Legal

Privacy Policy

Version 1.2 Effective Dec 12, 2023 Last Modified Feb 21, 2024

Contents

  1. Collection of Personal Data
  2. Cookies & Similar Technologies
  3. Privacy Considerations When Using Custom GPTs
  4. Uses of Personal Data & Legal Bases
  5. How We Disclose Personal Data
  6. Rights and Choices
  7. Third-Party Websites and Services
  8. Data Transfers
  9. Data Retention
  10. Children's Privacy Notice
  11. Changes to Our Privacy Policy
  12. Contact Information
Cerebry is an AI company from Singapore, working to build STEM-based Homework and Assessment Solutions for School Students. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal data when you use our website and other places where Cerebry may act as a data controller and link to this Privacy Policy.

This Policy does not apply where Cerebry acts as a "data processor," such as with respect to personal data we receive, process, store, or host when you use Cerebry's AI services as or through an enterprise customer, unless otherwise specified in this policy. In those cases, the enterprise customer company is the controller, and you can review their privacy policy for more information about how they handle your personal data.

Our Privacy Policy is underpinned by our dedication to the following Privacy Principles:


Section 01

Collection of Personal Data

When we refer to "personal data," we mean information that relates to you. We collect the following categories of personal data:

Personal data you provide to us directly

Identity and Contact Data: Cerebry may collect identifiers, such as your name, email address and phone number, when you sign up for a Cerebry account, to receive information on our Services, or submit an application for an employment opportunity. If you do not provide us with this information, we will not be able to administer your Cerebry account. We may also collect indirect identifiers (e.g., "USER12345").

Payment Information: We will collect your payment information if you choose to purchase access to Cerebry's products and services. If you don't provide us with this information, we will not be able to facilitate payment for Cerebry's products and services.

Professional Information: If you apply for employment with us, Cerebry may collect professional information, such as your employment history, your qualifications, and any other information contained in your CV or résumé.

Feedback on your use of our Services: Where applicable, we will collect your Feedback (as defined in our Terms of Service) regarding Prompts and Outputs, and use it under your authorization to train and improve our Services.

Personal data we receive automatically

When you use the Services, we may also receive certain technical data automatically. This includes:

Section 02

Cookies & Similar Technologies

We and our service providers use cookies, scripts, or similar technologies ("cookies") to manage the Services and to collect information about you and your use of the Services. These technologies help us to recognize you, customize or personalize your experience, offer additional products or services to you, and analyze the use of our Services to make it more useful to you.

We use cookies that are strictly necessary in order to facilitate your access to our Services or ensure your safety, as well as cookies or similar technologies for analytics.

Most browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the "help" menu on your browser, or access aboutcookies.org. Please note, however, that disabling our cookies may mean that you may not be able to take full advantage of our Services.

Section 03

Privacy Considerations When Using Cerebry's Custom Built GPTs

GPTs are custom versions of ChatGPT, an artificial intelligence tool offered by OpenAI. As a builder, Cerebry shares anonymized answers to math and science questions submitted by students either during practice, revision or post-test remedial practice. Cerebry receives information from OpenAI about such questions or prompts, which does not contain personal identifying information, and Cerebry's custom built GPT responds to the prompt.

The sole purpose of sharing the answers with OpenAI is to analyze the responses for correctness, conceptual understanding, and to generate educational feedback. Cerebry does not have access to your personal data when you use Cerebry's custom built GPT.

Remember: Cerebry's Custom Built GPTs are an AI tool. We recommend that you do NOT share personal data when using Custom Built GPTs or any other large language model (LLM).
Section 04

Uses of Personal Data and Legal Bases

We will only use your personal data when the law allows us to. Usually, we rely on the following grounds under European data protection laws:

PurposeType of DataLegal Basis
To provide and facilitate the ServicesIdentity & Contact Data, Payment Information, FeedbackContract
To communicate with you for non-marketing purposesIdentity & Contact DataContract, Legitimate interests
To send you marketing communicationsIdentity & Contact DataConsent
To review and consider employment applicationsIdentity & Contact Data, Professional InformationContract, Legitimate interests
To create and administer your accountIdentity & Contact Data, Payment Information, FeedbackContract, Legitimate interests
To facilitate paymentsIdentity & Contact Data, Payment InformationContract, Legitimate interests
To prevent and investigate fraud or unauthorized accessIdentity & Contact Data, Payment Information, Technical InformationLegitimate interests, Legal obligation
To investigate and resolve disputesIdentity & Contact Data, Prompts and Outputs, FeedbackLegitimate interests, Legal obligation
To debug and repair errorsIdentity & Contact Data, Feedback, Technical InformationLegitimate interests
To improve the Services and conduct researchIdentity & Contact Data, Feedback, Technical InformationConsent, Legitimate interests
To de-identify and train AI modelsPrompts and Outputs, Feedback, Technical InformationConsent, Contract, Legitimate interests
To enforce our Terms of ServiceIdentity & Contact Data, Prompts and Outputs, Technical InformationContract, Legitimate interests
Section 05

How We Disclose Personal Data

Cerebry will disclose personal data to the following categories of third parties:

Section 06

Rights and Choices

Subject to applicable law, and depending on where you reside, you may have some rights regarding your personal data, including the following:

To exercise your rights, you or an authorized agent may submit a request by emailing us at Info@Cerebry.co.

Section 07

Third-Party Websites and Services

Our Services may involve integrations with, or may direct you to, websites, apps, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not Cerebry and subject to the third party's privacy policy.

7A. Google Classroom Integration

Cerebry's feature to enable Educators to obtain Student Email, Assignment and Grade Information will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Section 08

Data Transfers

When you access our website or Services, your personal data may be transferred to our servers in the US, or to other countries outside the EEA and the UK. Where information is transferred outside the EEA or the UK, to a country that is not subject to an adequacy decision, we will ensure that your personal data is adequately protected by EU Commission and/or UK data protection law approved standard contractual clauses or applicable Binding Corporate Rules.

You can ask us to provide more information about the service providers we use and their locations by contacting us at Info@Cerebry.co.

Section 09

Data Retention

Cerebry retains your personal data for as long as reasonably necessary for the purposes and criteria outlined in this Policy.

Section 10

Children's Privacy Notice

This privacy notice supplements our Privacy Policy and provides additional information about how we collect, use and disclose personal information from children under the age of 13 (a "Child" or "Children").

Protecting the privacy of Children is especially important to Cerebry. When Cerebry is used by a School in an educational setting, we rely on the School to provide the requisite consent, on behalf of the Parent, for Cerebry to collect information from a School User under the age of 13 for educational purposes.
Section 11

Changes to Our Privacy Policy

Cerebry may update this Privacy Policy from time to time. When we make updates, we will post the updated Privacy Policy on this page and will update the Effective Date. We encourage you to review this page for updates when you access the Services.

Section 12

Contact Information

The responsible entities in respect of your personal data are:

Cerebry Pte. Ltd.
385 Pasir Panjang Road, #02-11, Singapore 118719
Company registration no.: 201621279N
Contact: Shubham Goyal (CEO) — Shubham@Cerebry.co

You can email us at Info@Cerebry.co

Please note that you have the right to lodge a complaint with the supervisory authority in the EU country in which you live or work. If you live or work in the UK, you have the right to lodge a complaint with the UK Information Commissioner's Office.