1. Introduction

1.1 This Privacy Policy explains how Brainy Bot, Inc (“Brainy Bot“, “we“, “us“) collects, uses, discloses, and safeguards Personal Information when you use www.brainybotva.com (the “Site“) and our Services (AI education for business professionals, a private community on Discord and Skool, and custom AI systems for businesses).

1.2 Audience. Our Services are for business professionals aged 18+. We do not knowingly collect Personal Information from children.

1.3 Controller. For the Site and most Services we act as a controller. For any client projects where we process Personal Information on a client’s documented instructions, we act as a processor under the applicable DPA.

1.4 Hosting & Transfers. We host Brainy Bot systems in the United States. If you access the Services from outside the U.S., your information will be transferred to and processed in the U.S. by Brainy Bot and our service providers. Some third-party providers (e.g., PayPal/GoCardless/Discord/Skool) may process data globally per their own policies.

1.5 Governing Law / Local Rights. This policy is governed by Oregon, USA law contractually, but you may have additional rights under your local law. See Section 12 (Regional Disclosures).

2. Definitions

2.1 Personal Information (or Personal Data) means any information that identifies, relates to, describes, or can reasonably be linked to an identifiable individual.

2.2 Services means our AI education, AI professional community, and custom AI system development/consulting.

2.3 Community Platforms means third-party platforms we use to host our community, currently Discord and Skool.

3. What we collect

3.1 Information you provide

  • Account & profile data: name, business email, password, role/title, company, country/region, preferences.
  • Purchases & subscriptions: product purchased, plan, billing name/address, tax ID (if supplied). Note: PayPal and GoCardless collect and process your payment credentials directly; we do not store full card or bank details.
  • Support & communications: messages, feedback, support tickets, survey responses.
  • Community content: posts, comments, messages, and profile details you share on Discord or Skool (subject to each platform’s rules and privacy controls).

3.2 Information collected automatically

  • Device & usage: IP address, device type, browser type/version, time zone, basic interaction data (page views, timestamps) from our servers and security tools. We do not currently use analytics or advertising cookies/SDKs.
  • Logs & security signals: events to detect abuse, spam, fraud, or service interruptions.

3.3 Information from third parties

  • Payment processors: limited transaction metadata from PayPal/GoCardless (e.g., payment status, last 4 digits, transaction ID, timestamps).
  • Community platforms: your username, profile, and content consistent with each platform’s settings and APIs.

4. How we use Personal Information (purposes)

We use Personal Information to:

  • Provide, maintain, and secure the Site and Services;
  • Create and manage accounts and memberships;
  • Process orders and deliver purchased features;
  • Provide customer support and respond to requests;
  • Operate community features (Discord/Skool) and moderate content;
  • Send transactional notices (receipts, service updates, policy changes);
  • Comply with legal obligations, enforce terms, and prevent fraud or misuse;
  • {Optional future} With your consent, send marketing communications (you can opt out at any time).

5. What we don’t do with your AI data

  • We do not collect or store your prompts, files, chat logs, or outputs from custom AI projects for product improvement.
  • If a client requests troubleshooting, we will handle only the minimum data needed under a DPA and delete/return it once the task is complete.

6. Legal bases (EU/UK where applicable)

If you are in the EU/UK, we rely on:

  • Contract (to provide the Services you request);
  • Legitimate interests (security, fraud prevention, service improvement for business users);
  • Consent (where required, e.g., certain marketing or cookies—currently not used beyond necessary operations);
  • Legal obligation (tax, bookkeeping, compliance).

7. Disclosures and service providers

7.1 Processors / service providers. We share Personal Information with vendors that help us run the Services, subject to appropriate contracts:

  • Payments: PayPal; GoCardless.
  • Community: Discord; Skool.
  • Hosting/security/email/ops: U.S.-based infrastructure and tools (details available on request).

7.2 Business transfers & legal. We may disclose Personal Information in a merger or acquisition, or to comply with law, enforce terms, and protect rights, safety, and property.

7.3 No sale/share for ads. We do not sell or “share” Personal Information for cross-context behavioral advertising as those terms are defined under California law.

8. Data retention

We keep Personal Information only as long as needed for the purposes above and to meet legal, accounting, or reporting requirements. Default periods:

  • Account/profile & membership records: life of account + 6 months.
  • Order and tax records: 3 years.
  • Support tickets/communications: 2 years.
  • Server/security logs: up to 6 months unless extended for investigations.

