Privacy Policy
Last updated: November 2023
BRAINMOUNT LTD ("we", "us", "our") is committed to respecting your
privacy. This Privacy Policy explains our data protection practices and
the types of information we may collect when you use our mobile
application, Chatomic (the "App"). This policy applies to all users who
access our App.
If you have any questions or concerns about our Privacy Policy, please
contact us via email [email protected].
1. DEFINITIONS
"Personal data" or "personal information" refers to any information that
can be used to identify an individual, either directly or indirectly. This
could be through an identification number or by one or more factors
specific to the physical, physiological, mental, economic, cultural, or
social identity of the individual.
We act as the data controller under the General Data Protection Regulation
(GDPR), unless otherwise stated.
CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CCPA) PRIVACY NOTICE
If you are a California resident, in accordance with the CCPA, you have
the right to request:
- The categories of personal information we process
- The sources from which personal information is obtained
- The purpose for processing your personal data
- The categories of third parties with whom we share your personal
information
- The specific pieces of personal information we may have about you
By using our App, you acknowledge that you have read, understood, and
agreed to the terms of this Privacy Policy.
2. COLLECTION AND USAGE OF PERSONAL DATA
We collect and process personal data to provide you with our services,
improve our App, and comply with our legal obligations.
3. SALE OF DATA
We do not engage in the sale of any of your personal data to third
parties.
4. SHARING OF DATA
We may share your personal data with third-party service providers.
5. OPT-OUT CHOICES
If you wish to stop us from processing your personal data, please contact
us via email [email protected]. Please note that certain functionalities
of the App may not work without processing your data. In such cases, we
recommend removing the App from your device.
6. CONSUMER INQUIRY
You have the right to request access, portability, or deletion of your
personal information. Please contact us to make such a request, providing
enough detail for us to understand, respond to, and fulfill your request.
7. PAYMENT INFORMATION
Our e-commerce provider, Apple, handles all in-app purchases and the
secure processing of your personal information. We do not have access to
your credit or debit card information.
8. CHILDREN'S PRIVACY
Our App is intended for users who are at least 18 years old. We do not
knowingly collect personal information from anyone under the age of 18. If
we learn that we have collected personal information from a minor without
parental consent, we will delete this information as soon as possible.
9. PURPOSES OF PROCESSING DATA
We use your information to provide and improve our App, personalize your
experience, communicate with you, and enforce our policies and protect our
rights.
10. PROCESSED INFORMATION
a. Essential Data
To deliver the services you request and fulfill our contractual
commitments, we require essential data. Without this information, we
cannot assure the complete functionality of the App.
User Content: This includes any text or other content that you input into
the message field and send through Chatomic, as well as any text or other
content generated by AI via Chatomic. You are free to use, share, and
exploit your User Content for your personal purposes, in line with the
guidelines and restrictions set out in our Terms of Use. Please be aware
that any use of User Content is at your own risk, and you bear all risks
and responsibilities associated with such use. You are solely responsible
for ensuring compliance with relevant laws when using User Content. Please
note that we use a third-party service provider, OpenAI, LLC, for
processing and creating AI-generated User Content.
Contact Information: This includes your name, email address, and any other
content you provide when reaching out to us via email or support form. We
store and process this information. We use this information to respond to
your inquiries, fulfill your requests, and deliver the services or
communications you request.
b. Automatically Processed Information
We may use third-party automatic data processing technologies, such as
advertising or analytics tools, to analyze certain information sent by
your device through Chatomic (e.g., identifier for advertisers for iOS
devices, etc.), with your consent. Some of these integrated tools may
conduct automated processing of your personal data, including profiling.
Profiling involves any form of automated processing of personal data to
evaluate certain personal aspects relating to you, particularly to analyze
or predict aspects concerning your personal preferences, interests,
behavior, location or movements (please refer to the list of data below).
Automatic data processing technologies will start processing information
as soon as you allow Chatomic to track your activity.
To enhance Chatomic's performance, we may process information about your
device and user behavior based on our legitimate interest (as detailed in
the "Automatically Processed Information" subsection). This data is
typically non-personal, meaning it cannot be directly linked to any
specific individual, and we only access it in an aggregated form. The
information we collect may include:
Mobile Device Data, Application Information, Cookies and similar
technologies, Log file information, Ad-related information, and In-App
Events.
Please note that we do not have control over the information provided
automatically to advertising or analytics tools, and therefore cannot take
responsibility for the processing of such information.
11. WHY WE PROCESS YOUR DATA
We use your information for the following reasons:
To provide Chatomic and its services: We use your information to provide
Chatomic and its services to you. This includes processing essential data
and automatically processed information to ensure that you can access and
use Chatomic as intended.
To improve Chatomic: We use automatically processed information to analyze
how users interact with Chatomic, identify areas for improvement, and test
new features and functionality. This helps us to continuously improve
Chatomic and provide a better user experience.
To personalize your experience: We may use automatically processed
information to personalize your experience within Chatomic. For example,
we may use this information to show you content that is tailored to your
interests, or to suggest features or services that may be of interest to
you.
To communicate with you: We may use your contact information to
communicate with you about Chatomic, such as to provide you with updates,
respond to your inquiries, and provide customer support.
To enforce our policies and protect our rights: We may use your
information to enforce our policies and protect our rights, including
investigating and preventing fraud, spam, or other unauthorized activity,
and complying with legal obligations.
If we use your information for any other purpose not listed here, we will
notify you and obtain your consent as required by applicable law.
12. DATA SHARING
We utilize external services to enhance the functionality of our App. We
ensure that our third-party service providers are meticulously selected
based on their commitment to implementing robust technical and
organizational measures to safeguard your personal data. Nevertheless, we
cannot guarantee the absolute security of any data transmitted to these
third-party providers and do not assume liability for any accidental loss
or unauthorized access to your personal data caused by these providers.
