Privacy Policy

Published
July 16, 2024

1. Introduction

Welcome to Thinkie Inc., the first safe, real-time measurement and visual feedback brain training system.  Thinkie Inc., including any current or future affiliates and subsidiaries (collectively, “Thinkie”) is thrilled that you are placing trust in our service. Thinkie knows that your personal information is important, and we will take every reasonable measure to secure that information.  We also will take reasonable actions to ensure that the hardware and software used in our Products and/or Services, and that are within our direct control, are secure and free from malicious software that could compromise your privacy or security.

This Privacy Policy is meant to provide you with some transparency by helping you understand the information we collect, why we collect it, and how you can manage it, so you know what to expect. This Policy applies to our website at Thinkie | Science Your Brain (thinkiesystem.com), our Thinkie System (the “Product”) and any related products, services, communications, or apps (collectively, together with the Site and Products, the “Services”). You may interact with many of our Services, and many of these Services are built to interact with one another. For example, the Thinkie Band sensor is linked via Bluetooth to the Thinkie app to provide visual brain activity feedback in real-time. By using our Services, you are acknowledging that you have read, understood, and accept this Privacy Policy and our Terms and Conditions.

In this Privacy Policy, any use of the words “you,” “yours,” or similar expressions refers to users of our Services, as well as any other individuals whose information we collect and process. References to “we,” “us,” “our” or similar expressions refer to Thinkie.

This Policy does not extend to: (i) anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after our Sites; (ii) by interacting with hardware and software that is not in our direct control; (iii) and which are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use, before you visit or submit personal information.

Thinkie is not a healthcare company. Any feedback received as a result of your interaction with the Services should not be interpreted as medical advice.  If you have any concern over your health or the feedback provided through the Services, please consult a licensed healthcare provider.

2. Information We Collect and How We Collect It

We collect information from and about users of our Services:

  • Directly from you when you provide it to us through the Website and/or the Product.
  • Automatically when you use the Product.

Information You Provide to Us

When you download, register with, or use the App or interact with our Website, we may ask you provide information:

  • That is about you but individually does not identify you, such as date of birth (limited to birth year and month), and gender. We may also ask you to create a pseudonym “nickname” when registering for your Services.
  • Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App. We may also ask you for information when you report a problem with the App.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.

When you come to purchase the Product through our Website, you will be redirected to Shopify (https://www.shopify.com) to complete your transaction and where you will be asked to provide certain information to complete your purchase.  Please carefully read the policies of Shopify (found at: https://www.shopify.com/legal/privacy), before you visit or submit personal information.

In some cases, our users may be provided with a Samsung tablet to support their Thinkie System.  Samsung may collect information, as outlined in their Privacy Policy, which is beyond our control.  Please carefully read the policies of Samsung (found at: https://www.samsung.com/us/account/privacy-policy), before using the Samsung tablet or providing any personal information.

Automatic Information Collection

Cookies and Other Trackers. We may use cookies and similar technologies (e.g., web beacons, pixels, and device identifiers) to recognize you and/or your device(s) on, off and across the Sites and different Services and devices. A cookie is a small file that is placed onto a device (e.g., computer, smartphone or other electronic device) that stores information when you visit a website. However, you can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising. Neither the Sites nor the Services respond to Do Not Track signals.

Thinkie uses cookies and related technologies on our website to help us recognize your device as a repeat visitor and enable certain website features and functionalities. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Specifically, we use cookies and other similar technologies on our websites to gather the following information:

  • Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the App, including communication data, game usage data, and the resources that you access and use on or through the App. Such information may include your user ID, username, log-in dates, what games are played, brain activity scores, and brain age (collectively, “gameplay data”).
  • Device Information. We may collect information about your Thinkie tablet and internet connection, including the device's unique device identifier and IP address.
  • Location Information. The Services do not collect real-time information about the location of your device; however, we do use mobile device management (MDM) for leased Thinkie tablets, which may enable us to track the location of tablets that we provide.

Pixels: Occasionally, we may also use tracking pixels (clear GIFs or pixel tags), typically one-pixel clear images that are embedded on a page of the site. These tracking pixels may be in our site or communications such as email messages. This technology helps us verify when a certain page of the site is viewed, when a message or ad is opened, when links are clicked and other content in a message is viewed, and the originating source of a click or view. We use the information collected for similar purposes as the information collected through cookies, as described above.

We also work with service providers and advertising partners that use cookies, tracking pixels, and other tools to collect information about your visits to our site and your behavior while on the site. This information is used to deliver targeted advertisements to you across the internet based on your site usage on our site. The information collected and used in this manner is generally anonymous and not personally identifiable. If you would like to learn more about this practice, you can visit the Digital Advertising Alliance at aboutads.info/consumers.

Types of Cookies: The cookies we place on your device fall into one of the following two categories:

  • Session cookies: these allow our websites to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
  • Persistent cookies: these are stored on your device in between browser sessions. These allow your preferences or actions across our websites to be remembered. These will remain on your device until they expire, or you delete them from your cache.

