Personal Information Governance Policy

Last updated: October 12, 2026

Vinci Brain is made by one independent developer, Arnaud Bastin, based in Quebec. This policy explains how we govern the personal information the app processes. The detail of the data, the providers and your rights is in our Privacy Policy (vincibrain.com/privacy/).

Roles and responsibilities

Arnaud Bastin is the only person running Vinci Brain. He is the person in charge of the protection of personal information and the only person at Vinci Brain with access to it (the providers listed in the Privacy Policy access it only to provide their service, under contract). He:

• decides which data the app collects, and collects only what is necessary;
• assesses privacy factors before entrusting information to a provider or communicating it outside Quebec;
• chooses providers bound by a written data protection agreement;
• answers requests for access, correction and deletion;
• keeps the register of confidentiality incidents and notifies the Commission d’accès à l’information and the people concerned when an incident presents a risk of serious harm.

Contact: [email protected], +1 438 365 5607, 2100 avenue Papineau, apt. 307, Montreal (Quebec) H2K 4J4.

Retention and destruction

• Information tied to an account is kept as long as the account exists and destroyed when it is deleted, which every user can do in the app. For a guest account, usage statistics and the purchase provider’s random identifier are linked to nothing else; the statistics expire after 1 year.
• Technical data is destroyed automatically: hosting logs after 1 day, diagnostics after 30 days, app update provider request logs after 90 days at most, usage statistics after 1 year. No database backups are kept.
• Emails we receive are kept as long as needed to answer, then up to 1 year.
• Age is never kept.
• Retention for each category is detailed in the Privacy Policy, section 7.

Complaints

1. Write to [email protected] describing your complaint.
2. We acknowledge it and answer in writing within 30 days.
3. If the answer does not satisfy you, you can contact the Commission d’accès à l’information du Québec (cai.gouv.qc.ca).

Training and awareness

Arnaud Bastin keeps informed of the applicable obligations and reviews this policy at least once a year.