The mission of Ignite Brain Training app is to help improve individual brain power and cognitive strength. This privacy statement and our other actions are tailored to achieve this Mission.

We believe that privacy is fundamental to creating an environment where users can focus on their cognitive development without concerns about their personal data. Our approach to privacy is designed to support our Mission by:

1. Minimizing Distractions: By not collecting personally identifiable information, we allow users to concentrate fully on their cognitive training.
2. Promoting Autonomy: Keeping all performance data solely on the user’s device empowers individuals to have complete control over their cognitive development journey.
3. Fostering Trust: Our transparent and privacy-first approach aims to build the trust necessary for users to engage deeply with their cognitive training.
4. Ensuring Accessibility: By complying with global privacy standards, we strive to make our cognitive development tools accessible to users worldwide.
5. Adapting Responsibly: Any future changes to our data practices will be carefully considered to ensure they align with and support our Mission of cognitive development.

This mission-driven approach to privacy underlines our commitment to your cognitive growth and personal data protection. As we continue to develop and improve Ignite Brain Training, our dedication to this Mission and to safeguarding your privacy will remain paramount.

Privacy by Design

Any information we do collect is in pursuit of our Mission. For example, email addresses may be collected during customer support interactions to provide assistance to our users.  Bringing these communications to a successful resolution is critical to our Mission to facilitate the development of individual cognitive strength and capacity.

While we focus on our Mission, it is important to note the following practices are contrary to the Ignite Brain Training’s mission:

• Delivering advertising for other products through the Ignite Brain Training app. This distracts users from developing cognitive strength and capacity.
• Collecting user information for any purpose other than improving the quality of the Ignite Brain Training app. This violates the trust of our users and hinders our ability to deliver on our Mission.
• Selling user information to other parties, as this violates the trust of our users and impedes the development of individual cognitive strength and capacity.

This mission-driven approach to privacy underlines our commitment to your personal data protection as well as your cognitive growth. As we continue to develop and improve Ignite Brain Training, our dedication to this Mission and to safeguarding your privacy will remain paramount.

If you have any questions about this policy or other matters, please reach out to us at [email protected].

Data Collection and Usage

User-Provided Information

• App Store Transactions: Ignite Brain Training is currently sold through the Apple App Store.
• No Personal Data Exposure: The App Store handles all aspects of the purchase transaction for the Ignite Brain Training license.
• Privacy Protection: Double Squeeze Productions, LLC does not receive any personally identifiable data from these transactions.
• Limited Information: We only receive anonymous purchase confirmations, which allow us to validate app licenses without compromising user privacy.
• User Control: Your personal and payment information remains solely with Apple, Inc., aligning with our commitment to data minimization and user privacy.

This arrangement ensures that your financial and personal information is handled securely by Apple, Inc., while allowing us to focus on providing you with the best possible brain training experience.

For more information on how Apple, Inc. handles purchase data, you can refer to their privacy policy at https://www.apple.com/legal/privacy/en-ww/.

Information Obtained through Ignite Brain Training Use

• Local Data Storage: Ignite Brain Training currently stores all performance-related data locally within the application on your device.
• No External Data Transmission: We do not send any of your performance data outside the application.
• Types of Data Stored: Performance data includes:
  • Time spent using the application
  • Exercises completed
  • Performance scores on exercises
• Data Purpose: This data is stored to calculate your performance history and time spent on-task, consistent with our Mission of aiding cognitive development.
• Anonymity: None of this stored data, by itself, identifies you as an individual.
• Potential Future Changes:
  • Double Squeeze Productions, LLC may modify this policy in the future to collect data that helps us achieve our Mission and improve Ignite Brain Training.  An example would be tooling that collects data on application crashes.
  • User Consent: We will ask for your explicit permission before implementing any changes that affect your data collection.
  • Opt-In Approach: We do not collect your data without your explicit permission.
• Transparency Commitment: Any changes to our data collection practices will be clearly communicated to you, along with the reasons for these changes and how they align with our Mission.

Third-Party Data

Current Practice:

• No External Data Sharing: Aside from Apple, Inc. (for app purchases), no external parties obtain any data about your purchase or use of Ignite Brain Training.
• Privacy-First Approach: This aligns with our commitment to protecting your privacy and minimizing data exposure.

