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Privacy Policy

Last revised 2025-01-10

BrainFreeze is committed to protecting the privacy and security of its visitor’s and User’s (“You” or “Your”) information, including personal data. If You use or access any BrainFreeze Services or websites, or otherwise contact BrainFreeze, You agree to and are subject to this Privacy Policy (“Policy”). For purposes of this Policy, BrainFreeze Services means the BrainFreeze’s software platform, applications, APIs, websites, and other services that may be provided by BrainFreeze. BrainFreeze may update this Policy in its sole discretion, which, with or without direct notice to You, becomes effective immediately upon posting of such updates to BrainFreeze’s website (e.g., at BrainFreeze.co/privacy-policy/). Capitalized terminology used throughout this Policy are defined in this Policy or in BrainFreeze’s Terms, as applicable.

This Policy explains how BrainFreeze accesses, uses, shares, processes, secures, and removes Your personal information through:

  • BrainFreeze Services;
  • BrainFreeze websites, including all websites provided by, operated by, or contributed to by BrainFreeze; and
  • Your contact with BrainFreeze (e.g., directly, indirectly, during visits to BrainFreeze’s premises, when attending BrainFreeze events, etc.).

This Policy also outlines information on the various rights You have under applicable law with respect to your personal information, such as Your right to update, access, or delete Your personal information, as well as object to various use cases involving your personal information. BrainFreeze adheres to relevant child privacy laws, including but not limited to Family Educational Rights and Privacy Act (“FERPA”) and Children’s Online Privacy Protection Act (“COPPA”).

Role of BrainFreeze.

  • BrainFreeze LLC, a Delaware limited liability company, acts as a Data Controller/Business (or other applicable law equivalent). This Policy only relates to BrainFreeze’s processing activities as it relates to BrainFreeze acting as a Data Controller/Business.
    • You can contact BrainFreeze by:
    • If You are a legal entity (e.g., a business, company, non-profit, partnership, etc.), BrainFreeze may process the personal information You provide as a Data Processor/Service Provider (or other applicable law equivalent). In this case, BrainFreeze’s processing activities relating to Your data would be pursuant to the BrainFreeze Terms and Conditions and/or it’s the Data Processing Addendum entered into by You and BrainFreeze.

Information You Provide to BrainFreeze.

Information provided to BrainFreeze.

  • Account and profile information. When You create an BrainFreeze User account, modify Your User profile or account’s group settings, set preferences, or make purchases, BrainFreeze collects the information You provide to BrainFreeze. This may include Your username, password, email, contact and billing information, profile details, preferences, and settings.
  • Content provided through BrainFreeze Services. BrainFreeze accesses and processes any data, content, or code You create, store, send, receive, or share through BrainFreeze Services (including Inputs and Outputs), which may include any information about You that You choose to include. BrainFreeze also collects feedback You provide directly to BrainFreeze or through BrainFreeze Services.
  • Content submitted through BrainFreeze Websites. When You interact with BrainFreeze websites, BrainFreeze collects the content You submit. This may happen when You participate in interactive features (e.g., commenting on blogs), respond to surveys, contests, promotions, or events, fill out forms (e.g., “Contact BrainFreeze” page, request a demo), and subscribe to email lists or notifications. The information collected depends on the nature of the interaction but typically includes Your name, contact details, company information (if applicable), and phone number. BrainFreeze also automatically collects certain information about Your use of BrainFreeze Services (e.g., through cookies and tracking technologies).
  • Information provided through support channels. When You engage with BrainFreeze’s support team (e.g., as an account administrator, by opening a support ticket, or speaking with an BrainFreeze representative), You may be asked to provide contact information, a summary of the problem, documentation, screenshots, or other helpful information.
  • Payment information for BrainFreeze Services. When registering for certain BrainFreeze Services, BrainFreeze may ask You to provide payment and billing information, such as billing representative name and contact information, and payment card details. This information may then be sent to and processed by a secure Third-Party Service provider procured by BrainFreeze solely for the purpose of processing any payments.

Information processed and generated by BrainFreeze Services.

