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Privacy Policy

Last updated: October 12, 2026

This policy explains what Vinci Brain does with your personal information. It is information for you: you do not have to accept it. Version française : vincibrain.com/fr/privacy/ (or set the app language to French in Settings).

1. Who is responsible for your data

Vinci Brain is made by one independent developer, Arnaud Bastin, based in Quebec (Canada), referred to below as “we”.

Arnaud Bastin is also the person in charge of the protection of personal information (Quebec Law 25) and our contact for data protection in Brazil (encarregado, LGPD). Our governance policy for personal information is published at vincibrain.com/privacy-governance/.

2. Where this policy applies

Vinci Brain is available worldwide. This policy applies to every user, wherever they live. Section 10 adds the rights that specific laws give you depending on where you live (Quebec and Canada, European Union and EEA, United Kingdom, Switzerland, United States, Brazil). If the law of your country gives you more rights than this policy describes, you keep them.

3. Data we collect

Your account

Your learning

Purchases

Technical data

Anonymous onboarding statistics

What stays on your device

What we do not collect

4. Why we use your data, and on what basis

Apart from the age check (section 9), we make no automated decisions about you, and we do not profile you.

Under Quebec Law 25 and PIPEDA, we use your information only for these purposes. We ask your consent for anything that is not necessary to provide the service.

5. Who receives your data

We do not sell your personal information and do not share it for advertising. The following providers process it on our behalf, under contracts that require them to protect it at least as well as this policy does:

We give the names of our providers on request ([email protected]).

Apple and Google act as independent controllers when you sign in with their account or buy through their store: their own privacy policies apply to that part.

Emails you send us are handled by our email service providers, in the United States, under their own terms.

6. Transfers outside Quebec and outside your country

Your information is processed outside Quebec, mainly in the European Union, and in the United States by our purchase provider, our app update provider and for the emails you send us. The providers of section 5 are companies established in the United States. Their data processing agreements include the European Commission’s standard contractual clauses for transfers out of the EU; you can ask us for a copy. We assessed each of these transfers as required by Quebec Law 25 (privacy impact assessment).

7. How long we keep your data

8. Your rights

You can, at any time:

To exercise a right by email, write to [email protected]. We answer within 30 days. We may ask you to write from the email address of your account to confirm it is yours.

9. Age and children

10. Rights depending on where you live

Quebec and Canada

Quebec Law 25 and PIPEDA apply. You can complain to the Commission d’accès à l’information du Québec (CAI) or to the Office of the Privacy Commissioner of Canada (OPC).

European Union, EEA, United Kingdom, Switzerland

The GDPR (UK GDPR in the United Kingdom, the Federal Act on Data Protection in Switzerland) gives you the rights of section 8, plus the right to data portability. You can complain to the data protection authority of your country (in the United Kingdom, the ICO; in Switzerland, the FDPIC).

United States

We do not sell or share your personal information and do not use it for targeted advertising. The rights of section 8 apply wherever you live in the United States.

Brazil

The LGPD gives you the rights of section 8, including confirmation that we process your data. You can complain to the ANPD.

Other countries

The rights of section 8 apply to every user.

11. Security and incidents

Data is encrypted in transit. Access to the database is restricted by per-user access rules, so that each account can only reach its own data. No system is infallible. If an incident creates a risk of serious harm, we notify the competent authorities and the people concerned, as the law requires. We keep a register of incidents.

12. Changes

When we change this policy, we update the date above and publish the new version in the app and at vincibrain.com/privacy/. If a change requires your consent, we ask for it before applying the change.

13. Contact

For any question about this policy or your data: [email protected]