1. Data Controller
Any processing of personal data is carried out under the responsibility of SKILL WAGON, a limited liability company incorporated under English law, registered in the UK under number 15627219. The registered office is located at 7 Bell Yard, London, WC2A 2JR, United Kingdom (hereinafter referred to as BRAINLify). You can contact us by email at contact@pprod.iqtest-expert.com.
When transferring data to partners, we ensure that this processing complies with applicable privacy standards, and your consent is obtained prior to any data transfer.
2. Types of data collected
BRAINLify may collect and process various categories of personal data, including but not limited to:
- Personal account data: Collected during the creation and management of your account, and/or when placing an order (e.g., title, name, date of birth, email address, phone number, billing address, credit card details, test answers, test results).
- Contact form data: Provided when contacting via the Site (e.g., name, email address, subject, and content of the message).
- Log and browsing data: Collected via cookies, including IP address, device identifiers (e.g., Apple or Android), operating system and browser type, timestamps of site logins and browsing activity.
Sensitive data, such as information revealing racial or ethnic origin, political opinions, or health-related information, is strictly avoided in our collection processes. In the unlikely event that such data is submitted to us, you may request its deletion by contactingcontact@pprod.iqtest-expert.com.
3. Purpose and legal basis of processing
Your personal data is collected for the following purposes:
| Legal basis |
Purpose |
| Execution of the contract |
Creation and management of accounts, activation of the use of the Site, processing of payments, and execution of orders. |
| Consent |
Sending marketing communications and managing cookies as described below. |
| Legitimate interests |
Conducting satisfaction surveys, preventing fraud, and service improvement activities. |
| Legal obligations |
Data retention to meet evidential or compliance requirements. |
We ensure that all processing activities are fully compliant with applicable legal standards.
4. Data retention
The retention periods for personal data depend on the type and purpose of the processing:
- Payment data: Retained by our payment processor for evidential purposes for up to 15 months.
- Usage data: Stored for up to 5 years after account closure, with inactive accounts being deleted after 3 years.
- Contract and order data: Retained for 5 years for evidential purposes. Data related to disputes may be stored until their resolution.
- Marketing data: Kept until you unsubscribe or after 3 years from the last interaction.
- Tax and accounting data: Kept for 10 years in accordance with legal requirements.
- Cookies: Kept for a maximum of 13 months, while cookie preferences are stored for 6 months.
Specific retention periods may vary depending on legal obligations and operational requirements. Therefore, the periods mentioned above are only guidelines and may change from time to time.
5. Recipients of personal data
Access to your personal data is strictly limited to the following:
- Internal teams: Data processing in the context of their functions.
- Subcontractors: Hosting, payment processing, and technical service providers (e.g., AWS AMAZON).
- Authorized authorities: Administrative or judicial entities according to legal requirements.
- With consent: Data sharing with third parties only occurs when explicitly authorized by you.
6. Data transfer outside the EU
When data is transferred outside the EU, BRAINLify ensures compliance with GDPR standards by:
- Adequacy decisions: Assessment of protection measures in the recipient country.
- Standard contractual clauses: Establishment of binding obligations regarding data protection.
Countries to which data may be transferred include, but are not limited to, the United States.
7. Rights of data subjects
You have the right to exercise your rights under the UK GDPR, including:
- Right of access: To obtain confirmation and details regarding processing activities.
- Right to rectification: To amend inaccurate or incomplete data.
- Right to erasure: To request the deletion of data, subject to legal obligations.
- Right to restriction: To limit processing in specific circumstances.
- Right to object: To refuse processing for commercial purposes or legitimate interests.
- Right to data portability: To receive data in a structured, machine-readable format.
Requests must be submitted by email or postal mail accompanied by a copy of an identity document.
Minors
The Site is not intended for minors under 18 years old. Personal data of minors is neither collected nor processed knowingly.
9. Technical and organizational security measures
We employ strict safeguards to ensure data security:
- Encryption: Secure storage of sensitive information.
- Access controls: Secure management of access to internal and external data.
- Audits: Regular reviews to maintain compliance and identify vulnerabilities.
- Employee awareness: Staff training on privacy practices.
We also assess subcontractors' compliance with high protection standards.
10. Cookies and tracking technologies
Cookies are used for site functionality, performance monitoring, and audience measurement. You can manage cookie preferences via:
- Browser settings: Customization of consent options for any browsing activity.
- Site tool: Configuration of preferences directly on our Site.
Disabling cookies may affect certain features or user experiences.
11. Changes to the policy
BRAINLify reserves the right to update this Privacy Policy if necessary. Any significant changes will be clearly communicated on our Site.