Effective date: April 13, 2026

1. About This Service

Brambin (hereinafter "the App") is an entertainment application provided by KUBOYA Inc. (hereinafter "the Company"). The App provides cognitive games for entertainment purposes. The App is not a medical device, psychological assessment tool, or clinical test. All scores and results are for entertainment purposes only and do not constitute a diagnosis or evaluation of actual intelligence.

This policy applies to users worldwide. Certain provisions below apply to specific jurisdictions.

2. Information We Collect

Information Collected Automatically

Game data (scores, play time, achievements)
Device identifier (a randomly generated anonymous ID)
Device information (device model, OS version)
Usage data (access date/time, features used, error logs)

Payment Information

Purchase history (purchased items, purchase date, platform)
Credit card and payment details are not collected by us — they are securely managed by Apple/Google.

Information NOT Collected

We do not collect your name, email address, phone number, or other personally identifiable information.
No account registration is required to use the App.

3. Purpose of Use

Providing, operating, and improving the App
User support and inquiry response
Prevention of unauthorized use and security assurance
Usage analysis and service improvement
Compliance with applicable laws

4. Legal Basis for Processing

We process information on the following legal bases:

Contract performance: Processing necessary to provide the App's core functionality (game data, scores)
Legitimate interests: Usage analysis and service improvement, security and fraud prevention
Legal obligation: Compliance with applicable laws

For users in the European Economic Area (EEA) and UK, this is pursuant to Articles 6(1)(b), 6(1)(f), and 6(1)(c) of the GDPR respectively.

5. Third-Party Disclosure

We do not sell, trade, or share collected information with third parties except as required by law or as described in Section 6.

We do not sell personal information as defined under the California Consumer Privacy Act (CCPA). We do not share personal information for cross-context behavioral advertising.

6. External Services

The App and website use the following external services:

Apple App Store / Google Play Store (payment processing)
Supabase (cloud database for storing game data — servers located in the United States)
Google Analytics (usage analysis on website)

Each external service has its own privacy policy governing the handling of data.

7. Data Management

We take appropriate technical and organizational measures to manage collected information and prevent unauthorized access, loss, or alteration. Data is transmitted using encryption (TLS/SSL).

8. Retention and Deletion

We retain information only for the period necessary to fulfill the stated purposes. Specifically: game data and scores are retained for the duration of app usage; usage analytics are retained for up to 24 months. Users may request deletion of their data at any time by contacting us at the email address below. We will process deletion requests within 30 days.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your data:

Right to access your data
Right to correct inaccurate data
Right to request deletion of your data
Right to data portability
Right to restrict or object to processing

To exercise any of these rights, please contact us at the email address below.

For users in the EEA/UK: You also have the right to lodge a complaint with your local data protection supervisory authority (e.g., the ICO in the UK, or the relevant DPA in your EU member state).

For California residents: You have the right to know what personal information is collected, the right to delete, and the right to non-discrimination for exercising your rights.

10. Children

The App is not intended for children under 13 years of age (or under 16 in the EEA/UK, under 14 in South Korea and China, or under 18 in India, as applicable). We do not knowingly collect information from children under these ages. If we learn that we have collected information from a child below the applicable age threshold, we will delete it promptly. If you are a minor above the applicable age threshold but under 18, please use the App with parental or guardian consent.

11. International Data Transfers

Your data may be processed and stored on servers located outside your country of residence. For users in the EEA/UK, transfers are conducted pursuant to Standard Contractual Clauses (SCCs) approved by the European Commission. For users in other jurisdictions, by using the App you acknowledge that your data may be transferred internationally.

12. Data Breach Notification

In the event of a data breach that poses a risk to your rights, we will notify the relevant supervisory authorities and affected users in accordance with applicable laws.

13. Changes to This Policy

This policy may be updated as needed. Material changes will be communicated through the App or our website. Continued use after changes constitutes acceptance.

14. Contact

KUBOYA Inc.
3-1 Nihonbashi Tomizawacho, Chuo-ku, Tokyo 103-0006, Japan
Email: info@kuboya-biz.jp

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