USER PRIVACY POLICY

Last Updated: November 10th 2022

Brainly, like you, cares about privacy. We hope that this Privacy Policy will help you understand what personal data we collect when you use Brainly’s website or mobile app (together, our “Platform”), how we use your personal data, and the rights and options you have regarding your personal data.

We’ve created this overview to give you a simple summary of the more complicated parts of our Privacy Policy.

By reviewing our Privacy Policy, you’ll learn what personal data Brainly collects and for what purposes as well as how you can update, delete, or otherwise manage this data. If you have any questions about Brainly’s use of your personal data after reviewing this Privacy Policy, please contact us at [email protected]. By using our services, you acknowledge that you have read and understand this Privacy Policy, and that we collect, use, and share your information as described below.

1. What is Brainly?

2. What data does Brainly collect?

3. How does Brainly use your data?

4. With whom does Brainly share your personal data?

5. Where is your data processed?

6. For how long does Brainly store your personal data?

7. Cookies and “Do Not Track”

8. What are your rights?

9. Note to Parents

10. Managing your personal data

11. Updating this policy

12. Contact us

13. Country-Specific information

1. What is Brainly?

Summary: We help you answer questions. Students can ask anything and get specific answers through text, image, or voice. Brainly is what the law calls a “data controller” of all information you share with us.

Brainly is a peer-to-peer learning platform where students and parents can engage with each other for homework help. Parents, students, teachers, experts, and other people who use our Platform or create an account are bound by this Privacy Policy, and will be referred to as “you,” “your,” or “users.”

Brainly’s official legal name is “Brainly spółka z ograniczoną odpowiedzialnością,” and we’ll be referring to ourselves as “Brainly,” “we,” “our,” or “us” from this point onward. Our registered office is in Krakow (post code 31-158) at ul. Krowoderska 63B/6, our mailing address is ul. Zabłocie 43A, floor 5, Kraków (post code 30-701), and our registration number in the register of entrepreneurs is KRS 0000354511. Brainly is considered a data controller in accordance with applicable data privacy laws.

Brainly has appointed a Data Protection Officer whom you can contact at [email protected] for all matters relating to personal data, especially around exercising your rights related to how Brainly processes your data.

2. What data does Brainly collect?

Summary: We collect information such as: your email, age, and phone number, User Content (i.e.: photos, videos, questions, and answers posted, comments, etc.), technical information about how you connect to our Platform (e.g. the type of device and internet connection you’re using), and payment information related to purchases, among other things listed below.

We collect the following personal data about you:

2.1. Information you provide to us directly – We may collect personal data, such as your name, address, email, telephone number, age, used identification number, payment information, any communications between you and Brainly, and any other information you provide directly to Brainly while using our Platform.

2.2. Information provided to us by your child – If you are a parent or a legal guardian of a minor (depending on your country), we may also collect your email, telephone number, and payment information provided to us by your child while they’re using our Platform.

2.3. Data collected through your use of our Platform – We collect information about how you use our Platform, as well as the content you post to our Platform or actions you take on our Platform (which we’ll refer to as “User Content”). User Content may include information on the groups you belong to on the Platform, your interaction with us or others on our Platform, any content you post to our Platform—including comments on another user’s questions—and any content you provide through messages, chat, or any other feature.

2.4. Information about how you connect with our Platform – We may collect information about your networks and connections such as your IP address, location, internet connection type, information about the hardware and software you use to connect to and interact with our Platform, and other unique identifiers, including cookie data (see Section 4 below for more info).

2.5. Information collected from third parties – We may collect information about your activities outside of our Platform provided to us by advertisers, third-party data providers, or other business partners. We require that a third-party has a lawful right to collect, use and share your data with us. If you log in to your Brainly user account with your Apple, Google, or Facebook account or accounts from other third-party services, we may also receive information from these accounts. The information we receive depends on your settings and the privacy policies of such third parties.

2.6. Payment information – If you make a purchase through our Platform, we may collect payment information in connection with the purchase, including via third-party payment processors.

2.7. Tests and research – If you decide to take part in a test or research survey with our teams to provide feedback and help improve our Platform, we may collect your email, phone number, and any contact information needed for the test or research survey. We may also collect the recording of those interactions, if applicable. You will be required to provide specific consent to take part in tests and research surveys.