Potential Future Practices:

• We may consider using third-party services (such as Crashlytics) to help improve the quality of our product.  Any future third-party integrations will be carefully evaluated to ensure they meet our high privacy standards.
• Purpose: Any such future data collection would be solely to enhance app performance and user experience, consistent with our Mission.
• User Consent: You will always be asked to explicitly agree to any new data collection before it is implemented.
• Transparency: We will provide clear information about what data would be collected and how it would be used.

User Control:

• You will always have the option to decline any new data collection practices.
• Declining will not affect your ability to use the core features of Ignite Brain Training.

Cookies and Tracking Technologies

We do not use cookies or similar technologies to recognise you when you visit our website.  If we were to do so in the future you would be asked to agree to a notification on our website before we inserted cookies on your browser.

Data Minimization

Data minimization is a crucial principle in protecting user privacy. It involves collecting and processing only the data that is absolutely necessary for the specific purpose of the application. By limiting data collection to what is essential, we reduce the risk of data breaches, minimize the potential for misuse, and enhance user trust. Data minimization also simplifies compliance with privacy regulations and demonstrates our commitment to respecting user privacy. In practice, this means we carefully consider the necessity of each piece of data we collect, ensuring that we gather only what is required to provide and improve our service.

Data Storage and Protection

Apple, Inc. Integration and Data Handling

Our app integrates with Apple Inc.’s systems in the following ways:

• Authentication: We use Apple Inc.’s authentication systems to verify user identity. This is a standard part of iOS app operations.
• Data Shared with Apple: Some basic information may be shared with Apple, including:
  • Your Apple ID (but not your password)
  • App usage data
• Apple’s Privacy Policy: All data shared with Apple, Inc. is handled in accordance with Apples privacy policy here:  https://www.apple.com/legal/privacy/.
• Limited Data Sharing: Beyond this necessary interaction with Apple, Inc.’s systems, we do not share your personal data with any other third parties.
• Local Data Storage: All performance data and app-specific information is stored locally on your device. This means:
  • Your data is not transmitted to our servers
  • Your data is not sent to any external services aside from Apple Inc.
  • You retain full control over your data

We prioritize your privacy by minimizing data sharing and maximizing local data storage. This approach ensures that your cognitive training data remains private and under your control.

For more information on how Apple, Inc. handles data for iOS apps, please refer to the Apple, Inc. privacy policy linked above.

Customer Service Interactions

The Ignite Brain Training app does not collect personally identifiable data about you. 

However, certain interactions may involve limited personal information:

• Email Communication: If you contact our customer support, you will expose your email address and possibly your name during the exchange.
• Data Protection: We treat these email addresses with the utmost confidentiality:
  • Emails are not shared with outside parties
  • Emails are used solely for customer support purposes
• Data Retention: We keep these email addresses only for the duration necessary to assist you:
  • We delete your email address within seven (7) days of your request to do so
  • If there’s no specific request, we delete your emails within thirty (30) days of your last correspondence with us
• Purpose Limitation: These email addresses are used exclusively for customer support activities and are not used for marketing or any other purposes.

Our approach to handling customer service data aligns with our overall commitment to privacy and data minimization. We collect only what’s necessary to assist you and retain it only for as long as it’s needed.

If you have any concerns about your data during customer service interactions, please don’t hesitate to mention this in your communication with our support team.

Data Retention

As mentioned above, the Ignite Brain Training app does not send any data to our servers.  Therefore, we do not retain any performance data for any user.

Email interactions are stored for the longer of seven days after a request to delete or 30 days after the last interaction with that email address.

Your Privacy Rights and Choices

The Ignite Brain Training app doesn’t collect any personal data. If this changes in the future, we’ll ask for your permission first.

We respect your right to control your personal data. Depending on your location, you may have the following rights:

1. Access: Review the personal data we hold about you.

2. Correction: Update or correct inaccuracies in your personal data.

3. Deletion: Request the erasure of your personal data, subject to legal requirements.

4. Objection: Oppose the processing of your personal data for certain purposes.

5. Restriction: Limit how we use your personal data.

6. Portability: Receive your personal data in a machine-readable format (for EEA users).

7. Consent Withdrawal: Revoke your consent for data processing activities based on consent.

To exercise these rights, please contact us at support@IgniteBrainTraining.com.

