Legal Document

Privacy Policy

Boost Your Brain by HiddenFlame Effective: May 19, 2026 GDPR Compliant
01

Who We Are

HiddenFlame ("we", "us", or "our"), a company registered in Poland, operates the Boost Your Brain mobile application available on Android. Boost Your Brain is a cognitive training app that offers brain games, puzzles, and memory exercises designed to help users strengthen their mental agility and cognitive performance.

For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), HiddenFlame acts as the Data Controller for any personal data collected through the Boost Your Brain application.

Contact: contact@multitools.ovh

02

Data We Collect

Boost Your Brain does not require an account. You can use the app fully without registering or providing any personal information. We do not collect your name, email address, or any directly identifying information.

Usage & Analytics Data

We collect anonymised and pseudonymised usage data via PostHog to understand how users interact with the app and improve the experience. This may include:

  • Features accessed and frequency of use
  • Device type, operating system version, and app version
  • Session duration and navigation patterns
  • Crash reports and performance metrics

This data is pseudonymised — linked to a random device identifier, not to any personal identity. It does not include your name, location, or contact details.

Local Game Data

Your game progress, scores, and training history are stored locally on your device only. This data never leaves your device and is not transmitted to our servers.

03

How We Use Your Data

Purpose Data Used
Provide and operate the Boost Your Brain service Local device data only
Improve app performance and features Anonymised analytics data
Detect and fix crashes and bugs Anonymised crash reports
Comply with legal obligations As required by applicable law

We do not sell your data. We do not use your data for targeted advertising. We do not share your data with third parties beyond the analytics processor described in Section 6.

04

Legal Bases for Processing (GDPR)

Under the GDPR, we rely on the following legal bases:

  • Legitimate Interests (Art. 6(1)(f)): Anonymised analytics help us understand usage patterns and improve the app. We have balanced our interests against your rights and concluded this processing is proportionate and minimally intrusive given the pseudonymised nature of the data.
  • Legal Obligation (Art. 6(1)(c)): We may retain certain data to comply with Polish and EU legal requirements.
05

Age Restriction

Boost Your Brain is intended for users aged 13 and over. We do not knowingly collect personal data from individuals under the age of 13. If you are under 13, please do not use the app.

Note for Parents & Guardians

If you believe your child under 13 has used this app and any data has been collected, please contact us at contact@multitools.ovh and we will delete any associated data promptly.

06

Third-Party Services

We use a minimal set of third-party services to operate Boost Your Brain:

PostHog (Analytics)

We use PostHog Cloud for product analytics. Anonymised usage data (events, device info, session data) may be processed on PostHog's infrastructure under Standard Contractual Clauses ensuring GDPR-compliant transfers. PostHog does not receive your name, email address, or any personal identifier. For more information, see posthog.com/privacy.

Google Play Store

Downloading the app through Google Play is subject to Google's privacy policy. We do not receive your payment information or Google account details from the platform.

We do not use Facebook/Meta, Google Ads, AppsFlyer, Firebase Analytics, or any other advertising or tracking SDK. No data is shared with advertisers.

07

Data Storage & International Transfers

Your game progress and scores are stored exclusively on your device and are never transmitted to our servers.

Analytics data processed by PostHog Cloud may be transferred outside the EEA under Standard Contractual Clauses as required by GDPR Art. 46. Data in transit is protected using TLS 1.2 or higher.

08

Data Retention

  • Local game data — stored on your device and deleted when you uninstall the app or clear app data.
  • Analytics data — pseudonymised events retained for up to 24 months for product improvement, then deleted.
  • Legal compliance data — retained as required by applicable Polish and EU law (typically up to 5 years).
09

Your Rights Under the GDPR

As a data subject in the EU/EEA, you have the following rights:

  • Right of Access (Art. 15): Request a copy of all personal data we hold about you.
  • Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
  • Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal data.
  • Right to Restriction of Processing (Art. 18): Request that we limit how we use your data.
  • Right to Data Portability (Art. 20): Receive your data in a machine-readable format.
  • Right to Object (Art. 21): Object to processing based on legitimate interests.

To exercise any of these rights, contact us at contact@multitools.ovh. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority. In Poland, this is the Urząd Ochrony Danych Osobowych (UODO) at uodo.gov.pl.

10

Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These include:

  • Encrypted data in transit (TLS 1.2+)
  • Pseudonymisation of analytics data
  • No collection of sensitive personal identifiers
  • Regular security reviews of our analytics pipeline

Since Boost Your Brain does not store personal data on our servers, your exposure to data breach risk from our infrastructure is minimal.

11

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you via the app at least 14 days before the change takes effect. The "Effective Date" at the top of this page will always reflect the current version.

Continued use of Boost Your Brain after the effective date constitutes your acceptance of the updated policy.

12

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your data, please contact us:

We aim to respond to all privacy-related enquiries within 30 days. For urgent matters concerning potential data breaches or misuse, please mark your message as urgent.

If you are not satisfied with our response, you have the right to lodge a complaint with the Polish data protection authority: Urząd Ochrony Danych Osobowych (UODO) at uodo.gov.pl.