2 Minute Brain, Ltd. (“2 Minute Brain,” “us,” “we,” or “our”) is committed to respecting and protecting your privacy. This relates to your use of the website, www.2Minute Brain.com (the “Website(s)”), applications (“Apps”) and other offerings, services, Offerings and features thereof (the Website, the Apps and such other offerings, services, Offerings, and features are collectively referred to herein as the “Offering” or “Offerings”, which are likely to be updated occasionally at the sole discretion of 2 Minute Brain). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal you provide to us, or we collect from you, in connection with the Offerings will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information. If you have any unresolved questions about this policy contact EMAIL.

INFORMATION WE MAY COLLECT FROM YOU

We may process the following information collected from you: • Personal information including, for example, telephone, e-mail address, your name, information about your usage of the Offerings and information collected by tracking technologies as further described below that may identify you as an individual or allow offline or online contact with you as an individual.

• 2 Minute Brain does not process or collect debit card or credit card (“Payment Card”) information. Google and Apple collect Payment Card information relating to in-app purchases made through the Apps, and our payment processor collects Payment Card information relating to purchases made through the Websites. Payment processors usually provide limited information to us related to you, such as a unique token that enables you to make additional purchases using the information they’ve – stored, and your card’s type, billing address, expiration date, and the final four digits of your card number.

• Facebook profile information, such as Facebook ID, email address, and name if you choose to log in to the Offerings through Facebook.

• Device Information such as device type, system performance information and operating system version.

• Information obtained through tracking technologies, as described fully in section 4.

• If you choose to invite a “Mate” to use the Offerings using our Mate option, we will ask you for their email address and name. We will use this information to invite her or him to join the Offerings. We store this information for the sole purpose of sending invitations and tracking the success of our Mate program. If your Mate would seeks to delete her or his information, they are able to by opting-out as described in each invitation or by contacting us at support@2MinuteBrain.com.

CONFIDENTIALITY AND SECURITY

The security of your personal information is very important to us. Except as described under the “Disclosure of Your Information” section below, we do not offer your personal information to any third party without your specific consent. We follow accepted standards to protect the personal information offered to us, both when received and during transmission. If you have any questions regarding the security of your personal information, you can contact us at support@2 Minute Brain.com.

ELECTRONIC COMMUNICATIONS SUCH AS NEWSLETTERS

If you choose to sign up to receive promotional materials from us via email this information will be used to service your request. If you inform us that you wish to cease receiving email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at support@2 Minute Brain.com, you will be removed from our mailing list. In order to cease receiving push notifications, you may turn them off via your device.

TRACKING TECHNOLOGIES

2 Minute Brain and our analytics partners use technologies such as tags, scripts, beacons, and cookies, to enable a service to identify your device so you need not provide the same information multiple times during one task, identify that you may have already given a password so it is not required for every web page requested, and to measure how people are interacting with the Offerings.

We use local storage, such as HTML5, to store preferences and content information. We may partner with third parties who also use HTML5 to store and collect information. Certain browsers offer their own management options for removing HTML5.

We partner with third parties, such as Google and Facebook, to organise our advertising of the Offerings on other platforms or sites as well as across your other devices based on your previous visits to our website. The third party partners we use may use cookies and other related technologies to obtain information about your activities within the Offerings to deliver related advertising to you, such as retargeting ads. Consent from you is required in order to use such trackers for advertising purposes to the extent stated by applicable law. We at this time do not respond to do-not-track signals. For more information about interest-based ads, such as learning how to opt-out of having your web-browsing information used for behavioral advertising purposes, visit www.aboutads.info/choices. This does not opt you out of having such ads served to you. You may continue to receive generic ads on such third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.

Third party trackers let us know when participants have visited the Offerings by “clicking-through” our hosted content or sponsored advertising on third party platforms. Google Analytics code is placed on the Offerings to gather statistical information. Google Analytics sets cookies to assist in estimating the volumes of usage of the Offerings and number of visitors to the Offerings. For more information on how Google Analytics processes this information, visit www.google.com/analytics.

LOG FILES

Like the majority of websites, we gather certain types of information and store it automatically in log files. This could include internet service provider (ISP), operating system, date/time stamp, clickstream data, Internet Protocol (IP) addresses, browser type.