  • Device and connection information. BrainFreeze collects information about the devices You use to access the BrainFreeze Services (e.g., servers, networks, desktops, laptops, tablets, smartphones, telephones), including connection type and device settings, device identifiers, operating system, browser type, IP address, approximate location, URLs of referring/exit pages, and debugging/crash data.
  • Usage log information. BrainFreeze and its Third-Party Services providers use cookies and other tracking technologies (e.g., web beacons, device identifiers, pixels) to provide functionality and recognize You across different BrainFreeze Services, computing devices, and browsers. If You provide personal information to the Services (e.g., as an Input to an AI Component), the usage log information may also include such personal information.
  • Security log information. BrainFreeze also maintains security logs to adhere to our security policies and certifications, which may contain Your activities while using the BrainFreeze Services such as Your account access, changes to configurations and account settings, and possible security-related incidents.

Information obtained from other sources.

  • Information from other Users of BrainFreeze Services. Other Users of BrainFreeze Services may provide information about You through their use of BrainFreeze Services or via contact with BrainFreeze for support purposes. This could include information within data made accessible to BrainFreeze Services, submitting information relating to You in a support ticket, providing Your email address to invite You to BrainFreeze Services, or if You are designated as an administrator or billing contact for BrainFreeze Services.
  • Information from Third-Party Services. When You or Your BrainFreeze account administrator integrate or link a Third-Party Services provider with BrainFreeze Services, BrainFreeze may receive information about You from that provider that you have previously shared with the provider for the purposes of enabling BrainFreeze to perform the requested BrainFreeze Services.

Information not intentionally accessed by BrainFreeze.

  • Personal information. Although BrainFreeze may receive Your personal information through BrainFreeze Services or Third-Party Services providers, BrainFreeze does not intentionally access it.
  • Sensitive personal information. BrainFreeze does not request from You nor purposely accesses “sensitive personal information”, which may include racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data used to uniquely identify a person, health and medical data associated with an individual, or information about a person’s sex life or sexual orientation. You are responsible for complying with any applicable regulatory controls if You choose to submit sensitive personal information to the BrainFreeze Services.
  • Minors. BrainFreeze Services are not intended for users under 13 years of age, and BrainFreeze does not knowingly access information from this age group or direct content specifically to this age group. If BrainFreeze learns or suspects that You or other Users are under 13 years of age, the User’s account will be closed. While BrainFreeze encourages interest in software and artificial intelligence, BrainFreeze must comply with legal age restrictions.

 

How BrainFreeze Uses Your Personal Information.

No selling. BrainFreeze will not sell Your data for any monetary value and will only share your Data as described in this Policy. Because of the broad definition of “sale” under applicable data privacy regulations, however, BrainFreeze may disclose Your personal information with certain vendors and affiliates to provide services on BrainFreeze’s behalf or in the context of a business transfer.

Do Not Track. BrainFreeze follows the processes and responsibilities established in this Policy and does not observe “Do Not Track” requests. You are responsible for selecting your Cookie preferences as described in this Policy, and BrainFreeze will follow Your submitted preferences.

For providing and personalizing BrainFreeze Services. Including: utilizing User information to process transactions, authenticate logins, provide customer support, intake Inputs and generate Outputs, and maintain the BrainFreeze Services; tailoring features to enhance productivity and collaboration by analyzing team activities and providing relevant activity feeds and notifications; inferring organizational or industry affiliations from email domains to personalize content and experiences on BrainFreeze Services; and combining information across multiple BrainFreeze Services or applicable Third-Party Services to offer an integrated experience, such as finding information from one service while searching another or presenting relevant product information as Users navigate BrainFreeze Services.

For conducting research and development. Including: continuously improving BrainFreeze Services by making them smarter, faster, more secure, integrated, and useful to Users; analyzing information and collective learnings (e.g., feedback and surveys) about usage of BrainFreeze Services to troubleshoot issues, identify trends, usage patterns, and areas for integration; developing innovative products, features, and technologies that benefit Users and the public; and testing and analyzing new features with limited Users before making them generally available.

For essential communications about BrainFreeze Services. Including: utilizing contact information to send important transactional communications through email and within BrainFreeze Services, such as confirming purchases, reminding of subscription expirations, responding to comments and requests, providing support, and sending technical notices, updates, security alerts, and administrative messages; and providing onboarding communications to help Users gain access to BrainFreeze Services or become more proficient with a particular BrainFreeze Service (where such onboarding communications are essential to the BrainFreeze Services and generally cannot be opted out of, unless an opt-out option is explicitly provided within the communication or account settings).

For customer support. Including: utilizing User information to resolve technical issues with BrainFreeze Services; responding to requests for assistance; analyzing crash information; and, repairing and improving BrainFreeze Services.

