Privacy Policy

Last Updated: January 15, 2025

Introduction and Overview

CerevoBrainy ("we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website cerevobrainy.com or use our income budgeting educational services.

As a financial education platform operating in Taiwan, we comply with the Personal Data Protection Act of Taiwan (PDPA) and international privacy standards. This policy applies to all users of our services, whether you're browsing our website, enrolling in our programs, or communicating with our team.

Important: By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described herein.

Information We Collect

We collect several types of information from and about users of our educational platform. The information we gather helps us provide personalized learning experiences and improve our services.

Personal Information

Name, email address, phone number, mailing address, and educational background when you register for our programs or contact us directly.

Financial Learning Data

Your progress in our budgeting courses, quiz results, learning preferences, and interaction with educational materials.

Technical Information

IP address, browser type, device information, operating system, and website usage patterns through cookies and analytics tools.

Communication Records

Messages, emails, and other communications between you and our support team or instructors.

We collect this information through various means including direct interactions, automated technologies, and third parties. For instance, when you fill out contact forms, participate in our learning assessments, or simply browse our website, certain data is automatically gathered to enhance your experience.

How We Use Your Information

Your information serves multiple purposes in helping us deliver quality financial education services. We use collected data to personalize your learning journey, track your progress through our income budgeting programs, and provide technical support when needed.

  • Educational Service Delivery: Customizing course content based on your learning style and progress, sending course materials, and tracking completion of modules
  • Communication: Responding to inquiries, sending program updates, sharing relevant financial education resources, and providing customer support
  • Platform Improvement: Analyzing user behavior to enhance our website functionality, developing new educational content, and identifying areas for service improvement
  • Administrative Purposes: Processing enrollments, managing accounts, maintaining records for educational compliance, and handling billing matters
  • Legal Compliance: Meeting regulatory requirements in Taiwan, protecting against fraud, and ensuring platform security

We also use aggregated, anonymized data to understand broader learning trends and improve our curriculum. This helps us identify which topics resonate most with students and where additional support might be beneficial.

Data Sharing and Third Parties

We maintain strict policies regarding data sharing and only work with trusted partners who meet our privacy standards. Your personal information is not sold, rented, or traded to third parties for marketing purposes.

Service Providers

We share data with carefully vetted companies that help us operate our platform, such as email service providers, payment processors, and learning management system vendors. These partners are bound by confidentiality agreements and can only use your data to provide services on our behalf.

Educational Partners

With your explicit consent, we may share learning progress data with certified financial advisors or career counselors who contribute to our programs. This sharing is limited to information directly relevant to your educational goals.

Legal Requirements

We may disclose your information when required by law, legal process, or to protect the rights, property, or safety of CerevoBrainy, our users, or others.

Before sharing data with any new partner, we conduct thorough privacy assessments and ensure they meet Taiwan's data protection standards. We also maintain detailed records of all data sharing activities for transparency and compliance purposes.

Your Rights and Choices

Under Taiwan's Personal Data Protection Act and international privacy principles, you have several rights regarding your personal information. We've designed straightforward processes to help you exercise these rights.

  • Access Right: Request a copy of the personal data we hold about you, including learning progress and account information
  • Correction Right: Update or correct inaccurate personal information in your account or learning profile
  • Deletion Right: Request deletion of your personal data, subject to certain legal and legitimate business requirements
  • Portability Right: Obtain your learning data in a structured, commonly used format for transfer to another service
  • Restriction Right: Limit how we process your data while maintaining your account access
  • Objection Right: Object to processing based on legitimate interests or for direct marketing purposes

To exercise any of these rights, contact us using the information provided at the end of this policy. We typically respond to requests within 15 business days and may need to verify your identity before processing certain requests. Some rights may be limited by legal obligations or legitimate business needs, which we'll explain if applicable.

Marketing Communications: You can opt out of educational newsletters and promotional emails at any time using the unsubscribe link in our messages or by contacting our support team directly.

Data Security and Protection

We implement comprehensive security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security framework includes both technical and organizational safeguards designed to maintain data integrity.

Technical Safeguards: We use industry-standard encryption for data transmission and storage, secure server environments with regular security updates, multi-factor authentication for administrative access, and automated backup systems with encryption. Our website uses SSL certificates to ensure secure communication between your browser and our servers.

Organizational Measures: Access to personal data is limited to employees who need it for their job functions, all staff receive privacy training annually, we maintain incident response procedures for potential breaches, and conduct regular security audits and assessments.

Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. We encourage users to protect their account credentials and report any suspicious activity immediately.

In the unlikely event of a data breach that poses a risk to your privacy rights, we will notify affected users within 72 hours and take immediate steps to contain the incident and prevent further unauthorized access.

Data Retention and Deletion

We retain your personal information only as long as necessary to fulfill the purposes outlined in this privacy policy or as required by law. Our retention periods are based on the type of data and the purpose for which it was collected.

Educational Records: Learning progress, course completions, and certificates are retained for seven years after your last activity to support continued learning and provide transcripts upon request. This period aligns with Taiwan's educational record-keeping requirements.

Account Information: Basic profile data remains active while your account exists and for three years after account closure, unless deletion is specifically requested. This allows for account reactivation and customer service support.

Communication Records: Email correspondence and support tickets are kept for three years for customer service purposes and quality assurance.

Technical Data: Website analytics and usage logs are typically retained for 24 months to help us understand user patterns and improve our services.

When retention periods expire, we securely delete or anonymize your information. You can request earlier deletion of your data by contacting us, though some information may be retained if required by law or for legitimate business purposes. We'll explain any limitations if they apply to your deletion request.

International Data Transfers

While CerevoBrainy primarily operates within Taiwan, some of our service providers and technology partners may be located in other countries. When we transfer your personal data internationally, we ensure appropriate safeguards are in place to protect your information.

We only work with international partners who demonstrate adequate levels of data protection, either through certification programs, binding corporate rules, or standard contractual clauses approved by relevant data protection authorities. Before any international transfer, we assess the destination country's privacy laws and the recipient's data handling practices.

Current International Partners: Our email service provider operates servers in secure facilities within countries that have received adequacy decisions for data protection. All transfers include contractual protections that meet Taiwan PDPA requirements.

If you have concerns about international transfers of your data, please contact us to discuss available options, including data localization preferences where technically feasible.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience, understand usage patterns, and provide personalized content. Cookies are small text files stored on your device that help us recognize you on return visits.

Essential Cookies: These are necessary for the website to function properly, including maintaining your login session and security features. These cookies cannot be disabled without affecting site functionality.

Analytics Cookies: We use these to understand how visitors interact with our website, which pages are most popular, and where users encounter difficulties. This helps us improve our educational resources and user experience.

Preference Cookies: These remember your choices, such as language settings and course preferences, to provide a more personalized experience.

You can control cookies through your browser settings, though disabling certain cookies may affect website functionality. Most browsers allow you to view, manage, and delete cookies, and many offer privacy modes that don't store cookies permanently.

We do not use cookies for advertising purposes or share cookie data with advertising networks. Our tracking is focused solely on improving our educational services and website performance.

Children's Privacy

CerevoBrainy's services are designed for adults seeking financial education and income budgeting skills. We do not knowingly collect personal information from children under 16 years of age without verifiable parental consent.

If we become aware that we have collected personal information from a child under 16 without parental consent, we will take steps to remove that information from our systems promptly. Parents who believe their child has provided us with personal information can contact us to request deletion.

For users between 16 and 18 years old in Taiwan, we may require parental or guardian consent for certain activities, particularly those involving financial information or long-term educational commitments.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. When we make significant changes, we will provide notice through our website and, for registered users, via email notification.

We encourage you to review this policy regularly to stay informed about how we protect your information. The "Last Updated" date at the top of this policy indicates when the most recent changes were made.

If we make material changes that significantly affect your rights or how we handle your personal information, we will seek your renewed consent where required by law. Your continued use of our services after policy updates constitutes acceptance of the revised terms.

Policy Archive: Previous versions of this privacy policy are available upon request for reference and transparency purposes.

Contact Information

If you have questions about this Privacy Policy, want to exercise your privacy rights, or need assistance with your account, we're here to help. Our privacy team is trained to handle all data protection inquiries promptly and professionally.

Privacy Inquiries Contact

Address: No. 391號, Zhongshan Road, Taitung City, Taitung County, Taiwan 950
Phone: +886222513500
Email: contact@cerevobrainy.com
Privacy Officer: Available Monday-Friday, 9:00 AM - 6:00 PM Taiwan Time

When contacting us about privacy matters, please include your full name, email address associated with your account, and a detailed description of your request or concern. This helps us respond more efficiently and accurately to your needs.

For urgent privacy concerns or suspected data breaches, please mark your communication as "URGENT - PRIVACY" in the subject line. We monitor these messages continuously and will respond within 24 hours during business days.