Privacy Policy
Updated Date: Oct 24, 2025, 12:00 AM
Introduction
Brainy ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-assisted development platform, including our website, platform, APIs, SDKs, and related services (collectively, the "Service").
Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not access or use the Service.
1. Information We Collect
We collect several types of information from and about users of our Service.
1.1 Information You Provide Directly
Account Information:
Name and email address
Username and password
Company or organization name
Billing and payment information
Profile information and preferences
Content and Assets:
Data models, behaviours, and widgets you create
Files and documents you upload
Beliefs and development standards you define
Project information and configurations
Comments and feedback you provide
Repository Information:
Git repository connections (GitHub, GitLab, Bitbucket)
Repository names and metadata (subject to OAuth permissions)
Template configurations
Communications:
Support inquiries and correspondence
Survey responses and feedback
Email communications with us
1.2 Information Collected Automatically
Usage Data:
Pages and features accessed
Time spent on the Service
Assets created, modified, and exported
API and SDK usage patterns
Search queries and interactions
Click-stream data
Device and Technical Information:
IP address
Browser type and version
Operating system
Device identifiers
Time zone and location data (general)
Referral source
Crash reports and error logs
Cookies and Tracking Technologies:
Session cookies for authentication
Preference cookies for settings
Analytics cookies for usage analysis
Local storage data
1.3 Information from Third Parties
OAuth Integrations:
Profile information from GitHub, GitLab, or Bitbucket
Repository access permissions you grant
Organization or team memberships (if authorized)
Payment Processors:
Transaction confirmations
Payment status information
2. How We Use Your Information
We use the information we collect for the following purposes:
2.1 Service Provision
Create and manage your Account
Provide access to Service features
Process your transactions and billing
Store and manage your Assets
Generate AI-assisted suggestions based on your Beliefs
Export Assets in requested formats
Integrate with your connected repositories
Provide customer support
2.2 Service Improvement
Analyze usage patterns and trends
Improve AI model accuracy and suggestions
Develop new features and functionality
Test and optimize the Service
Debug and fix errors
Conduct research and development
2.3 Communication
Send Service-related notifications
Respond to your inquiries and requests
Send administrative messages
Provide product updates and announcements
Send marketing communications (with your consent)
2.4 Security and Compliance
Detect and prevent fraud or abuse
Enforce our Terms and Conditions
Comply with legal obligations
Protect our rights and property
Ensure platform security and integrity
2.5 Analytics and Performance
Monitor Service performance and availability
Measure feature usage and engagement
Generate anonymized statistics and insights
Optimize user experience
3. AI and Machine Learning
3.1 AI Training and Improvement
We use aggregated and anonymized data to improve our AI models. This includes:
Patterns in how developers define data models
Common behaviours and logic structures
Frequently used development conventions
Usage patterns across projects
Important: Your specific Beliefs, proprietary Assets, and identifiable Content are NOT used to train general AI models accessible to other users.
3.2 Your Beliefs
Your defined Beliefs are used exclusively to:
Generate personalized AI suggestions for your use
Ensure consistency across your projects
Apply your standards to Asset creation
Your Beliefs remain private to your Account and are not shared with other users or used to train models for others.
3.3 Opt-Out
You may request to opt-out of having your anonymized data used for AI improvement by contacting us at support@brainy.nz.
4. How We Share Your Information
We do not sell your personal information. We share your information only in the following limited circumstances:
4.1 Service Providers
We share information with third-party service providers who perform services on our behalf:
Cloud hosting and infrastructure (data storage)
Payment processing
Email delivery services
Analytics providers
Customer support tools
Security and fraud prevention services
These providers are contractually obligated to protect your information and use it only for specified purposes.
4.2 OAuth Partners
When you connect git repositories, we share limited information with:
GitHub, GitLab, or Bitbucket (as applicable)
Only information necessary for the integration
Subject to the OAuth permissions you grant
4.3 Legal Requirements
We may disclose information if required to:
Comply with legal obligations, court orders, or subpoenas
Enforce our Terms and Conditions
Protect the rights, property, or safety of Brainy, users, or others
Investigate fraud or security issues
4.4 Business Transfers
If Brainy is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.
4.5 With Your Consent
We may share information with third parties when you explicitly consent to such sharing.
5. Data Security
5.1 Security Measures
We implement reasonable technical and organizational measures to protect your information, including:
Encryption in transit (TLS/SSL)
Encryption at rest for sensitive data
Access controls and authentication
Regular security assessments
Secure development practices
Employee training on data protection
Intrusion detection and monitoring
5.2 No Guarantee
However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.
5.3 Your Responsibility
You are responsible for:
Maintaining the confidentiality of your Account credentials
Using strong passwords
Enabling two-factor authentication (if available)
Notifying us immediately of any unauthorized access
5.4 Data Breaches
In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law.
6. Data Retention
6.1 Active Accounts
We retain your information for as long as your Account is active or as needed to provide the Service.