For ensuring safety and security. Including: utilizing user information and data on use of BrainFreeze Services to verify accounts and activity; preventing, detecting, and responding to potential or actual security incidents; and protecting against malicious, deceptive, fraudulent, illegal activity, and violations of BrainFreeze’s Terms and Conditions.

For protecting legitimate business interests and legal rights. Including: where required by law or deemed necessary, utilizing User information in connection with legal claims, enforcing a contract, responding to data subject requests, regulatory compliance, audits, and as necessary for disclosures related to business transactions such as acquisitions, mergers, or asset sales.

For acting with User consent. Including: utilizing User information for specific purposes not listed herein (e.g., such as publishing testimonials, sending marketing materials, or featuring customer stories to promote BrainFreeze Services), but only with Your express consent.

How BrainFreeze Shares Your Information.

Sharing with other Users of BrainFreeze Services.

  • Collaboration settings. You have control over who can view, share, edit, copy, and download the content You create through BrainFreeze Services, which may include personal or sensitive information of You or other individual(s) if such data is submitted by You. Permissions are based on settings selected by You or the administrator of your BrainFreeze account.
  • Managed accounts and administrator access. If You register or access BrainFreeze Services using an email address with a domain owned by Your employer or organization, or associate that email address with Your existing account, certain information about You may become accessible to the organization’s administrator and other Users sharing the same domain, account, or Environment. This information may include Your name, profile picture, contact information, content, and past account usage. If You are an administrator for a specific User group within BrainFreeze Services, Your contact information may be shared with other admin Users to facilitate admin-related requests.
  • Posting on public sites. If You post Your information on public sites (e.g., blogs, forums, or message boards discussing BrainFreeze Services, whether hosted by BrainFreeze or a third-party), Your information may be read, collected, and used by any other User who accesses such public sites. Your posts and profile information may remain on such public sites even after You delete Your account. Carefully consider the sensitivity of any information You share on such public sites. To request removal of Your information from BrainFreeze Services, contact [email protected].

Sharing with Third-Parties.

  • Third-party vendors. BrainFreeze collaborates with Third-Party vendors to offer software and website development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analytics, and other services. Third-Party vendors may require access to User information to perform their services on BrainFreeze’s behalf. When a Third-Party vendor needs to access User information, they do so under strict instructions from BrainFreeze, which include adherence to security and confidentiality requirements designed to protect Your information, with such access being limited to the extent needed for the Third-Party vendor to provide the applicable services. BrainFreeze’s subprocessors are listed in the Terms, as may be updated by BrainFreeze from time to time. BrainFreeze will remain responsible for its Third-Party vendors compliance with this Privacy Policy with respect to the processing of Your personal information.
  • Third-Party Service providers. You, Your account administrator, or other Users may enhance BrainFreeze Services by enabling integrations between BrainFreeze Services and Third-Party Services providers. These integrations may grant Third-Party Services providers access to Your account, information, and content. Third-Party Services providers’ policies and procedures are outside BrainFreeze’s control, and this Policy does not cover how Third-Party Services providers use Your information, which is governed by the policies, terms, and conditions between You and any Third-Party Services provider(s).
  • Compliance with legal obligations and enforcement of BrainFreeze’s rights. In exceptional circumstances, BrainFreeze may share Your information with a third-party if BrainFreeze believes that sharing is reasonably necessary to: respond to lawful requests by public authorities and governments; enforce agreements (e.g., BrainFreeze Terms and Conditions, Privacy Policy, or any other relevant agreement); protect the security or integrity of BrainFreeze Services; protect BrainFreeze, its customers, or the public from harm or illegal activity; respond to an emergency to prevent death or serious bodily injury of any person.

Sharing with BrainFreeze affiliates. In the event of mergers, acquisitions, financing, or sale of company assets, BrainFreeze may transfer User information to another entity. In such event, BrainFreeze will notify Users through BrainFreeze Services, which will specify any User choices regarding their information. BrainFreeze is dedicated to protecting privacy rights and ensuring that Users can make informed decisions about their information in these situations.

How BrainFreeze protects Your information.

Information Security.  BrainFreeze’s robust security safeguards are designed to protect Your information. While no security system can guarantee absolute security, BrainFreeze employs industry-standard administrative, technical, and physical security measures to safeguard the information it accesses and regularly conducts data protection impact assessments to monitor risks. These measures are further outlined in the Terms.  For information relating to data protection impact assessments, please email [email protected].