9. Security

We use administrative, technical, and physical safeguards appropriate to the nature of the Personal Information we process (access controls, encryption in transit, least-privilege practices, and monitoring). No method of transmission or storage is 100% secure.

10. Your choices

  • Email preferences: you can opt out of non-transactional emails via the unsubscribe link.
  • Cookies: we currently operate without analytics/ads cookies. If this changes, we will update this Policy and our cookie controls.
  • Community controls: Discord and Skool provide their own privacy and notification settings.

11. Your rights

Depending on where you live, you may have rights to access, correct, delete, port, and object to certain processing, and to opt out of targeted advertising, sale, or profiling. See the Regional Disclosures below. We will not discriminate against you for exercising rights.

How to exercise rights: Email admin@mybrainybot.com with your request. We may need to verify your identity (and, where permitted, your authorized agent’s authority). We aim to respond within the timelines required by applicable law.

12. Regional Disclosures

12.1 United States — California (CCPA/CPRA)

Notice at Collection & Use. Categories we collect (for business/professional users):

  • Identifiers (name, email, account ID, IP address);
  • Customer records (billing name, billing address, limited payment metadata from processors);
  • Commercial information (purchases, subscription details);
  • Internet activity (basic usage logs on our Site);
  • Professional information (role/title, company);
  • Inferences: none created for advertising.

Purposes: as described in Section 4; Sources: you, your devices, payment processors, and community platforms. Retention: see Section 8.

Sensitive Personal Information: not sought; processors may collect limited financial data for payment processing.

Sale/Share: We do not sell or share Personal Information for cross-context behavioral advertising. If that changes, we will provide a “Do Not Sell or Share My Personal Information” link and honor opt-out preference signals.

Rights: access/know (including specific pieces), correct, delete, portability, and to limit use of sensitive PI (where applicable). Authorized agents may submit requests with valid proof of authority.

12.2 United States — Oregon (OCPA)

If you are an Oregon resident, you have rights to access, correct, delete, port, and opt out of processing for targeted advertising, sale, and certain profiling decisions. On request, we will also provide a list of the specific third parties to which we have disclosed your Personal Information, to the extent required by law. You may appeal a rights decision by emailing admin@mybrainybot.com with the subject “Appeal”; we will provide a written response with reasons and how to contact the Oregon Department of Justice if you remain unsatisfied.

12.3 European Economic Area/United Kingdom (GDPR/UK GDPR) — if applicable

If you are in the EEA or UK, you may have rights to access, rectify, erase, restrict, object, and port your Personal Data, and to withdraw consent at any time (without affecting prior processing). You also can lodge a complaint with your local supervisory authority. [[PLACEHOLDER: EU/UK representative (if appointed)]]; no Data Protection Officer is currently appointed.

International transfers: Brainy Bot stores data in the U.S.; some processors may transfer data internationally. Where required, we implement appropriate safeguards (e.g., Standard Contractual Clauses) and supplementary measures as applicable.

13. Third-party services

Your use of PayPal, GoCardless, Discord, and Skool is subject to their terms and privacy policies. We encourage you to review their notices:

14. Do Not Track

Our Site does not respond to browser Do Not Track signals at this time.

15. Changes

We may update this Policy from time to time. If we make material changes, we will notify you by posting an updated version and adjusting the date at the top. Your continued use of the Services after the changes become effective means you agree to the updated Policy.

16. Contact

Questions or requests: admin@mybrainybot.com

Postal address: 6305 Ulali Dr, Keizer, OR 97303, USA.

C) Plain-English Summary

  • We collect only what we need to run Brainy Bot (accounts, purchases, basic logs) and we don’t store your AI prompts/outputs.
  • Payments are handled by PayPal and GoCardless; we don’t see full card or bank details.
  • We don’t run analytics or ads right now and we don’t sell or share your data for advertising.
  • You can request a copy, correction, or deletion of your data and, in many places, opt out of sale/targeted ads (we don’t do these today).
  • We’re U.S.-hosted. If you’re outside the U.S., your data is processed in the U.S. and by our providers.

Appendix: Legal References (links)

Vendor references: PayPal Privacy Statement; GoCardless Privacy (Payers); Discord Privacy Policy; Skool Legal/Privacy.

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