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Privacy Policy

Last updated: 5 November 2026

This policy explains how Genioworks Consulting & IT-Services UG (haftungsbeschränkt) (“Genioworks”, “we”, “us”) processes personal data when you use our mobile apps and games (the “apps”). It does not cover the website. Visitors and publishing applicants should read the website privacy policy.

The current version is always at https://brainsoft-apps.com/privacy-policy/. Where this policy says we rely on consent, using an app is not that consent. We ask you in the app, and you can refuse.

Who we are

The controller is:

Genioworks Consulting & IT-Services UG (haftungsbeschränkt)
Karlheinz-Stockhausen-Straße 30
50171 Kerpen, Germany

Commercial register: HRB 90444
Registration court: Amtsgericht Köln
VAT ID (Sect. 27 a UStG): DE310780221

Phone: +49 159 06701777
Email: info@brainsoft-apps.com

We have not appointed a data protection officer. For privacy requests, use the email address or the postal address above, or the support feature in the app.

Contents

Data, purpose and legal basis

We design the apps so that we do not need your name, postal address or email address unless you send those to us, for example in a support message. The table is a summary. The sections below explain the same processing.

Data Purpose Legal basis
Device type, operating system, screen resolution, app version, language, time zone, IP address Run the app, keep it secure, diagnose faults, host the service Contract (Art. 6(1)(b) GDPR). Legitimate interest in security, diagnostics and hosting (Art. 6(1)(f) GDPR).
Features you use, time of use, in-app purchase history, subscription status Provide the features you chose, including paid access, and understand outages and product quality Contract for the service and for access you purchased. Legitimate interest in keeping the app reliable.
Advertising identifier (Apple IDFA or Android advertising ID) and data used to build or apply an ad profile Personalized advertising, including through mediation Consent (Art. 6(1)(a) GDPR). In the EEA, the UK and Switzerland we ask in the app before this processing.
Context of the screen you are on, without an advertising identifier and without a profile of you Contextual advertising Legitimate interest in funding the free app (Art. 6(1)(f) GDPR).
Install and in-app events sent to Adjust GmbH Measure installs and campaign events. Adjust is our processor for this attribution. Legitimate interest in measuring our own campaigns (Art. 6(1)(f) GDPR). Use of the advertising identifier for attribution requires the same consent as personalized advertising; without it, measurement is limited to aggregated or privacy-preserving methods.
Data sent to Adapty Tech Inc.: install identifier; Identifier for Vendor (IDFV); advertising identifier only if tracking is allowed; device model; operating system; paywall events; subscription status and history. Not your name, email address or card number. Validate a purchase, grant access, and measure the paywall Contract for access you purchased (Art. 6(1)(b) GDPR). Legitimate interest for paywall analytics (Art. 6(1)(f) GDPR).
Content you submit in an AI feature: text and voice in Chat AI, a camera photo of a problem in SolveNow AI, prompts in Nano Banana AI. Sent to OpenAI, Google (Gemini) or xAI (Grok) to generate the answer. Return the result you asked for. Not used by us to build an advertising profile. The provider may use the content to improve its models under its own terms. Contract for returning the result (Art. 6(1)(b) GDPR). Any use by the provider for its own purposes is under that provider’s responsibility and terms.
Precise location, camera or similar device data Only a feature you choose to use, and only after the operating system has asked you Consent (Art. 6(1)(a) GDPR).
What you send to support or to info@brainsoft-apps.com Answer you and keep a record of the request Contract, if you are asking about a service you use. Legitimate interest in handling other messages. Legal obligation where we must keep the record.
Purchase records received from Apple or Google. We do not receive the card number. Confirm paid access and meet accounting and tax duties Contract (Art. 6(1)(b) GDPR). Legal obligation (Art. 6(1)(c) GDPR).

Push notifications are sent only if you allow them on the device. You can turn them off in the device settings. That permission is the consent for those notifications.

We may receive information about app use from the analytics providers listed below, under their own privacy notices, and we use it for the purposes in this policy.

Purchases and subscriptions

Payments are taken by Apple or Google. We never see your card number and we do not charge the card. The store tells us whether a purchase or subscription is active so we can grant access.

Adapty Tech Inc. is our processor for subscriptions and the paywall. We send Adapty an install identifier, the device model, the operating system, the Identifier for Vendor (IDFV), paywall events, and subscription status and history. We send the advertising identifier only if tracking is allowed on the device. We do not send Adapty your name or email address. Adapty’s notice for end users is at adapty.io/end-users-privacy. The contract basis covers validating the purchase and granting access. Paywall analytics are our legitimate interest. Rules for auto-renewal are in the subscription terms.