3. How does Brainly use your data?

Summary: We need to use the information listed above to: help set up your account, communicate with you, comply to our legal obligations, respond to your requests, keep our Platform free of harmful content, show you relevant and appropriate ads, make our Platform better, personalize what you see, and more, as listed below.

3.1. When you register a user account to use our Platform – We use necessary information about you when you create a user account. Certain features and activities on our Platform can only be accessed if you are a registered user. We also use your information to verify your identity. Please think carefully about the username you choose when you create your user account, because it will be visible to the public when you post a question or answer on our Platform.

3.2. When you pay for a service on our Platform – We use your payment-related information when you pay for a service or a subscription on our Platform.

3.3. When we communicate information related to your use of our Platform – We use your contact information (e.g. email address) to contact you with important information related to the use or operation of our Platform, or about your user account and User Content (including info about the security of the aforementioned items). We also notify you about, among other things, new questions or answers being added to topics of interest to you or about your achievements, if you’ve given us permission to do so under Account Settings -> Notifications.

3.4. When we comply with our legal obligations – We use your information to comply with tax or other legal obligations on our part (e.g. when you make a purchase on our Platform, win a prize in a contest, confirm the registration of your child’s account, or when necessary for legal reasons). We may be required to process your data for the purposes of complying with any such obligations.

3.5. When responding to any contact, complaint, or request to exercise your rights – We use your information when you initiate contact with us (e.g. via contact forms, email, or chat bots) to respond to a complaint or a request to exercise your rights. In these cases, we use your data for the purpose of processing the complaint or request and, if applicable, for its resolution.

3.6. When combating inappropriate behavior and promoting safety – We examine information about the operation and use of our Platform to verify users and accounts, as well as enhancing security and combating inappropriate behavior, spam, or fraud. In doing so, we ensure our Platform is used in accordance with our Terms and Conditions and remains free of harmful and inappropriate content.

3.7. When we share marketing content – We use your information (e.g. information collected from cookies) to show you marketing content that may offer services and products provided by us and/or our business partners.

3.8. When we improve our Platform through user analytics and user satisfaction surveys – Based on analytics data about how you use our Platform (e.g. when you use and when you last used our Platform; which questions, answers, and other content you view or respond to), we are able to compile statistics related to your use of our Platform, assess your satisfaction with our services, determine the quality of our services, and develop and improve our Platform. We also conduct research and surveys, issue questionnaires, test new products and features, and troubleshoot relevant issues.

3.9. When providing customization for you – Based on your user account details (e.g. your age, interests, and program of study) as well as your activity and use of our Platform, we try to tailor our Platform to your individual needs and preferences. We adjust our communication style to you and provide you with information about our Platform’s features that may be of most interest to you.

3.10. When we share aggregate/de-identified/anonymous data – We may aggregate, de-identify, or anonymize any information collected through our Platform and our services so that this information is no longer linked to your personal data (e.g. your name or email address). We may use aggregated and anonymized information for any purpose, including for research and marketing purposes. We may also share such information with third parties at our discretion.

4. With whom does Brainly share your personal data?

Summary: Your username and the content you post are public. Anyone visiting our platform can see it — so be sure to choose your username carefully! Other companies may also need to access your data for different purposes. But don’t worry — we make sure these folks (e.g. advertisers, payment processors, etc.) are complying with our instructions when doing things such as displaying the ads you see while using our Platform, processing payments, and more, as listed below.

We may share your personal data with the following parties:

4.1. Persons visiting our Platform – Most User Content on our Platform is public, including your profile information and your User Content. This means that any person visiting our Platform may have access to information you provide while using our Platform.

4.2. Subcontractors – We work with subcontractors to help process personal data. These may include hosting service providers, IT specialists and technicians managing our technical infrastructure, service providers that ensure the functionalities of our Platform, claims adjusters (including insurers), advertising and marketing companies, accounting and bookkeeping offices, and legal advisors. All subcontractors process data under contracts with Brainly and only in accordance with our instructions and their legal obligation.

