AIBRAIN, INC.

Privacy Policy

This Privacy Policy (“Policy”) explains what information will be collected by AIBrain, Inc. (“AIBrain”) when you use the Tyche App (the “App”), access our websites (the “Sites”), software, products and related services (collectively, the “Services”), and how your information will be used and protected.  We will not use or share your information with anyone except as described in this Policy.  This Policy should be read together with our Tyche Terms of Service at [to which this Policy is subject, and which incorporates this Policy.  By using or accessing the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent to our collection, use, and sharing of your information as described in this Policy.

For purposes of this Policy, “Personal Information” means information that includes a personal identifier, such as your name, account password, date of birth, email address, or parent’s email address,  or data that could reasonably be linked back to you.

Our Privacy Promise

We pledge to respect your privacy, to be transparent about our data practices, to keep your data safe, never to sell your personal data, to let you decide how your information is shared, and to only collect data to operate the Service or that helps us improve our products and services.

We are here to help. If something in this policy does not make sense or if you have any questions, please contact us at privacy@aibrain.com

AIBrain takes great care to protect your privacy and to secure the data that is stored on the servers used by AIBrain.  AIBrain employs security professionals who implement the technical and organizational security during development and operations. AIBrain takes measures to protect Personal Information against loss, misuse, unauthorized access, unauthorized disclosure, manipulation, or destruction. This Privacy Policy describes how AIBrain handles the Personal Information and other data to which it has access.

Children’s Privacy Policy

The App and Services are intended for users of all ages, including children under the age of 13 (the latter referred to as a “child” or “children” in this Privacy Policy.)  In compliance with the United States’ Children’s Online Privacy Protection Act (“COPPA”), when we collect Personal Information, we will ask first-time users of the Services to provide us with their birthdate, so that we can determine whether we need to contact a parent or guardian to obtain verifiable parental consent for their child to use the App and the Services (the “Parental Consent”).

COPPA requires the verifiable consent of a child’s parent or guardian before the online service provider knowingly collects personally identifiable information online from children who are under 13.  We do not knowingly collect or solicit personally identifiable information from a child under 13 without obtaining Parental Consent, except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (the “Required Information”).  Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent.  If you are a child under 13, please do not attempt to send any Personal Information about yourself to us before your parent or guardian has provided Parental Consent, except for the Required Information in the context of the Parental Consent process.

If a child signs up for a Tyche account (an “Account”), his or her parent or legal guardian will be provided with notice via email and the parent or legal guardian must provide Parental Consent to approve the Account and the child’s use of the Service before the child’s Account is activated.  If no consent is received within 10 days after sign up, the child’s Account will be deleted from the Services.

The Personal Information collected from the child and stored (with permission of the parent or legal guardian) may include a username, Account password, date of birth, email address, the parent’s or legal guardian’s email address, and the parent/guardian’s Parental Consent.  We may also collect and link to the child’s Account the information we store within our analytics software.

The child’s Personal Information will be used for the purposes stated in this Privacy Policy, as permitted under COPPA. The child’s Personal Information may also be shared with certain third-party vendors that help us operate the Service, such as those that may assist us with sending out email communications to users or processing account information for internal purposes.   Any such third-party providers have, or will have, entered into nondisclosure agreements with us that are consistent with the terms of this Policy.

We will only collect such Personal Information from children as is reasonably necessary to provide the features and services of the Service.  When applicable, parents or legal guardians have the right to consent to AIBrain’s collection and use of Personal Information from their child(ren) without also consenting to its disclosure of their child(ren)’s Personal Information to independent third parties; however, our inability to provide Personal Information to third-party vendors as described above may negatively affect the Services.

If a parent or legal guardian becomes aware that his or her child under 13 has provided us with personal information (beyond the Required Information) without our having obtained Parental Consent, or the parent or legal guardian wishes to revoke his or her prior consent, that parent or legal guardian should contact us at privacy@aibrain.com.  In such case, we will delete such information within a reasonable time.  The parent or legal guardian may also contact us at privacy@aibrain.com to review, modify, delete, or stop AIBrain’s continued use or collection of their child(ren)’s Personal Information.

Alternatively, a parent or guardian may contact us by sending a letter to:

Privacy Officer
AIBrain, Inc.
68 Willow Road
Menlo Park, CA 94025

If we change this privacy statement in a way that expands the collection, use or disclosure of children’s personal information to which a parent has previously consented, the parent will be notified and we will be required to obtain the parent’s additional consent.

We strongly encourage you to talk with your child(ren) about communicating with strangers and disclosing personal information online.

When DO We Collect Data?

We ask for Personal Information and other data at various stages: when you create an Account, when you set up the App and your robot, and in the course of communications with or from you in connection with the Services.

