California Privacy Policy

Last updated: July 14, 2025

1. Scope of This Policy

This Privacy Policy explains how Brainista, Inc. (“Brianista”) (“we,” “our,” “us”) collects, uses, and discloses personal information when you:

• visit our website, mobile apps, or any other online service displaying this Policy (collectively, the “Site”);
• purchase products, create an account, or participate in promotions; or
• communicate with our customer‑service channels (e.g., phone, chat, email, and social media).

The California Privacy Policy supplements Brainista’s general Privacy Policy and is applicable to California residents. Further, additional supplemental terms may apply in specific regions or for specific programs (e.g., NFT drops). If a supplement conflicts with this Policy, the supplement controls for the covered region or program.

2. Notice at Collection (Summary)

We collect the categories of personal information listed in Section 3 for the purposes described in Section 5. We do not sell personal information for money, but we do “share” it for cross‑context behavioral advertising—only after you opt in. You can opt out of sale/share at any time through Your Privacy Choices.

3. California Privacy Notice (“Supplement”)

The following chart, required by the California Consumer Privacy Act as amended by the CPRA, applies solely to California residents and is incorporated by reference:

Statutory Category	Examples	Business / Commercial Purpose	Sold or Shared?*	Retention Period	SPI?
Identifiers	Real name, postal & email address, IP address, device IDs	Account creation, order fulfilment, fraud prevention	Shared for analytics/ads; never for money	7 yrs after last transaction	No
Sensitive Identifiers	Government ID, precise geo‑location	Age‑restricted delivery, fraud checks	No	Deleted immediately after verification	Yes
Commercial Information	Products purchased, returns, loyalty points	Customer service, marketing analytics	Shared for ad measurement	7 yrs	No
Internet / Network Activity	Page views, clickstream, Pixel/replay data	Site analytics, personalization	Shared for cross‑context ads	24 mo	No
Geolocation	Approx. location from IP; precise GPS if you consent	Localized content, fraud detection	No	24 mo	No
Audio, Electronic or Visual Data	Call recordings, chat transcripts	Quality assurance, dispute resolution	No	3 yrs	No
Inferences	Profiles reflecting preferences	Product recommendations	Shared for personalization	24 mo	No

*“Sold or Shared” follows Cal. Civ. Code §1798.140(ad)&(ah). We do not sell or share PI of known minors (< 16) without affirmative opt‑in.

Right to Limit SPI — California residents may direct us to restrict use/disclosure of SPI to necessary purposes. Exercise this right at Your Privacy Choices. California residents can direct us to limit the use and disclosure of Sensitive Personal Information (SPI) solely to necessary purposes. Submit a request through "Your Privacy Choices.” We confirm receipt within 10 business days and comply within 15 business days.

4. Categories of Personal Information We Collect

1. Information you provide – contact details, account credentials, payment data, user‑generated content, survey responses.
2. Information we generate – internal customer IDs, purchase history, loyalty metrics, inferred interests.
3. Information collected automatically – cookies, device IDs, IP address, browsing data, approximate location.
4. Information from others – social‑media platforms, data brokers, joint‑marketing partners, fraud‑prevention vendors.

5. How We Use Personal Information

• Provide goods & services (fulfil orders, process payments, manage loyalty programs).
• Communicate (transactional messages, support, marketing you have not opted out of).
• Operate & improve the Site (debugging, analytics, new features).
• Personalize content & recommendations.
• Advertise & measure the performance of our campaigns.
• Detect security incidents & prevent fraud.
• Comply with law and enforce our terms.

6. Recording & Tracking Notice (California)

To improve security, analytics, and customer service, we record or enable third‑party collection of

• telephone calls, chats, keystrokes, mouse movements, and page views; and
• HTTP headers, IP addresses, and other electronic communications as they transit our Site.

By continuing to interact with our Site or customer‑service channels after reading this notice, you expressly consent to such recording or tracking under Cal. Pen. Code §§ 631 & 632. If you do not consent, refrain from using the Site, disable cookies/JavaScript, or contact us by mail.

7. Pixel & Third‑Party Ad‑Tech (Opt‑In)

We embed the Meta Pixel, Google Ads Conversion Tag, and similar technologies (“Pixels”) to measure ad performance and deliver interest‑based ads. Pixels may send hashed identifiers, URLs visited, and purchase events to their platform providers.
Pixels are disabled by default for California residents until you click “Accept All” on our cookie banner. You may withdraw consent at any time via Your Privacy Choices, a GPC signal, or by clearing cookies.

8. Disclosure of Personal Information

We may disclose personal information to:

• Brands & subsidiaries within our corporate family.
• Service providers and contractors under written contracts that prohibit further sale, share, or retention beyond contracted services. We maintain written agreements with service providers and contractors prohibiting them from selling, sharing, or retaining your personal information beyond contracted services.
• Advertising & marketing providers (only after you opt in).
• Social‑media platforms when you interact with their widgets.
• Public or other participants in our forums.
• Law enforcement or regulators when legally required.
• Successors in a corporate transaction.

We do not sell your personal information for monetary consideration.

9. Your Privacy Rights and Choices

Depending on your residence, you may exercise:

Right	Description	How to Exercise
Know / Access	Obtain a copy of personal information collected about you.	Your Privacy Choices link
Delete	Request deletion of personal information (with statutory exceptions).	Your Privacy Choices link
Correct	Request correction of inaccurate information.	Your Privacy Choices link
Opt‑Out of Sale/Share	Stop our sale/share for cross‑context ads.	Your Privacy Choices link
Limit SPI	Restrict use of Sensitive PI.	Your Privacy Choices link
Appeal	Appeal a denied request (where applicable).	Your Privacy Choices link

We will comply with an opt‑out of sale/share within 15 business days and direct third parties who received the data in the last 90 days to do the same. We do not sell/share PI of minors under 16 without affirmative opt‑in.

10. Financial Incentives

We may offer loyalty points, birthday discounts, or referral credits that require personal information. Participation is voluntary. The material terms, including how the incentive value relates to your information, are disclosed at sign‑up. You may withdraw at any time via Your Privacy Choices.

11. Retention of Personal Information

We follow the schedule in the California Supplement (Section 3). If a category is not listed, we retain it no longer than seven (7) years after the later of (a) your last purchase/service interaction or (b) expiration of any charge‑back or statutory limitation period, unless a longer period is required for tax, contract, or litigation.

12. Non‑Discrimination

We will not deny goods/services, charge different prices, or provide a different level/quality of goods or services because you exercised your privacy rights.

13. Children’s Privacy

Our Site is not directed to children under 16. We do not knowingly collect PI from children without verifiable parental consent.

14. International Data Transfers

Your information may be processed in the United States and other countries with different data‑protection laws. Where required, we rely on Standard Contractual Clauses or adequacy decisions for such transfers.

15. Information Safeguards

We maintain technical and organizational measures designed to protect personal information. We never email you asking for passwords or payment data.

16. Third‑Party Sites and Platforms

Our Site may contain links/plugins to third‑party sites. Their privacy practices are governed by their own policies.

17. Contact Us

Email: help@brianista.com

18. Policy Revisions and Updates

We may revise this Policy from time to time. Material changes will be announced via banner or pop‑up at least 15 days before they take effect, and archived versions will remain available at the link above.