4.3. Advertisers, advertising agencies, and intermediaries – Based on the information contained in cookies or other online identifiers (if they contain personal data), advertisers, advertising agencies, and intermediaries globally participate in the process of selecting the content of targeted advertisements that are displayed to you on our website. We have not provided, and do not currently provide, personal data to third parties for monetary payment.

When you use our website, we may share with third parties some personal data, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system. These third parties may sometimes act as “joint controllers” (e.g.: LiveRamp and its group companies.)

These third parties may use this information to create an online identification code for the purpose of recognizing you on your devices. This code may be stored in a first-party cookie for use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising.

4.4. Payment intermediaries – If you purchase a subscription on our Platform, we will provide your payment data to our payment intermediaries.

4.5. Companies in our corporate group – We may share data with our subsidiaries or parent companies included in the Brainly group to assist, enhance, and fulfill services on our behalf. These entities may be outside of your jurisdiction. We may also disclose your information if we undergo organizational restructuring (e.g. establish a subsidiary or merge with another entity), or an acquisition by another entity. In such transactions (including in contemplation of such transactions, e.g. due diligence) your information may be disclosed. If any of our assets are sold or transferred to a third party, your information would likely be one of the transferred business assets.

4.6. Legal compliance and protection of Brainly and others – We may disclose your information if required to do so by law, or on a good faith belief that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (i) to comply with legal process; (ii) to enforce this Privacy Policy or other contracts with you, including investigations of potential violations thereof; (iii) to respond to claims that any content on our Platform violates the rights of a third party; (iv) to respond to your requests for customer service; and/or (v) to protect the rights, property, or personal safety of Brainly, our agents and associates, and the public. This includes exchanging information with other companies and organizations for fraud prevention, spam/malware prevention, and other similar purposes.

4.7. Other Lawful Disclosures – Upon information and consent provided by you, if applicable, we may share your information elsewhere that is not legally prohibited.

5. Where is your data processed?

Summary:  To run our Platform, we must use computers all over the world. This means your data might be transferred anywhere we (or our partners) operate, such as North America, Europe, Asia, and Latin America.

Your personal data may be transferred to our partners or affiliates that are based in a different country than yours. Whenever your personal data is transferred, we provide adequate safeguards for your data by requiring data recipients to sign and abide by the applicable Standard Contractual Clauses approved and issued in each by relevant authority in each jurisdiction, such as the European Commission.

6. For how long does Brainly store your personal data?

We retain your personal data for different periods of time depending on the purpose for which it is processed:

Summary: We need to keep your data for as long as you have an account on Brainly. When your account is deleted, we may also need to keep some data for complying with tax or legal obligations, statistics, and for other purposes that you’ve authorized us to do so. But don’t worry — we’ll make sure the data isn’t traceable back to you anymore.

6.1. In order to perform the contract with you – We store your data for as long as you have a user account on our Platform. If you delete your user account or if we must delete your account (e.g., due to your violation of the Terms and Conditions of our Platform or violation of the law), we will delete or anonymize your personal data. However, we may retain some data for longer time to comply with legal, tax, and accounting requirements (e.g. until the expiration of statutory limitation periods for contractual claims or limitation periods for tax liabilities arising from the fact that you purchased our services) or if the data is necessary for ongoing or anticipated legal proceedings. We make every effort to limit the retained data to the necessary minimum, and to retain it for no longer than required.

6.2. On the basis of a legitimate interest (ours or that of a third party) – we keep it until you object to the processing or until we determine that the data is no longer relevant, or we have already fulfilled our purpose for using it.

6.3. As requiredby law – We use the data for the time in accordance with applicable laws.

6.4. Based on your consent – Until whichever happens first: (i) withdrawal of your consent or (ii) fulfillment of the purpose for which the data was collected.

7. Cookies and “Do Not Track”

Summary:  We and our partners place cookies (not the delicious kind) on your device to make our products better and show you personalized ads and other relevant content on our website and app. To change your preferences, please click here and then “Cookie Preferences” on the footer of the page.