Creating a Tyche Account

To use the App, you must create an Account. When you create this account, we ask for some Personal Information about you. Personal Information is data that includes a personal identifier like your name, email or address, date of birth, or data that could reasonably be linked back to you. If a child under the age of 13 registers for an Account, the email address of his or her parent or legal guardian is collected in order to enable us to seek Parental Consent.  When setting up your Account, you will be asked to create a Tyche user name, which may or may not be your real name, and which will be stored in the App on your device.  We ask for your email address so that we can communicate with you. We do not display your email address to other users.

Communications Between You and AIBrain

We collect and store your email address when you create an Account and, if you are under 13, we collect and store your parent or legal guardian’s email address  and Parental Consent as well. This email address is used for communications from AIBrain.  If you send AIBrain a message, this message can be stored to process it, to compile statistical information, to improve our services and support or to get in touch with you.

Site Data

AIBrain collects industry standard data from everyone who visits our websites—even if you don’t have an Account. This includes log data that automatically records information about your visit, such as your browser type, operating system, the URL of the page that referred you, the different actions you performed, and the IP address you used to access pages on the Site. We use this type of information to provide you with an experience that’s relevant to your location based on the IP address, to prevent Site misuse, and to ensure the Site is working properly. We also collect data from cookies. To see how we use cookies, please read our Cookie Policy below.

What Information Do We Collect?

We collect the following Information:

  • In the process of Account Creation, we ask you to provide Personal Information, such as your name, email address, date of birth, and, in the case of users under the age of 13, the name and email address of that child’s parent or legal guardian.
  • In the process of set up of the App and the Tyche robot, we ask for your username and an image of your face.  This image is stored in the App on your device, not on our server.
  • To access the Service over the internet, you will need to connect it to your wireless network.  During setup, we may ask for your wireless network name (SSIS) and password to connect to the internet.  The App will save this information on the device, along with your IP address, so that you can access it and control it from your smartphone or tablet, and so that it can connect with AIBrain servers.
  • Like most internet sites, we routinely record log entries (including information such as your IP address) and technical information (such as your browser type and version) when your browser, mobile device, or robot contacts our servers.  These log files are used for troubleshooting and are stored on our servers.
  • We record your robot ID and App version as necessary.
  • When connected to the internet, the App regularly uploads to AIBrain servers the data mentioned above (except for your wireless password) to provide you with the Service.  Incoming and outgoing messages are stored in the App on your device for your retrieval and playback, as well as on our servers.
  • Cookie and usage data for use with Google Analytics.

HOW DO WE USE Your Information?

AIBrain uses your Information to provide you with the best experience possible when using the Service, and to improve and protect the Service. Here are some examples:

  • Your email address is used to communicate with you, including to send you:
    •  administrative notices and communications relevant to your use of the Service, such as security, support and maintenance notifications.
    • notifications about new features or products we think you would be interested in. For information on how you can opt out of receiving notifications, please see “Can I Opt-out Of Receiving AIBrain Emails?” below.
  • Your Personal Information may be used for fraud prevention, authentication, to enforce the Tyche Terms of Service, this Policy, or as required to comply with applicable law.
  • We use the email address of parents and guardians of children in order to verify Parental Consent for a child to use the App and the Service.
  • Data and logs are used in research to understand and improve the Tyche App; to troubleshoot the Tyche App service; to detect and protect against error, fraud or other criminal activity.
  • Data may be used to monitor, analyze and describe usage patterns and performance of the Service.  Aggregate data that does not identify you may be used to inform the Tyche community about trends; for our marketing and promotional use; or for sale to interested audiences. See “Data That Does Not Identify You” to learn more.

HOW DO WE SHARE YOUR INFORMATION?

Data That Could Identify You

We will only share your Personal Information under the following circumstances:

  • If we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., subpoenas or warrants served on us), or governmental or regulatory request; to enforce or apply the Terms of Service or this Policy; to protect the security or integrity of the Tyche App; and/or to protect the rights, property, or safety of AIBrain, its employees, users, or others. If we are going to release your Personal Information, we will endeavor to provide you with notice in advance by email, unless we are prohibited by law from doing so.
  • We may share your Personal Information with our agents, representatives and contractors so that they provide us with support or other services.  We require these third parties not to use your Personal Information for any other purpose.
  • We may store Personal Information in locations outside the direct control of AIBrain, such as third party data centers where our servers are housed.
  • We may disclose or transfer your Personal Information in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company. We will notify you if a different company will receive your Personal Information, and the promises in this Privacy Policy will apply to your Personal Information as transferred to the new entity.

Data That Does Not Identify You (De-identified Data)

AIBrain records certain requests and transactions in log files. This log data is used for troubleshooting, statistics, quality assurance, to monitor system security and may be analyzed to that end. AIBrain can publish anonymous statistics under the condition that no personally identifiable information can be derived from such statistics.

Log data may include information such as your IP address, browser type, operating system, the referring web page, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with the Services via the App, for example, when you visit our website, sign into the App, interact with our email notifications, or visit a third-party website that includes or refers to AIBrain’s services.