We want to assure you that we do not rent or sell your personal data to
third parties. However, we may share anonymized data, derived from tools
like cookies, log files, device identifiers, and location data, with
third-party organizations that provide automated data processing
technologies for Chatomic. Please note that we do not have control over
these third parties' tracking technologies or how they use them.
We may also share certain anonymized data, such as cookie data, with
third-party advertising partners. This information allows these ad
networks to deliver targeted ads that they believe will be of most
interest to you.
In our ongoing commitment to providing and improving our services, we
engage with the following third-party service providers:
OpenAI - AI-generated content provider (https://openai.com/privacy/)
AppsFlyer - Analytics service provider (https://www.appsflyer.com/legal/services-privacy-policy/)
Google - Analytics and marketing service provider (https://policies.google.com/privacy,
https://firebase.google.com/support/privacy)
Chatomic may include links to third-party websites or services, or you may
access Chatomic from a third-party site. We want to make it clear that we
are not responsible for the privacy practices of these third-party sites
or services, including the information or content contained within them.
You are solely responsible for any risk arising from your use of these
third-party websites or resources.
In certain circumstances, we may disclose your personal information where
it is necessary for legitimate reasons, such as public interest or as
required by law. We may also disclose your personal information in good
faith to protect our rights, your safety, or the safety of others,
investigate fraud, or respond to a government request.
In the event of a merger, acquisition, or sale of all or a portion of our
assets, we will notify you via a prominent notice in Chatomic of any
change in ownership or usage of your personal information, as well as any
options you may have regarding your personal information.
13. INTERNATIONAL DATA TRANSFERS
We along with our third-party partners who provide automated data
processing technologies for Chatomic, or our third-party advertising
associates, may transfer the information processed automatically across
international borders and from your jurisdiction to other countries or
jurisdictions worldwide.
Please understand that this may result in the transfer of your data,
including personal information, to a country and jurisdiction that may not
have the same data protection laws as your own. Consequently, your
personal information may be transferred to a third country, a territory,
or one or more specified sectors within that third country, or to an
international organization where data protection and confidentiality
regulations may not offer the same level of protection for personal data
as your jurisdiction.
By utilizing Chatomic, you consent to the transfer of your personal data
to any third country, a territory, or one or more specified sectors within
that third country, or to an international organization.
For data storage purposes, we employ the services of reputable hosting
providers. We prioritize your privacy and, where feasible, encrypt your
personal data before transmitting it to the hosting providers for storage.
Please note that we only collaborate with hosting providers that have met
our stringent security and reliability standards.
14. DATA RETENTION AND USAGE DURATION
We will retain your personal information only for the necessary duration
to provide Chatomic's functional service and to fulfill our legal
obligations. If you decide that you no longer wish for us to use your
information that we physically access and store, you can request that we
delete your personal information and close your account.
However, some data may still be retained for a limited period (but no
longer than necessary) if mandated by law (such as for taxation,
accounting, or auditing purposes), or to ensure data safety and backup,
prevent fraud, or other malicious acts.
15. EXERCISING YOUR RIGHTS
Applicable data protection laws provide you with certain rights regarding
your personal information. The following options are available to you in
relation to your collected personal information:
Data Access and Portability: You can request copies of your personal
information.
Change or Correct Data: If you cannot update data independently through
your account, you have the right to request corrections, changes, updates,
or rectifications to your data.
Data Retention and Deletion: User data is generally retained for as long
as your user profile exists or as it is needed to provide relevant
services. However, specific retention times can vary based on the context
of the processing performed. You have the right to request deletion of all
or some of the personal data held about you.
Restriction of Processing: Under certain circumstances, you may have the
right to limit the ways in which your personal information is used.
To exercise any of the rights described above, please contact us via email
[email protected]. Please note that we can only guarantee the
aforementioned rights concerning the information that we physically access
and store.
If your personal information is being processed automatically, you may
have the right to object to such processing under certain circumstances.
If your personal information is being processed for direct marketing
purposes, you may request us to cease processing your data for these
purposes.
16. OPTING OUT
Opting Out of Location Data Processing
If you prefer not to have your precise location data or street-level
location information utilized by our third-party service providers, please
adhere to the following instructions:
For iOS 11 or later: Disable Location Services for the relevant Chatomic
Product via the menu “Settings > Privacy > Location Services”. Then
select our App and set the “Share My Location” status to “Never”. For more
details, please visit: https://support.apple.com/en-us/HT203033.
Opting Out of Marketing Tracking
If you prefer not to have personalized ads tailored to your interests by
our third-party service providers, please adhere to the following
instructions:
Select "Limit Ad Tracking" on your iOS device in “Settings > Privacy
> Advertising”. For more details, please visit:
https://support.apple.com/en-us/HT202074
Please bear in mind that opting out of interest-based advertising does not
necessarily mean you will no longer receive any ads. You may still receive
contextual ads that are based on non-personal information such as the
content of the Chatomic products you are using.
17. DATA SECURITY
We prioritize the security of your personal information. We have put in
place measures to safeguard your information against loss, misuse,
unauthorized access, disclosure, alteration, and destruction.
It's important to note that no method of transmission over the Internet,
or electronic storage, is 100% secure. While we take all necessary
precautions to protect your personal data, we cannot guarantee complete
security.
18. UPDATES TO THE PRIVACY POLICY
We regularly update this Privacy Policy to keep up with our practices and
legal obligations.
Any changes to this Privacy Policy will be updated and posted on this page
and other relevant locations.
19. CONTACTING US ABOUT THIS PRIVACY POLICY
For any inquiries about this Privacy Policy, please reach out to us using
our support form, or by contacting us at [email protected]