Data Portability

     At Ignite Brain Training, we believe in giving you full control over your data. Here’s how we ensure this:

     Local Data Storage:

•        All your Ignite Brain Training performance data is stored locally on your iPhone.
•        No performance data is ever sent from your device to our servers or any third parties.     

     Data Access:

•        Since all data is on your device, you have direct and immediate access to all your performance information through the app interface.

     Data Deletion:

•        You have the ability to delete all your performance data at any time.
•        To do this:

 1. Go to the main Settings screen (tap “Settings” on the main Ignite Brain Training screen)

2. Click “Delete Exercise History”

3. This action permanently deletes all user data from your device.

     Data Backup:

•        Your Ignite Brain Training data can be included in your regular iPhone backups.
•        This allows you to transfer your data to a new device if needed

     No Server-Side Data:

•       As we don’t store any of your data on our servers, there’s no need for traditional data portability requests to us.

     Privacy by Design:

•        Our local-only data storage approach ensures that you always have full control over your data.
•        This design aligns with our commitment to user privacy and data protection.

     Remember, once you delete your data using the “Delete Exercise History” function, it cannot be recovered unless you have a backup. We encourage you to consider your decision carefully before deleting your exercise history.

General Rights

The only data we store are customer service emails.  The deletion policy for these emails is  described elsewhere.

Additional Rights for Specific Regions

Nevada Residents

Nevada law provides the right to opt-out of the sale of certain personal information to third parties.

Virginia Residents

The Virginia Consumer Data Protection Act (VCDPA) provides you with rights to access, correct, delete your personal data, and opt-out of personal data processing for targeted advertising.  If we decline to take action on your data rights request, you may appeal our decision by contacting us at [email protected] with the subject line “Appeal of Refusal to Take Action on Privacy Request”. We will respond to your appeal within 60 days, providing a written explanation of our decision. If your appeal is denied, you may contact the Office of the Virginia Attorney General for further assistance.

California Privacy Rights (CCPA Compliance)

As required by the California Consumer Privacy Act (CCPA), we provide the following breakdown of personal information categories collected and disclosed in the past 12 months:

Only email addresses obtained as a by-product of customer service interactions.  These are handled as described above.

General Data Protection Regulation (GDPR)

Data collected from users in the European Economic Area (EEA) is processed under various legal bases as outlined in the GDPR. These include your consent, performance of our contract with you, our legitimate interests, and compliance with legal obligations.

Legal Bases for Processing (EEA Users)

For users in the European Economic Area (EEA), we process your personal data under the following legal bases:

1. Your Consent: For sending marketing emails (which you can withdraw at any time).

2. Performance of Contract: To provide our services, manage your account, process payments, and communicate regarding service usage.

3. Legitimate Interests: For research and analysis, personalized advertising, enforcing our Terms of Service, and preventing fraud. Our legitimate interests are balanced against your rights and interests.

4. Legal Obligations: To comply with applicable laws and regulations.

Other details

Service Provider Details

We work with various service providers to deliver and improve our services. Key providers include:

• Host Gator for web hosting.
• Apple, Inc. for authentication and payments processing

Each of these providers processes your data in accordance with our instructions and their own privacy policies. We encourage you to review their policies for more information on their data practices.

Age Restrictions

Our services are not intended for individuals under 16 years of age. We do not knowingly collect or process personal data from children under 16 (or any other user). If we become aware that we have inadvertently collected such data, we will take prompt steps to delete it.

Do Not Track Requests

Ignite Brain Training website does not currently support “Do Not Track” browser requests. 

Data Controller

Double Squeeze Productions, LLC, registered at 47 Wood Ave Suite 2 Barrington RI 02806, is the data controller responsible for the processing of your personal data as described in this Privacy Policy.

Governing Law and Dispute Resolution

Applicable Law:

• This Privacy Policy is governed by and construed in accordance with the laws of the State of Rhode Island, United States, without regard to its conflict of law provisions.

Dispute Resolution:

• In the event of any dispute, claim, question, or disagreement arising from or relating to this Privacy Policy or the breach thereof, the parties shall use their best efforts to settle the dispute, claim, question, or disagreement amicably through good-faith negotiations.

