings by logging into your Apple ID on your Apple device. Before canceling, be sure to understand the policies and possible fees in advance. Please note that you will be automatically charged unless you cancel your subscription 24 hours before the end of the free trial period or the current subscription period. It should be noted that deleting the APP from your device does not mean that your subscription is canceled, and automatic renewal will continue. Cancellation of subscription will take effect at the end of the current subscription period, and users can continue to use premium services during the current subscription period.

more details about managing subscriptions via Apple ID, please refer to:

iOS: https://support.apple.com/kb/HT4098

3. Refund Policy

Your payment is managed by Apple through the App Store and you will need to contact Apple Customer Service for a refund as we are unable to process refunds ourselves.

Please consciously initiate a refund application through legal channels. If you subscribe in an illegal way, or use a subscription method not specified by us, or use loopholes in different channels to maliciously refund, we cannot guarantee that the subscription will be completed smoothly or correctly. If your rights are damaged as a result, we will not make any compensation or compensation. We also reserve the right to terminate your account qualifications at any time, recover the amount paid for illegal subscriptions, and stop providing various services.

If there is no valid evidence, the subscription behavior of underage users will be deemed to have been consented by their legal guardians.

4. Lifetime subscription plan

Improve 's Lifetime Subscription Plan allows you to access the then-currently available premium features of Improve. We make no warranties or representations regarding the expected lifespan of the Improve service, however, by purchasing a Lifetime Plan, you acknowledge and agree that the Improve service may be changed or terminated in the future and, therefore, you may not transfer the Lifetime Subscription Plan to any other person.

5. Data Deletion

When the subscription service expires and you decide not to renew, the service you enjoy will be closed at the same time, and we will delete the relevant data on the cloud server. Please make sure to back up your data in time. We do not assume any responsibility if your data is damaged, lost, or destroyed as a result. Please understand.

X. Our policy regarding children

We do not knowingly collect or solicit any personal data or serve interest-based advertising to children, nor do we knowingly allow children to register for or use the Platform. Children should not use our Platform or send us any personal data about themselves at any time. If we become aware that we have inadvertently collected personal data from a child, we will take reasonable steps to promptly delete such information from our records. If you believe we might have information from or about a child, please contact us.

XI. Contacting us and changing your personal data

If you have any questions or comments about this Privacy Policy or your personal data, or if you wish to exercise any of your rights, including those set out in paragraph 8 above, or if you wish to withdraw your consent (where we have stated that we are processing your personal data based on your consent), please contact us by email at whaleriver666@outlook.com.

XII. Changes to this Privacy Policy

1. Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly for updates or changes to this Privacy Policy.

2. This Privacy Policy was last updated in July 2024.