We do not “sell” personal data to third parties. However, when you use our Platform, even if you’re not a registered user, we may collect and allow third-party advertising networks and other third party businesses to collect your data through cookies or similar technologies, such as your IP address, the type of device you are using, screen resolution, operating system, geographical data, and which pages of the site you’ve viewed. We use several types of cookies including: essential cookies to run our Platform, analytics cookies to understand how to improve our Platform, and advertising cookies to determine who might benefit from services offered by Brainly or our partners.

Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals.

To change your preferences, please click here and then “Cookie Preferences” on the footer of the page.

8. What are your rights?

Summary: You have many rights regarding your data, for example: requesting a copy of your data or that your data is deleted, among the other things listed below. To send us a request, click here.

In accordance with all applicable law, we enable you to exercise some or all the following rights regarding our collection, use, and sharing of your data:

Accessing the data we maintain about you

Updating or correct any inaccurate or incomplete data about you

Requesting that we delete your data

Objecting to or restricting the processing of your data

Receiving the data you’ve previously provided, in a machine-readable format, allowing you to transfer that data to another company at your discretion

Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; and

Filing a complaint directly with the relevant Supervisory Authority about how we process your data.

8.1. Exercising Your Rights – If you would like to request access to your personal data, and/or request erasure/deletion of data previously provided, please click here. We will respond to your request within a reasonable timeframe. We also may need to verify your identity.

8.2.Denial of Requests – We may deny a request as permitted by applicable law. We will notify you regarding any decision and reason(s) for denial within a reasonable timeframe.

8.3. Requests by Agents – You can designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. We reserve the right to take steps to verify that the agent is authorized to make that request, which may include requiring you to provide us with written proof such as a notarized authentication letter or a power of attorney.

9. Note to parents

Summary: We don’t allow children (or those who are minors according to the laws in your country) to create an account on our Platform without parental authorization.

Brainly does not knowingly collect any personal data from children under the age of 13 in the United States, or the age of 16 in the United Kingdom or Europe, or the age of 18 in India and Brazil, unless and until Brainly has obtained appropriate parental consent for your child to use our Platform. Please contact us at [email protected] if you believe we have inadvertently collected personal data of a child without proper consent, as required in your jurisdiction, so that we may delete such data as appropriate.

10. Managing your personal data

Summary: You have control over the data you share with us. You can update your profile information and allow (or not allow) access to your photos, camera, or location. You can also unsubscribe from certain types of emails we send you.

10.1. Profile and data sharing settings – You can update your profile information (such as your email address and password) and change some of your data-sharing preferences on the Account Preferences page.

10.2. Access to device information – You can control the mobile app’s access to your device information under the Settings menu on your device. For example, you can revoke the app’s permission to access your location, photos, and camera.

10.3. Communication preferences – You can opt out of receiving promotional emails from us by clicking the unsubscribe link provided in such emails. You cannot opt out of Platform-related communications (e.g., account verification, payment communications, changes/updates to our Platform, or technical and security notifications).

11. Updating this policy

Summary: When we update this policy, changes will become effective 30 days after the new version is posted. If you keep using our Platform, we’ll assume you agree with the changes.

We may update this Privacy Policy from time to time. We will post the changes or information about them on our Platform, and we will notify you of major modifications by email or through our Platform. The date at the top of this Privacy Policy tells you when it was last updated. If we make a material change to this Privacy Policy, you will be provided notice in accordance with legal requirements. Any changes to this Privacy Policy will become effective and will be applicable to you 30 days after the revised Privacy Policy is posted. By continuing to use our Platform, you are confirming that you have read and understood the latest version of this Privacy Policy.

12. Contact us

If you have any requests, questions, comments, or concerns regarding this Privacy Policy or privacy practices, please contact our Data Protection Officer at [email protected] or by mail to this address: ul. Zabłocie 43A, floor 5, 30-701 Kraków.

13. Country-Specific information

13.1. India – When you provide your mobile phone number, you agree to receive communications, even if this mobile number is registered under the DND/NCPR list under Telecom Regulatory Authority of India (TRAI) regulations. You may receive calls, emails, messages (SMS), notifications, and information from us and from third-party service providers for promotions, discounts and/or other messages related to the Platform. When you provide your mobile phone number, you authorize us to share/disclose it to any third-party service provider, affiliates, and group companies, as well as their authorized agents or third-party service providers.