International Transfers. Depending on Your location and how You use the BrainFreeze Services, your personal information may be transferred internationally. BrainFreeze ensures that all Third-Party vendors have contractual obligations to provide adequate security measures and protection of Your personal information and are compliant with applicable data privacy laws. BrainFreeze utilizes the European Commission’s Standard Contractual Clauses (and the UK addendum) for all international transfers.

Information Retention. BrainFreeze retains information pursuant to the retention periods specified below, after which BrainFreeze will either delete or anonymize the information. If deletion is not possible (e.g., when the information is stored in BrainFreeze’s standard backup and archives), BrainFreeze will securely store the information and isolate it from further use until deletion is triggered through BrainFreeze’s retention policy.

  • Account information. BrainFreeze retains Your account information while Your account is active and for a reasonable time thereafter. Some information may be retained as necessary to comply with applicable law, resolve disputes, enforce agreements, support business operations, and to develop and improve BrainFreeze Services.
  • Data Subject Requests. BrainFreeze retains Your identification, account, and contact information, and any data relating to your data subject request as long as necessary to comply with applicable law.
  • Information shared on BrainFreeze Services. If Your account is deleted, some of Your information and content may remain on BrainFreeze Services to allow Your team members or other users to fully utilize BrainFreeze Services.
  • Managed accounts. If BrainFreeze Services are provided to You through an organization (such as Your employer), BrainFreeze retains Your information for as long as required by the account administrator of Your account.
  • Marketing information. If You opted to receive marketing emails regarding BrainFreeze, BrainFreeze retains Your marketing preferences for a reasonable and compliant period after Your last indication of interest. BrainFreeze also retains information collected from cookies and other tracking technologies for a reasonable and compliant period after its collection.

Choices About Your Information – Your Rights.

You have various options to manage and exercise your rights relating to Your information, including:

  • Accessing, confirming, and updating Your information. You have a right to know if BrainFreeze is processing your personal information and can request a record of any such data BrainFreeze has. If Your data is inaccurate, You have a right to update Your personal information.
  • Deleting Your information. You have the right to request that BrainFreeze deletes your personal information, or where applicable, You may delete Your personal information through the BrainFreeze Services.
  • Objecting to processing and withdrawing consent. You have the right to object to BrainFreeze processing your personal information (unless we have a legal obligation to do so) and a right to withdraw Your consent to BrainFreeze processing your personal information.
  • You have the right to file a complaint before the appropriate supervising authority.
  • Pausing processing. You have the right to request that BrainFreeze pause the processing of Your personal information.
  • You have the right to request that BrainFreeze transfer Your personal information to another entity selected by You.
  • Post-Death. You have the right to tell BrainFreeze how You want us to process Your personal information after Your death.

You may exercise these choices through BrainFreeze Services (as supported given the request type) or by contacting BrainFreeze directly. Please contact BrainFreeze at [email protected] with any questions, comments, or requests relating to Your personal information.

Cookies Policy.

This Cookies Policy is a part of the Privacy Policy and is intended to provide insight on Cookies and BrainFreeze’s use of the same. Cookies are small text files that can be used by websites and web applications to make a User’s experience more efficient. BrainFreeze’s websites and Services use different types of cookies, as further detailed in the table below. Some cookies are placed by third party services that appear on our pages. Further, BrainFreeze may store cookies on Your device if they are strictly necessary for the operation of the BrainFreeze Services. For all other types of cookies, we need Your permission. Therefore, BrainFreeze will request that you select which cookies You would like us to use when using our Services. To maintain accuracy of the in-scope cookies relating to the BrainFreeze Services, BrainFreeze scans its websites regularly to ensure our cookies list is up to date.

You can at any time change or withdraw Your consent from the Cookie control center on our website.

Types of Cookies:

  • Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. BrainFreeze’s websites and Services cannot function properly without these cookies.
  • Statistic cookies help BrainFreeze understand how visitors interact with its websites and Services by collecting and reporting information anonymously.
  • Preference cookies enable BrainFreeze to remember information that changes the way its websites and Services behave or look. For example, Your preferred language or the region that You are in.
  • Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

Below are the cookies BrainFreeze may use on its websites and applications, subject to Your consent and preferences:

  • Websites: Necessary, Statistics, and Marketing
  • Applications: Necessary, Statistics, and Preferences