Advertising and opt-out

Personalized advertising uses an advertising identifier or a profile of your activity so that ads can follow your interests across apps. That processing, and the use of the advertising identifier for it, is based on consent. It is not based on legitimate interest. In the EEA, the UK and Switzerland we ask in the app before we or our advertising partners use the advertising identifier or serve personalized ads. You can refuse, and you can withdraw consent later with the steps below. Withdrawal does not affect processing that happened before you withdrew.

ironSource Mobile Ltd mediates advertising in the apps (Unity LevelPlay). Personalized ads served through that mediation require the same consent.

If you refuse personalized ads, we may still show contextual ads. A contextual ad is chosen from the app or screen you are using. It does not use your advertising identifier and it does not use a profile of you. The basis for contextual ads is legitimate interest. You can object to that interest by contacting us. The app may then be less able to offer a free version.

iOS

You can stop personalized ads on an iPhone or iPad in either of these ways:

  1. App Tracking Transparency. Refuse the tracking prompt, or later open Settings, then Privacy & Security, then Tracking, and turn tracking off for the app. The app then cannot access the IDFA.
  2. Apple Advertising. Open Settings, then Privacy & Security, then Apple Advertising, and turn off personalized ads.

Android

Delete your advertising ID, or reset it, in the system settings. The menu is usually under Privacy or Google settings. The wording differs by device and by Android version. After the advertising ID is deleted, apps cannot use it for personalized ads.

When you opt out, advertising partners treat that choice as a withdrawal of consent for a personalized ad experience and limit themselves to contextual ads.

Sharing an advertising identifier with advertising networks for personalized ads can be a “sale” or “sharing” of personal information under US state privacy laws, even when no money is paid for the data. To opt out of that sale or sharing for the apps, use the app and operating-system settings above. The cookie banner on the website does not control advertising in the apps.

AI features

Some apps include AI features. Chat AI takes the text or voice you submit. SolveNow AI takes a camera photo of a problem you submit. Nano Banana AI takes the prompts you submit. We process that content only to return the result you asked for. We do not use it to build an advertising profile.

To generate the answer, the content you submit is sent to one or more of these AI providers, depending on the app and the feature:

These providers may keep the content for a period set by their terms and may use it to improve their models. Where a provider does so, it does that for its own purposes and under its own privacy notice, not on our instructions. Do not enter names, contact details, health, financial or other sensitive information, or photos of people, into an AI feature. Voice input is converted to text; we do not keep the audio after the result is returned. AI features are not available in apps designed for children.

How long we keep data

We keep personal data only for as long as the purpose requires, including where the law tells us to keep it, where we have to resolve a dispute, or where we have to enforce an agreement.

  • Account and usage data are deleted after 26 months of inactivity.
  • Records of a consent choice are kept while that choice is valid and for 3 years after.
  • Payment records are kept for the period required by German accounting and tax law.

When the data are gone, we can no longer give you access, correct them, delete them again, or hand them over in a portable copy.

Children

Most of our apps are not directed at children under 16. In those apps we do not knowingly collect personal data from children under 16, and in the United States we do not knowingly collect personal information from children under 13. If you are a parent or guardian and you believe a child has sent us personal data through one of those apps, email info@brainsoft-apps.com and we will delete it and tell processors who received it to delete it as well.

A small number of our apps are designed for children. Those apps follow the stricter rules in the next section.

Apps designed for children

Some of our apps are listed in the Google Play Families program or the Apple Kids category. You can recognise them by the age rating and the family or kids label in the store listing. In those apps we apply the following rules, in line with the Children’s Online Privacy Protection Act (COPPA), Art. 8 GDPR and the store policies for apps designed for children:

  • We do not serve personalized advertising. Ads are contextual only. We do not collect or share the advertising identifier for those apps, and we do not build a profile of the child.
  • Advertising is delivered only through ad SDKs that the store has certified for apps designed for children, configured for child-directed treatment. Ad networks from the general list below that are not certified for children are not used in these apps.
  • There are no AI features, no precise location, no camera or microphone capture, no social sharing and no account in these apps.
  • We collect only what the app needs to run and stay secure: device type, operating system, app version, language, crash information and, where the store reports it, purchase status. Attribution and analytics in these apps run without the advertising identifier.
  • We do not ask children for a name, email address, photo or any other contact details.
  • Where the law requires parental consent, we rely on the consent mechanism of the store or do not offer the feature.

Parents and guardians can review the data we hold about a child, ask us to delete it, or refuse further collection by emailing info@brainsoft-apps.com with the app name. We may ask for information needed to confirm you are the parent or guardian. We respond within one month.