If you receive our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on the newsletter links are saved. These statistics are used in aggregate form to give us an indication of the popularity of the content.

MOBILE ANALYTICS

Mobile analytics software is used to allow us to more easily comprehend the functionality of our mobile software on your phone. This software may record information such as aggregated usage and performance data, where Applications are downloaded from, events that happen within Offerings and how often you engage with Offerings. We may link the information we store within the analytics software to personal information you offer within the mobile application.

WHERE YOUR PERSONAL INFORMATION IS STORED

All information you provide to us via the Offerings is stored on secure servers located in the USA. All payment information is stored with our payment processor and is never stored on 2 Minute Brain’s servers. All payment transactions will be encrypted using SSL technology. Where you have chosen or we have given you a password which enables you to access certain parts of the Offerings, it is your responsibility to keep the password confidential. We strongly recommend you not share a password with anyone and change it regularly.

When we receive your information, we use strict security features and procedures to attempt to prevent any unauthorised access. Information transmitted via the internet is not fully secure. We do our best to protect your personal information but cannot guarantee the security of your information transmitted to the Offerings; any transmission is at your own risk.

ORGANISATION SHARING

Larger groups known as Organisations (companies, universities, hospitals, etc.) (“Organisations”) may  introduce the Offerings to their members and employees. If you register to use the Offerings through a code or other registration credential offered by an Organisation (an “Organisation Subscription”), the Organisation will have access to the date you registered, your email address, and the date you last used the Offerings. The Organisation will have access to general usage information on an anonymised and aggregated basis with all other members of the Organisation using the Offerings.

If you have provided consent under applicable law, your Organisation may also have access to your usage information.

SINGLE SIGN-ON

You can log into our Offerings using sign-in services such as Open ID provider or Facebook Connect.  These services will authenticate your identity, assist to pre-populate our sign-up form, and provide you the option to share certain personal information (such as your email address and name) with us. Services such as Facebook Connect offer you the choice to post information about your activities on our Offerings or to your profile page.

ACCESS TO AND DELETION OF PERSONAL INFORMATION

If requested, 2 Minute Brain will give you information about whether we process on behalf of a third party or hold any of your personal information. To request this information, please email support@2MinuteBrain.com.

You can access your personal information to update or modify at any time via an online account, or by emailing support@2MinuteBrain.com.

If requested, your personal data that we have on file can be deleted. Simply email support@2Minute Brain.com. 2 Minute Brain will permanently and irrevocably anonymise your data such that it can never be reconstructed to identify you as an individual.

We will act on your request in a timely manner as dictated by applicable law.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

• To send customer service communications.

• To notify you of changes to the Offerings.

• To provide you with promotional communications, like email for example, to the extent that you have provided consent to receive these communications under applicable law.

• To allow for your participation in interactive features of the Offerings, if you choose to do so.

• To provide you with information, Offerings or services related to 2 Minute Brain that will facilitate your engagement with such Offerings.

• To allow the content provided by the Offerings to be presented in an efficient manner for you and for your devices.

• To fulfil our obligations based on any agreements entered into between us and you.

• To comprehend your non-specific and broad geographic location to help us identify groups of participants by general geographic market (such as country, zip code, state).

• To arrange applicable sales taxes based on zip codes provided to our payment processors for sales made through the Websites.

• To inform your Organisation about your registration and use of such Offerings as described under Organisation Sharing in section 6 above.

• To show our advertisements to you through third party platforms, such as Google or Facebook, on other apps and sites or across your devices, to the extent that you have provided consent for such uses under applicable law

• We may ask you to complete surveys for research purposes, although you do not have do them.

• Details of your interactions with and visits to the Offerings including, but not limited to, location data, traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

• Details of transactions carried out through the Offerings and of the fulfillment of your Offering orders.

• If you are an existing customer, we will only contact you by electronic means (e-mail or in-Offering communication) with information about Offerings and related services similar to those that were the subject of a previous sale to you.

INFORMATION DISCLOSURE

We may disclose your personal information to any member of our group, this relates to our subsidiaries, our ultimate holding company and its subsidiaries.