Data that You Choose to Share

Contests and Giveaways

AIBrain may offer opportunities to participate in contests, giveaways and other promotions. Any data you submit in connection with these activities will be treated in accordance with this Policy, unless the rules for those offers state otherwise.

Surveys

AIBrain may also ask you to participate in surveys (processed by AIBrain or third parties) that help us understand your use of the App. Any Personal Information you provide to AIBrain (or supplied by you or AIBrain to any such third-party survey providers) in connection with these surveys will only be used in relation to that survey and as stated in this Policy.

Security AND STORAGE OF YOUR INFORMATION

AIBrain uses a combination of technical and administrative security controls to maintain the security of your Information.

In order to help secure your Personal Information, access to your data in the Services is password-protected. You should choose a secure password and ensure its confidentiality to prevent unauthorized access to your account. AIBrain uses authentication tools (OAuth) for user authentication. We also use https:// secure transmission of information between the App and our servers.  When you access the Service AIBrain does not store any passwords, as it logs you in to your Account via Google’s OAuth2 authentication mechanism.  Google’s Privacy Policy can be found here: https://www.google.com/intl/en/policies/privacy/

AIBrain stores conversations with you and some other Information on its servers for as long as you remain a Tyche customer in order to provide you with the Services. As described above, some Personal Information is stored in the App on your device. You can delete the Personal Information of a user on the App on your device by deleting the associated user from the App on your device.

Our servers reside in a data center that protects against unauthorized access through external access control using firewall and access control between internal servers.  It also has an Intrusion Protection System (“IPS”) and a Distribute Denial of Service (“DDoS”) defense device.

All Personal Information is encrypted and cannot easily be accessed.  To protect any data stored on AIBrain’s servers, AIBrain regularly audits its system for possible vulnerabilities and attacks. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to or via the Service. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. We strongly advise you not to communicate any confidential information through any electronic means.

How Long DO We Save Your INFORMATION?

As described above, you can delete the Personal Information stored in the App by deleting the applicable user from the App.  As for information stored on our servers, we store your Personal Information for as long as you maintain a Tyche account unless you request that we delete the information.  If you want us to delete your Personal Information from our servers, please contact us at privacy@aibrain.com.  However, because of the way we maintain the Service, some back up copies of your information may linger for some time after such deletion.

AIBrain may continue to use your de-identified data after you deactivate your account.

Can I Opt-out Of Receiving AIBrain Emails?

Of course! You can opt-out of receiving weekly summaries, achievement notifications, contests, giveaways, surveys and promotional emails by changing the notification preferences in your account settings or by unsubscribing via the “Unsubscribe” link in any AIBrain email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the AIBrain Service.

Does AIBrain Honor “Do Not Track” Signals?

Although we would like to honor the browsers set with a “Do Not Track” signal, the Site does not currently respond to a DNT or similar signal as we await the conclusions of the policy and legal communities about the meaning of DNT and the proper way to respond. However, we believe that consumers should exercise choice regarding the collection of this type of data, which is why we disclose that we use cookies and provide links to opt-out of those collection practices.

VISITORS FROM OUTSIDE THE UNITED STATES

AIBrain is based in the United States of America, while our servers are located at our data center in South Korea.  Please be aware that information you provide to AIBrain or that it obtains as a result of your use of the App may be processed and transferred to the U.S or South Korea and, therefore, be subject to the laws of those countries.  The privacy and data protection laws in the U.S. and/or South Korea may not be equivalent to such laws in your country of residence.  By using the Site or Service, or by providing any of your Personal Information to AIBrain, you consent to the collection, transfer, storage, and processing of such Personal Information to and in the U.S. and South Korea.  AIBrain will take commercially reasonable steps to safeguard your data in accordance with this Privacy Policy, but is not responsible for the privacy and security practices of third parties

Advertising

We do not display advertisements in any of our products, and we do not share any information with advertisers.

Cookie Policy

Cookies

When you use AIBrain, cookies can be stored on your device. Cookies are little pieces of information that can help identify your browser and that can store information, e.g. application settings. AIBrain may use cookies to track usage, to improve ease-of-use and the overall user experience.

Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. However, some services may not function properly if you disable cookies.

Technologies We Use

Social media tools, like widgets and plug-ins, may be used so you can share information from AIBrain on other sites such Facebook and Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our Sites, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by AIBrain’s Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

AIBrain reserves the right to update this Privacy Policy at any time.  Any future changes will not affect data that was collected under a previous version of this policy. If any modifications substantially change your rights, we will send an email summarizing the changes to the address associated with your Tyche App account and provide notice on the Site.

The most current version of this policy is available at [

HOW DO YOU CONTACT US?

You can email us with any questions or comments at privacy@aibrain.com.

Privacy Officer
AIBrain, Inc.
68 Willow Road
Menlo Park, CA 94025