International transfers

We are established in Germany. Apple, Google, advertising partners, analytics providers, Adapty, the AI providers named above and Amazon Web Services may process personal data outside the EEA, including in the United States, the United Kingdom, Israel, Singapore, Canada and the United Arab Emirates. Where we transfer personal data from the EEA, the UK or Switzerland, we use one or more of the following:

  • an adequacy decision, where the destination is covered;
  • standard contractual clauses adopted by the European Commission, and the UK or Swiss equivalent where that transfer needs it;
  • the EU-US Data Privacy Framework, and the UK extension and the Swiss-US Data Privacy Framework, where the recipient is certified for that framework.

You can ask us for a summary of the safeguard that applies to a transfer. We do not claim that every partner is certified under a Data Privacy Framework. We rely on that framework only where the recipient’s certification covers the transfer.

Advertising networks and their partners

The companies below help us show ads in the apps. They may receive device data, including an advertising identifier such as the Android advertising ID or Apple’s IDFA, an IP address, and information about ads shown and how you interact with them. Personalized advertising that uses an advertising identifier or a profile is based on your consent, including when the ad is filled through ironSource. These advertising partners are independent controllers of personal data they process for their own purposes. Adjust and Adapty, described separately, are our processors and are not in this list of independent advertising controllers. In apps designed for children only networks certified for such apps are used, without personalized advertising.

Apart from the partners in this policy, we disclose personal data only to authorities where the law requires it or where it is necessary to protect our rights or the safety of users, and to a buyer or successor if our business or an app is sold or merged, under the same obligations described here.

1. BidMachine

Provided by BidMachine Inc. (US).
Privacy Policy: bidmachine.io/privacy-policy

2. Blis

Provided by Blis Corp Limited (United Kingdom).
Privacy Policy: blis.com/blis-privacy-policy

3. Criteo

Provided by Criteo GmbH.
Privacy Policy: criteo.com/privacy

4. Epsilon

Epsilon (formerly known as Conversant), provided by Epsilon International UK Ltd, part of the Publicis Groupe (France).
Privacy Policy: epsilon.com/emea/privacy-policy-services

5. Meta (Facebook)

We use Meta Audience Network, Meta Business Tools and ads conversion measurement, provided by Meta Ireland Platform Limited or Meta Platforms, Inc. (“Meta”). These tools connect data from the Facebook advertising network with actions in our apps. They use cookies, pixels and similar technologies to deliver and measure targeted advertisements. Meta may process some of the collected information as a joint controller. Personalized advertising through Meta requires your consent.
Privacy Policy: facebook.com/policy.php
Manage Ad Preferences: from your Facebook account.

6. Digital Turbine

Provided by Digital Turbine (IL) Ltd.
Privacy Policy: digitalturbine.com/privacy-policy

7. Google Advertising Products

Including AdManager, AdMob, and AdSense.
Privacy Policy: policies.google.com/privacy
Manage Ad Preferences: myadcenter.google.com

8. Index Exchange

Provided by Index Exchange Inc. (Canada).
Privacy Policy: indexexchange.com/privacy

9. InMobi

Provided by InMobi PTE Ltd (Singapore).
Privacy Policy: inmobi.com/privacy-policy
Opt-out: inmobi.com/page/opt-out

10. ironSource and Advertising Partners

Provided by ironSource Mobile Ltd (Israel), also operating as Unity LevelPlay. ironSource mediates advertising demand. Personalized ads served through this mediation require your consent.
Privacy Policy: developers.is.com (privacy policy)
Advertising Partners: developers.is.com (partners)

11. Liftoff

Provided by Liftoff, Inc. (US).
Privacy Policy: liftoff.io/privacy-policy
Opt-out: vungle.com/opt-out

12. LoopMe and Partners

Provided by LoopMe Limited (UK).
Privacy Policy: legal.loopme.com/privacy-center

13. Media.net

Provided by Media.net Advertising FZ-LLC (UAE).
Privacy Policy: media.net/privacy-policy

14. Minute Media

Provided by Pro Sportority (Israel) Ltd.
Privacy Policy: minutemedia.com/policies/privacy-policy

15. Mintegral

Provided by Adlogic Technology Pte. Ltd (Singapore).
Privacy Policy: mintegral.com/en/privacy

16. MobileFuse

Provided by MobileFuse LLC (US). Used only for users in the US.
Privacy Policy: mobilefuse.com/privacy-policy

17. Moloco

Provided by Moloco, Inc. (US).
Privacy Policy: moloco.com/advertising-policy

18. Nexxen

Provided by Nexxen Group LLC (US).
Privacy Policy: nexxen.com/privacy-policy

19. Ogury

Provided by Ogury Ltd (UK).
Privacy Policy: privacy.ogury.com

20. OpenX

Provided by OpenX Software Ltd (US).
Privacy Policy: openx.com/legal/privacy-policy