Your personal information may be disclosed to third parties as follows:

• In certain circumstances, and based on your specific requests, we may need to disclose your personal information to a third party so that they can provide the service you have requested for, or complete a request for information from them. An example of this would be an SMS Service.

• In certain circumstances, we may disclose the personal information you provided to 2 Minute Brain to a third party that provides and/or offers services or goods complementary to our own for the purpose of enhancing our participants’ experiences by offering you complementary or integrated functionality, related services or bundled pricing options.

• If 2 Minute Brain’s service providers (like payment service providers, hosting, market analytics) necessitate this information to provide services to 2 Minute Brain. 2 Minute Brain requires each of its service providers to agree to maintain the security and confidentiality of your personal information.

• If we buy or sell any assets or business, in which case we may disclose your personal information to the prospective seller or buyer of such assets or business.

• If all of 2 Minute Brain is fully acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.

• If we share your personal information in order to comply with any legal obligation or are under a duty to disclose, as to comply with bankruptcy proceedings, a subpoena, similar legal process, or in order to apply or enforce our agreements with you; or to protect the rights, safety or property of 2 Minute Brain, our customers, or others. This includes exchanging information with other organisations for the purposes of credit risk reduction and fraud protection.

• With your Organisation, if your subscription is an Organisation Subscription, as described under Organisation Sharing above.

• With third parties, such as Google or Facebook, in order to present 2 Minute Brain advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.

WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES

To the extent that you have provided appropriate consent under applicable law to related processing activities, this consent can be withdrawn at any time by emailing support@2MinuteBrain.com.

LINKS TO THIRD PARTY SITES

The Offerings may, on certain occasions, contain links from and to the Offerings of our affiliates, advertisers and partner networks. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any liability or responsibility for these websites or their policies. Please check the policies of those websites before you submit any personal information to such external websites.

SOCIAL MEDIA WIDGETS

Our Offerings may include social media features and widgets, such as a “Share This”, Facebook Like or other related concepts. Your interactions with these features are governed by the privacy statement of the company providing it. These features may set a cookie to enable the feature to function properly and might collect your Internet protocol address and which page you are visiting or Offerings. Social media widgets and features are hosted directly on our Offerings or by a third party.

USE OF 2 MINUTE BRAIN BY MINORS

You must be 18 years of age, or the age of majority in your territory, country or province, to sign up as a registered participant of the Offerings. Individuals under the age of 18, or the applicable age of majority, may utilise the Offerings only with the consent and involvement of a legal guardian or parent, under such person’s account and otherwise subject to these Terms.

INFORMATION POSTED ON FORUMS

2 Minute Brain participants have the ability to post content to 2 Minute Brain forums. All such participants may obtain removal by request of such posted content by contacting 2 Minute Brain at support@2MinuteBrain.com and specifically identifying what content is to be removed. Please take note that any such removal does not ensure comprehensive and complete removal of all traces of the content posted on any 2 Minute Brain forum(s).

CHANGES TO OUR PRIVACY POLICY

We may at any time update this Privacy Policy to reflect changes to our information practices. If any material changes are made, you will be notified by email (sent to the e-mail address specified in your account), in-Offering message, or by means of a notice in the Offerings prior to any change becoming effective. You are welcome to periodically review this page for the latest information on our privacy practices.

CONTACT

Comments, requests and questions relating to this privacy policy are should be addressed to support@2 MinuteBrain.com.

This Privacy Policy is effective and was last updated on January 4, 2020. 2 Minute Brain’s physical address is 20-22 Wenlock Road, London, UK. N1 7GU

Swiss-U.S. and EU-U.S. Privacy Shield

We follow the Swiss-U.S. Privacy Shield and EU-U.S. Privacy Shield and Frameworks. 2 Minute Brain is committed to subjecting all personal data received from the United Kingdom and/or Switzerland and European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.

2 Minute Brain complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Relating to personal data covered by Privacy Shield, you have the ability to opt-out of whether such personal information is to be used for a purpose that is materially different for the purpose for which it was originally collected or subsequently authorised or disclosed to a third-party. You can contact 2 Minute Brain at support@2MinuteBrain.com in order to state your choices.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, 2 Minute Brain is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, 2 Minute Brain may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.