Arbitration:

• If the parties do not reach a solution within a period of 30 days, then upon notice by either party to the other, all disputes, claims, questions, or differences shall be finally settled by arbitration:
  • The arbitration shall be conducted in Rhode Island, United States
  • The arbitration shall be administered by American Arbitration Association
  • The arbitration shall be conducted in the English language
  • The arbitration shall be conducted by a single arbitrator

Limitation on Claims:

• Any claim or cause of action arising out of or related to this Privacy Policy must be filed within one (1) year after such claim or cause of action arose, regardless of any statute or law to the contrary.

Class Action Waiver:

• Any proceedings to resolve or litigate any dispute in any forum will be conducted solely on an individual basis. Neither you nor we will seek to have any dispute heard as a class action or in any other proceeding in which either party acts or proposes to act in a representative capacity.

Severability:

• If any provision of this section is found to be unenforceable, that provision will be severed with the remainder of this section remaining in full force and effect.

Data Breach Notification:

While we take extensive measures to protect your data, we are committed to transparent communication in the unlikely event of a data breach. Our notification process includes:

1. Timely Notification: We will inform affected users as quickly as possible upon discovering and confirming a data breach.
2. Multiple Communication Channels: We will notify impacted users through:
   • Email: Using email addresses available to us from customer support interactions
   • Website: A prominent notification on our homepage at www.IgniteBrainTraining.com
   • In-App Alert: If technically feasible, we will push an in-app notification
3. Information Provided: Our notification will include:
   • The nature of the data breach
   • The type of data potentially affected
   • Steps we are taking to address the breach
   • Recommendations for users to protect themselves
   • Contact information for further inquiries
4. Regulatory Compliance: We will comply with all applicable laws regarding data breach notifications, including any required reporting to regulatory authorities.
5. Ongoing Updates: We will provide regular updates on our website about the status of the breach and our response.
6. Preventive Measures: Following any breach, we will conduct a thorough review of our security practices and implement necessary improvements to prevent future incidents.

It’s important to note that due to our minimal data collection practices and local storage of performance data, the risk and potential impact of a data breach are significantly reduced.

Data Sharing and Third-Party Services

Our approach to data sharing and third-party services is guided by a commitment to our Mission, which depends on user privacy and transparency. We do not sell user data to third parties. We regularly review our data sharing practices to ensure they align with our privacy commitments and comply with applicable regulations.

Corporate Transactions

The Ignite Brain Training app doesn’t collect any personally identifiable data.  If the Ignite Brain Training app were to be acquired by another organization there would be no personal data transferred.

Third-Party Services

We use no third-party services that collect or use personally-identifiable data.

Data Retention

We retain your personal data for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements.  This is limited to email exchanges as described above.

Data Deletion

Performance data stored on the user’s iphone and our servers can be deleted through the application.  Go to the main Setting screen (on the main Ignite Brain Training screen) and click “Delete Exercise History”.  This action deletes all user data from your device.

Deletion of email exchanges is described above.

Changes to This Privacy Policy

We are committed to maintaining transparency about our data practices. While we strive to maintain consistency in our privacy practices, we may occasionally need to update this Privacy Policy. Here’s how we manage changes:

1. Policy Updates:
   • We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or app functionality.
2. Notification of Changes:
   • For significant changes: We will notify you through prominent in-app notifications and, if we have your email address, via email.
   • For minor changes: Updates will be posted on our website and within the app’s Privacy Policy section.
3. Effective Date:
   • Each version of the Privacy Policy will include an effective date at the top of the document.
4. Review Period:
   • We will provide a reasonable period between announcing changes and implementing them, allowing you time to review the updates.
5. User Consent:
   • For material changes that affect data collection or use, we may require your explicit consent before implementing the changes.
6. Continued Use:
   • Your continued use of our services after the effective date of any modifications constitutes your acceptance of the updated Privacy Policy.
7. Historical Versions:
   • We will maintain an archive of previous versions of the Privacy Policy, which you can request by contacting us.
8. Questions and Concerns:
   • If you have any questions or concerns about changes to our Privacy Policy, please contact us at [email protected].

We encourage you to periodically review this Privacy Policy to stay informed about how we protect your data. Your privacy is important to us, and we are committed to being open about any changes to our practices.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: [email protected]

Double Squeeze Productions, LLC

47 Wood Ave Suite 2 

Barrington, RI 02806

Acknowledgment

By using the Ignite Brain Training app , you acknowledge that you have read and understood this Privacy Policy and agree to the practices described herein.

Last Updated:Oct 3, 2024