21. Pangle

Provided by Bytedance Pte. Ltd. (Singapore).
Privacy Policy: pangleglobal.com/privacy
Chinese Mainland users: pangle.cn/en/privacy/partner, compliance guide

22. Primis

Provided by M.D. PRIMIS TECHNOLOGIES LTD (Israel).
Privacy Policy: primis.tech/privacy-policy

23. PubMatic

Provided by PubMatic, Inc. (US).
Privacy Policy: pubmatic.com/legal/privacy-policy
Opt-out: pubmatic.com/legal/opt-out

24. Verve

Provided by Verve Group, Inc. (US).
Privacy Policy: verve.com/privacy-policy

Analytics and attribution

1. Adjust

Adjust GmbH (Germany) is our processor for install and in-app event attribution. It measures which campaigns lead to an install or a later event, on our instructions. It does not decide those purposes for itself.
Privacy Policy: adjust.com/privacy-policy

2. Firebase Analytics

Provided by Google LLC (US) and, for users in the EEA, Google Ireland Limited. You may opt out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google.
Privacy Policy: google.com/policies/privacy

3. Google Analytics

Provided by Google LLC (US) and, for users in the EEA, Google Ireland Limited.
Privacy Policy: policies.google.com/privacy

4. Tenjin

Provided by Tenjin, Inc. (US). It collects and analyzes user data to track app performance, advertising attribution, and monetization metrics.
Privacy Policy: tenjin.com/privacy-policy

Hosting

AWS (Amazon Web Services)

Provided by Amazon Web Services, Inc. (US). We use AWS to host app infrastructure.
Privacy Policy: aws.amazon.com/privacy

Social sharing

Some apps let you share an action to another service. You need to meet that service’s own minimum age. What is shared depends on the settings you chose with that service. Sharing features we use:

Links to other sites

The apps and this policy link to sites we do not operate. Those sites have their own rules. We are not responsible for their content or their privacy practices.

United States state privacy rights

If you live in a US state that gives residents privacy rights over personal information, you may have the right to:

  • confirm whether we process personal information about you and to access it;
  • correct inaccurate personal information;
  • delete personal information;
  • receive a portable copy of personal information you provided;
  • opt out of the sale of personal information, of sharing it for cross-context behavioral advertising, and of targeted advertising;
  • appeal our refusal of a request, where that state’s law provides an appeal.

We will not discriminate against you for exercising these rights. The categories we use in the apps are those in the table above: device and usage data, advertising identifiers where you allow them, purchase status, support messages, and content you submit to an AI feature. Sources are you, your device, the stores, and the processors and advertising partners named in this policy.

We do not sell personal information for money. Disclosing an advertising identifier to an advertising network for personalized ads can still be a sale or a share under these laws. Opt out of that sale or share in the app and in the operating-system settings described under Advertising and opt-out. Do not use the website cookie banner for the apps. To make any other request, email info@brainsoft-apps.com. We may need to confirm that the request comes from you.

Rights in the EEA, the UK and Switzerland

If the GDPR or the UK GDPR applies, you can ask us to:

  • confirm whether we process personal data about you and give you access;
  • correct inaccurate data;
  • delete data;
  • restrict processing;
  • give you, or a service you name, a portable copy of data you provided;
  • object to processing based on legitimate interest;
  • withdraw consent. Withdrawal does not affect processing that took place before it.

Send the request through support in the app or by email to info@brainsoft-apps.com. We may ask for information we need to confirm it is your data. We do not charge a fee for a reasonable request. We reply within one month.

You can lodge a complaint with the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), ldi.nrw.de, and with the data protection authority where you live.

Automated decisions

We do not make decisions based solely on automated processing that produce legal effects or similarly significant effects for you.

Security

We protect personal data with technical and organizational measures, including:

  • encryption of data in transit;
  • monitoring to reduce the risk of unauthorized access;
  • limiting access to people and processors who need it for the purposes in this policy.

No method of transmission or storage is completely secure. We cannot promise absolute security.

Changes

We may update this policy. The date at the top is the date of the current version. Where a change is material we will post a notice in the apps before it takes effect. If you keep using the apps after the new date, the updated notice applies. Consent-based processing still needs the consent described above.

Contact

Questions about this policy, and requests to exercise your rights, go to the controller:

Genioworks Consulting & IT-Services UG (haftungsbeschränkt)
Karlheinz-Stockhausen-Straße 30
50171 Kerpen, Germany

Phone: +49 159 06701777
Email: info@brainsoft-apps.com