UDZU – The Brain Trainer

In order to use the services, we will ask you to enter information about yourself, your name and email. We also automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the service, to serve ads.

For improving our service and serving ads, we use third party solutions. As a result, we may process data using solutions developed by Google, Firebase, Apple, Amazon. Some of the data is stored and processed on servers of such third parties. This enables us to: (1) analyze different interactions (how often users make subscriptions, how many users have finished certain training games etc.); (2) serve and measure ads (adjust the relevant ads to a certain category of users and assess how well our marketing partners perform).

Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 5), who will be the data controller (Section 14), and how to influence personalized advertising (Subsection 2.8). If any questions will remain unanswered, please contact us at support@udzutech.com.

Privacy Policy

This Privacy Policy explains what personal data is collected when you use the Udzu – the brain training mobile application ("App"), our website located at www.udzutech.com (the "Website") and related services (together with App and the Website, the "Services"), how such personal data will be used, shared or otherwise processed.

BY USING THE SERVICES, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Services. In such case, you must (a) delete your account using the functionality found in "Settings" in App or the Website, or contact us and request deletion of your data; (b) cancel any subscriptions depending on how you subscribed (using the functionality provided by Apple or Google if you subscribed via an app store; or the functionality of our Website if you purchased subscription via the Website); and (c) delete App from your device(s).

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

"EEA" includes all current member states to the European Union and the European Economic Area. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.

"Process" in respect of personal data, includes to collect, store, and disclose to others.

Table of contents

  1. Categories of personal data we collect
  2. For what purposes we process personal data
  3. Under what legal bases we process your personal data (applies only to EEA-based users)
  4. With whom we share your personal data
  5. How you can exercise your privacy rights
  6. Age limitation
  7. International data transfers
  8. Changes to this privacy policy
  9. Supplemental notice for California residents
  10. Supplemental notice for Virginia residents
  11. Supplemental notice for Nevada residents
  12. Data retention
  13. How "Do Not Track" requests are handled
  14. Personal data controller
  15. Contact us

1. Categories of personal data we collect

We collect data you give us voluntarily (for example, when you enter info about yourself, your name or email). We also may receive data about you from third parties (for example, when you sign in via Google). We also collect data automatically (for example, your IP address) and use third-party service providers for such collection.

1.1 Data you give us

You provide us information about yourself when you register for and/or use the Services. For example, your name or email.

1.2 Data provided to us by third parties

When you decide to log in using Google, we get personal data from your Google account. This includes your email, name, profile image, and Google ID. You can revoke access provided to us on Apps Permissions page. To know more about how Google processes your data, visit its Privacy Policy.

When you use Sign In with Apple to register an account in App, we get personal data from your Apple ID account. This data may include, in particular, your name and verified email address. You may choose to share your real email address or an anonymous one that uses the private email relay service. Apple will show you their detailed privacy information on the Sign In with Apple screen. Apple lets you revoke access provided to App in your Apple ID settings by following the next steps. Find more about Sign In with Apple here.

1.3 Data we collect automatically

  • Data about how you found us: We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
  • Device and Location data: Examples of such data include language settings, IP address, time zone, type and model of a device, device settings, operating system and its version, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
  • Usage data: We record how you interact with our Services. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Services, how long you are in the Services, and your subscription orders. We also record the ads in our App or Website with which you interact (and the Internet links to which those ads lead).
  • Advertising IDs: We collect your Apple Identifier for Advertising ("IDFA") or Google Advertising ID ("AAID") (depending on the operating system of your device). You can typically reset these numbers through the settings of your devices operating system (but we do not control this).
  • Transaction data: When you make payments through the Services, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.
  • Cookies: A cookie is a small text file that is stored on a users computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Services. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.

Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Services. Cookie data will be stored on your device and most of the times only for a limited time period.

2. For what purposes we process your personal data

We process your personal data for the following purposes:

2.1 To provide our Services

We use Firebase Performance Monitoring, Firebase Crash Reporting, and Crashlytics, which are monitoring services provided by Google. To learn more, please visit Googles Privacy Policy, Privacy and Security in Firebase and Crashlytics Data Collection Policy.

2.2 To customize your experience

We process your personal data to adjust the content of the Services and make offers tailored to your personal preferences. For example, we may show you more games from the "Memory" category.

2.3 To manage your account

We process your personal data to secure access to your personal account and send you technical notifications or emails about the performance of our Services, security, or updates to the Terms and Conditions of Use or this Privacy Policy.

2.4 To communicate with you regarding your use of our Services

We communicate with you, for example, via push notifications or emails. These may include reminders and motivational messages encouraging you to continue using our puzzle games. You may receive daily reminders, for example, to maintain your puzzle streak. To opt-out of push notifications, adjust your device settings. To opt-out of emails, click the unsubscribe link in the footer of our emails.

2.5 To provide you with customer support

We process your personal data to respond to your requests for technical support. We use Zoho email services for handling inquiries. To learn more about how Zoho processes your data, visit its Privacy Policy.

2.6 To research and analyze your use of the Services

We use data to better understand our business and improve our Services. For instance, we analyze which features and sections of the app users prefer to decide on further development. To analyze visitors behavior, we use Google Analytics and Firebase Analytics.

2.7 To send you marketing communications

We may use your email address for marketing purposes to inform you about our products and special offers. To unsubscribe, follow the instructions in our marketing emails.

2.8 To personalize our ads

We and our partners, including Facebook and Google, use your personal data to tailor ads to your preferences. For example, if you have installed our app, you may see our ads on Facebook. You can manage ad personalization settings for iOS, Android, macOS, Windows, and browsers using the guides below:

  • iOS: Go to Settings > Privacy & Security > Apple Advertising and deselect Personalized Ads.
  • Android: Go to Settings > Privacy > Ads and enable Opt out of Ads personalization.
  • macOS: Go to System Preferences > Security & Privacy > Privacy and deselect Personalized Ads.
  • Windows: Go to Start > Settings > Privacy and turn off the advertising ID setting.
  • Browsers: Adjust cookie settings in browser preferences (e.g., Chrome, Firefox, Safari).

2.9 To process your payments

We use third-party payment processors to handle transactions. Payment details are stored and processed directly by these providers.

2.10 To enforce our Terms and Conditions of Use and prevent fraud

We use your personal data to enforce our agreements, detect fraud, and ensure compliance with our Terms and Conditions of Use.

2.11 To comply with legal obligations

We may process or share your data if legally required, for example, in response to law enforcement requests.

4. With whom we share your personal data

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Services.

4.1 Service providers

We share your personal information with the following types of service providers:
  • Cloud storage providers (e.g., Timeweb);
  • Data analytics providers (e.g., Google, Firebase).

4.2 Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, as required by law.

4.3 Third parties as part of a merger or acquisition

As part of business transactions (e.g., mergers or sales), customers information may be transferred as one of the business assets.

5. How you can exercise your privacy rights

To be in control of your personal data, you have the following rights:
  • Accessing / reviewing / updating / correcting your personal data.
  • Deleting your personal data, as permitted by law.
  • Objecting to or restricting the use of your personal data, or asking us to stop processing your data.

For EEA-based users, additional rights include lodging a complaint with supervisory authorities and requesting data portability in a machine-readable format.

6. Age limitation

We do not knowingly process personal data from persons under 16 years of age. If you become aware of such processing, please contact us at support@udzutech.com.

7. International data transfers

We may transfer personal data to countries other than where it was originally collected. If these countries do not have the same data protection laws, we use safeguards such as Standard Contractual Clauses or adequacy decisions .

8. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. If material changes occur, we will notify you through our Services or other available means. Continued use of the Services after changes signifies acceptance of the revised policy.

9. Supplemental notice for California residents

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (the "CCPA"). The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below.

Category of Personal Information CollectedCategories of Third Parties Personal Information is Disclosed to for a Business Purpose
IdentifiersService providers, users or third parties you share with, advertising partners
Personal information categories listed in Cal. Civ. Code § 1798.80(e)Service providers, users or third parties you share with
Commercial informationPayment solutions partners
Internet or other electronic network activityService providers, users or third parties you share with, advertising partners
Geolocation dataService providers, advertising partners
Inferences drawn from other personal information to create a profile about a consumerService providers, advertising partners

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

"Sales" of Personal Information under the CCPA

For purposes of the CCPA, we do not "sell" personal information, nor do we have actual knowledge of any "sale" of personal information of minors under 16 years of age.

Non-Discrimination

California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification

When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us at support@udzutech.com. We will process such requests in accordance with applicable laws.

10. Supplemental notice for Virginia residents

This Supplemental Virginia Privacy Notice only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under the Virginia Consumer Data Privacy Act ("VCDPA").

Disclosures about the use of your personal data

We may collect and use certain information about you, some of which may be personal data (such as your name, email address, IP address, or other information which may be reasonably linked to you), in order to operate the Services and to maximize your experience.

If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 1 and Section 2. To learn more about sharing of your personal data with our business partners and other third parties, please read Section 4.

Data Rights

Section 5 of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Services. Before completing your request, we may require some information sufficient to authenticate your identity.

Additionally, VCDPA provides Virginia residents with these data rights:
  • Opt out of the Processing of your Personal Data for Targeted Advertising: In order to exercise your choice as a Virginia resident, please contact us at support@udzutech.com with the subject line "Virginia Do Not Sell Request".
  • Confirm whether your Personal Data is being Processed: You may confirm whether your personal data is being processed by emailing us at support@udzutech.com.
  • Appeal a Case with regard to your Request: In the case where we declined to take action on your data rights request or have rejected your request, you may contact us at support@udzutech.com to initiate an appeal of this decision.

If your appeal is denied, you may contact the Office of the Virginia Attorney General:
Address: 202 North Ninth Street, Richmond, VA 23219
Website: Virginia.gov

11. Supplemental notice for Nevada residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at support@udzutech.com with the subject line "Nevada Do Not Sell Request". Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

12. Data retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Services to you), which includes (but is not limited to) the period during which you have an account with the Services. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13. How "Do Not Track" requests are handled

Except as otherwise stipulated in this Privacy Policy, this App does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

14. Personal data controller

Name: Aleksei Kochetov
Email: team@udzutech.com
Address: Yerevan, Fuchik 27/1, Apt 38, Zip Code: 0048, Armenia

As the Personal Data Controller, Aleksei Kochetov is responsible for determining the purposes and means of processing personal data collected through the UDZU application. For any inquiries regarding the processing of personal data, users may contact the personal data controller using the contact details provided above.

15. Contact us

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at support@udzutech.com.

Last Update: 17 November 2024