PRIVACY POLICY

This Privacy Notice for SC MUSINOX ASSET MANAGEMENT SRL ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

• Download and use our mobile application (Brainbank), or any other application of ours that links to this Privacy Notice
• Use Brainbank. Brainbank is a mobile flashcard application that helps users learn and retain information through scientifically-proven spaced repetition techniques.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at marius@brainbank.space.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Email addresses
• User ID (automatically generated)

Sensitive Information. We do not process sensitive information such as racial or ethnic origins, sexual orientation, or religious beliefs.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by RevenueCat and your device's app store (Apple App Store or Google Play Store). You may find their privacy notice links here: https://www.revenuecat.com/privacy/

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address.

User-Generated Content. We collect flashcard content (questions, answers, cloze text), deck names and descriptions, and deck customization settings (colors, icons) that you create within the app.

Study Performance Data. We automatically track your card review history, review ratings, FSRS algorithm data (stability, difficulty, review intervals, card state), quiz session data, study streak information, and daily study activity for the heatmap calendar. This data is used to optimize your spaced repetition scheduling and show you progress statistics.

Camera and Photo Library Access. If you grant permission, we access your device's camera and photo library to allow you to add images to your flashcards. Images are automatically compressed (to 800px width, 80% JPEG quality) before upload to optimize storage and performance. We do not access your camera or photos for any other purpose, and we do not use facial recognition or analyze image content.

Profile Picture. If you choose to upload a profile picture, the image is stored in Firebase Storage and associated with your account. You can update or remove your profile picture at any time from the Profile screen.

Local Device Storage. The app stores your flashcard data, images, and study progress locally on your device for offline access. This cached data is automatically synced with our cloud servers when you have internet connectivity.

Brainbank Certified Decks. We provide pre-made, verified flashcard decks ("Certified Decks") that users can add to their accounts. When you add a Certified Deck, the deck content is copied to your personal account. Your study progress (FSRS scheduling data) remains private and is not shared. We may automatically update Certified Deck content to add new cards or correct errors, but updates preserve your existing study progress. We track which Certified Decks users have added for analytics and update purposes.

User Preferences and Settings. We store your quiz answer mode preferences, notification settings, FSRS algorithm parameters, theme preferences, and analytics opt-out preferences.

Analytics and Usage Data. We use Mixpanel, a third-party analytics service, to understand how users interact with our application. Mixpanel collects information about your usage patterns, feature interactions, subscription events, and device identifiers. This helps us improve the app experience and develop new features. Mixpanel's privacy policy is available at: https://mixpanel.com/legal/privacy-policy/. You can disable analytics tracking in Settings → Analytics toggle.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Information Automatically Collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Firebase Services

We use Google Firebase to provide secure cloud storage and authentication services. Firebase stores your account information, flashcards, decks, and study progress, and enables synchronization across your devices. Our use of Firebase adheres to Google's privacy and security standards. You can learn more about Firebase's data practices at: https://firebase.google.com/support/privacy

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To track and analyse usage patterns and app performance to understand how users interact with our Services and improve the user experience.
• To provide spaced repetition learning features by processing your study session data, review history, and performance metrics to implement the FSRS algorithm that optimises your learning schedule.
• To send notifications including daily reminders, overdue alerts, and streak notifications based on your preferences.
• To generate AI-powered flashcards by processing your prompts through Google's AI services (Premium feature, coming soon).
• To comply with legal obligations and protect our legal rights.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us at marius@brainbank.space.

Performance of a Contract. We process your information to provide you with our Services and fulfil our contract with you.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the 'data controller' under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform.

If you are located in Canada

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We share your personal information with the following third-party service providers to operate our Services:

Error Tracking. We use Sentry to track errors and crashes in production. Sentry collects error messages, stack traces, device information, and user identifiers to help us identify and fix issues. Sentry does NOT collect your flashcard content, deck names, or study data. Unlike analytics, error tracking cannot be disabled as it is essential for maintaining app stability.

We may also need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal Requirements. We may disclose your information if required to do so by law or in response to valid requests by public authorities.

We do NOT sell your personal information to third parties.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ('AI Service Providers'), including Google Cloud AI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI-powered flashcard generation: Generate flashcards based on your prompts and requests (Premium feature, coming soon)

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.

Important: We only send your prompts and generation requests to AI services. We do NOT send your existing flashcard content to AI services.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.

• Active accounts: Data stored indefinitely while you use the App
• Deleted accounts: All user data deleted within 30 days
• Backup archives: May remain in backup archives for up to 90 days after deletion
• Analytics: Anonymized usage data may be retained for statistical purposes

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

Our security measures include:

• Passwords are hashed and never stored in plain text
• Data transmission is encrypted using SSL/TLS protocols
• Firebase security rules restrict unauthorized access
• Regular security audits and updates

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly collect, solicit data from, or market to children under 13 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 13 years of age. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

If you become aware of any data we may have collected from children under age 13, please contact us at marius@brainbank.space.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

You can:

• Access your data: View your data within the App or request a copy
• Update your information: Modify your email, settings, flashcards, and preferences at any time
• Delete your account: Delete your account and all associated data (Settings → Delete Account)
• Export your data: Export your flashcards and study data
• Opt-out of analytics: Disable usage tracking (Settings → Analytics toggle)
• Control notifications: Manage notification preferences in Settings

To exercise these rights, contact us at marius@brainbank.space. We will respond to your request within 30 days.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at marius@brainbank.space or updating your preferences in the App.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Additional Rights for California Residents (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and disclose
• Request deletion of your personal information
• Opt-out of the sale of personal information (Note: We do not sell personal information)
• Non-discrimination for exercising your privacy rights

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

Your continued use of the Services after changes become effective constitutes acceptance of the updated policy.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at marius@brainbank.space.

SC MUSINOX ASSET MANAGEMENT SRL

Romania

If you are a resident in the European Economic Area, we are the 'data controller' of your personal information. You can contact us directly regarding our processing of your information, by email at marius@brainbank.space.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. To request to review, update, or delete your personal information, please contact us at marius@brainbank.space.

By using Brainbank, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

© 2025 SC MUSINOX ASSET MANAGEMENT SRL. All rights reserved.