The cookies that we place on your device may also be:

  1. Strictly necessary cookies: these cookies are essential for you to be able to navigate our websites and use their features. Without these cookies, we could not provide you with the Services you have requested.
  2. Performance cookies: these cookies collect information about how you use our websites, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous and is only used to improve how our websites work.
  3. Functionality cookies: these cookies allow our websites to remember the choices you make (such as your username, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
  4. Analytics cookies: We use Google Analytics, a web analytics service of Google Inc. (“Google”) and Amplitude which use cookies to identify the frequency of use of certain areas of our Services and to identify preferences. For more information regarding how Google and Amplitude collect, use, and share your information please visit http://www.google.com/policies/privacy/partners and https://amplitude.com/privacy. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the Services, compile reports on activity for us, and perform further services associated with the Sites and Internet use. Google may also transmit this information to third parties where required by law or to the extent that third parties process these data on behalf of Google. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.

Controlling Cookies: Your browser may give you the ability to control some types of cookies. If you do not want to accept the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. To control flash cookies, which cannot be disabled through your browser, please go to: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Consent to Use Cookies: The first time you visit our websites, a cookie notice may be displayed describing our use of cookies and linking to this Cookie Policy. As described in that notice, the cookie choices you make the first time you visit our Sites will be used for your future use of the Sites.

3. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • To deliver, maintain and improve our Services.
  • To allow you to log into, access and manage your account.
  • To provide customer services and other support services.
  • To alert you about product updates, special offers, functionalities, security updates, updated information, and other news and services from Thinkie.
  • To track or store your performance while using our Product and App, allowing us to customize the content according to your individual interests, including but not limited to, speeding up your searches.
  • To assist in business transfers, such as if Thinkie is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Thinkie’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event.
  • To identify usage trends, audience sizes and determine effectiveness of our promotional campaigns.
  • To help us create and publish content most relevant to you.
  • To carry out our obligations and enforce our rights arising from any contracts we have entered into with respect to our provision of the Services to you.
  • To automatically push updates to the App.
  • To contact you in response to sign up forms or requests such as our Contact Us feature; and
  • For other legitimate business purposes.

4. With Whom We May Share Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Notwithstanding the generality of the foregoing, we use Shopify to host our online store. Their Privacy Policy can be viewed at https://www.shopify.com/legal/privacy.

In some cases, our users may be provided with a Samsung tablet to support their Thinkie System.  Samsung may collect information, as outlined in their Privacy Policy, which is beyond our control.  Please carefully read the policies of Samsung (found at: https://www.samsung.com/us/account/privacy-policy), before using the Samsung tablet or providing any personal information.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business, such as our customer relationship management vendor and our App Developer.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Thinkie Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Thinkie Inc. about our Service users is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts we have entered into with respect to our provision of the Services to you, including the T&Cs (available at https://thinkiesystem.com/terms-of-service).
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Thinkie inc., our customers, or others.

We may obtain your written consent from time to time in electronic form by using online agreements or other acknowledgements on the Services, including for any other contemplated uses of your personal data not addressed in this Privacy Policy. Please read all online agreements carefully before accepting them.

5. Storage and Protection of Your Personal Data

We retain the information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations.

Notwithstanding the generality of the foregoing, we store email addresses until the user requests to be unsubscribed.

The Company is committed to the protection of the personally identifiable information that you share with us. We utilize a combination of security technologies, procedures and organizational measure to help protect your personally identifiable information from unauthorized access, use or disclosure.

We do not store payment card information; rather we utilize a third-party store, Shopify, to conduct those transactions and have no access to your payment details or any other information you offer to Shopify to complete your order, such as your full name or your address.

No Internet or e-mail transmission is ever fully secure or error free, however.  We therefore cannot guarantee absolute security of your data, and we are not responsible for processes and networks that we do not control.  Users assume the risk of security breaches and the consequences resulting from them.  Please be careful in deciding what information you send to us via email or over the Internet.

6. Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.  If you would like to make a request, please contact us at privacy@thinkiesystem.com.  Note that we cannot delete your personal information except by also deleting your user account.

You may opt out of receiving electronic marketing communications from us by clicking on the “unsubscribe” link on the communication or contacting us at privacy@thinkiesystem.com.

Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal information, such as the right to complain to your local data protection authority and appeal the outcome of a data access request.

You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Services.

7. Our Policy Towards Minors

The Services are not intended for children. We do not knowingly collect personal information from children under 13, and in some jurisdictions under the age of 16. By using our Services, you represent that you are at least 18 years old and understand that you must be at least 18 years old in order to use our Services.

8. Users Outside the United States

The Services are controlled and operated from the United States. If you are an individual located outside the United States with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store and process the information we collect in the United States.  Personal data may also be transferred from the country of your residence to other countries, including the United States.

9. Links to Other Sites

Our Website may contain links to other websites for your convenience or information.  These websites may be operated by companies unaffiliated with the Company, and we are not responsible for the content or privacy practices of those websites.  Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.

10. Changes to Our Privacy Policy

We may update our privacy policy from time to time without prior notice to you to reflect changes in our information practices, and any such amendments shall apply to information already collected and to be collected. Your continued use of the Website after any changes to our Privacy Policy indicates your agreement with the terms of the revised Privacy Policy.  Please review this Privacy Policy periodically and especially before you provide personal information to us.  If we make material changes to this Privacy Policy, we will notify you here, by email or by means of a notice on our home page.  The date of the last update of the Privacy Policy is indicated at the top of this Privacy Policy.

11. Questions and Contact Information

To submit questions or comment about this privacy policy and our privacy practices, contact us at:

THINKIE Inc.

Attn: Privacy

1201 Third Avenue, Suite 1560

Seattle, WA 98101

privacy@thinkiesystem.com

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