6.2 After Account Termination
Following Account termination or deletion request:
We retain some information for legitimate business purposes (e.g., billing records, dispute resolution)
Personal data is deleted or anonymized within 90 days unless legally required to retain
Backup copies may persist for up to 180 days
6.3 Legal Obligations
We may retain information longer if required by law, regulation, or legal proceedings.
6.4 Anonymized Data
We may retain anonymized, aggregated data indefinitely for analytics and improvement purposes.
7. Your Rights and Choices
7.1 Access and Portability
You have the right to:
Access your personal information
Export your Assets and data
Request a copy of your data in a portable format
7.2 Correction and Updates
You can:
Update your Account information through settings
Correct inaccurate personal data
Request that we correct errors
7.3 Deletion
You may:
Delete your Account through settings or by contacting us
Request deletion of specific data
Note: some data may be retained for legal or business purposes
7.4 Opt-Out of Marketing
You can:
Unsubscribe from marketing emails via the link in any message
Update email preferences in Account settings
Note: you will still receive Service-related communications
7.5 Cookie Management
You can:
Control cookies through your browser settings
Opt-out of analytics cookies
Note: some cookies are essential for Service functionality
7.6 Do Not Track
Our Service does not currently respond to "Do Not Track" signals.
7.7 Exercising Your Rights
To exercise these rights, contact us at support@brainy.nz. We will respond within a reasonable timeframe as required by applicable law.
8. International Data Transfers
8.1 Global Operations
Your information may be transferred to and processed in countries other than New Zealand, including countries that may have different data protection laws.
8.2 Safeguards
When transferring data internationally, we ensure appropriate safeguards are in place, such as:
Standard contractual clauses
Privacy Shield frameworks (where applicable)
Other legally recognized transfer mechanisms
8.3 Consent
By using the Service, you consent to the transfer of your information to other countries.
9. Children's Privacy
9.1 Age Restriction
The Service is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18.
9.2 Parental Notice
If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@brainy.nz.
9.3 Deletion
If we learn we have collected information from a child under 18, we will delete that information promptly.
10. Third-Party Links and Services
10.1 External Links
The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties.
10.2 Third-Party Responsibility
We encourage you to read the privacy policies of any third-party services you access through our Service.
10.3 OAuth Providers
Your use of GitHub, GitLab, Bitbucket, and other integrated services is subject to their respective privacy policies.
11. Repository and Code Privacy
11.1 Repository Access
We only access repositories you explicitly connect through OAuth authorization. Access is limited to the permissions you grant.
11.2 Code Confidentiality
We treat your repository code and templates as confidential information:
We do not share your code with other users
We do not use your code to train public AI models
We access code only as necessary to provide the Service
11.3 Exported Code
Once you export code from Brainy, that code is yours to use without restriction. We do not track or monitor exported code usage.
12. California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
12.1 Right to Know
You have the right to request:
Categories of personal information collected
Categories of sources
Business purpose for collection
Categories of third parties we share with
Specific pieces of personal information collected
12.2 Right to Delete
You have the right to request deletion of your personal information, subject to certain exceptions.
12.3 Right to Opt-Out
You have the right to opt-out of the "sale" of personal information. We do not sell personal information.
12.4 Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA rights.
12.5 Exercising CCPA Rights
To exercise these rights, contact us at support@brainy.nz. We will verify your identity before processing requests.
13. European Privacy Rights (GDPR)
If you are in the European Economic Area (EEA), UK, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):
13.1 Legal Bases for Processing
We process your personal data based on:
Contract performance (to provide the Service)
Legitimate interests (to improve and secure the Service)
Consent (for marketing and optional features)
Legal compliance (to comply with laws)
13.2 GDPR Rights
You have the right to:
Access your personal data
Rectify inaccurate data
Erase your data ("right to be forgotten")
Restrict processing
Data portability
Object to processing
Withdraw consent
Lodge a complaint with a supervisory authority
13.3 Data Protection Officer
For GDPR-related inquiries, contact us at support@brainy.nz.
13.4 International Transfers
We ensure appropriate safeguards for data transfers outside the EEA.
14. Changes to This Privacy Policy
14.1 Updates
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date.
14.2 Material Changes
For material changes, we will:
Notify you via email
Display a prominent notice on the Service
Provide reasonable advance notice
14.3 Continued Use
Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.
14.4 Review
We encourage you to review this Privacy Policy periodically.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Email: support@brainy.nz
Website: https://brainy.nz
Mailing Address:
Brainy
Auckland, New Zealand
We will respond to your inquiry within a reasonable timeframe, typically within 30 days.
16. Definitions
For purposes of this Privacy Policy:
"Personal Information" means information that identifies, relates to, or could reasonably be linked with you
"Process" or "Processing" means any operation performed on personal information, including collection, storage, use, and disclosure
"Service" means Brainy's platform, website, APIs, SDKs, and related services
"You" or "User" means the individual or entity using the Service
Acknowledgment
BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY.