Rewali, Inc. Privacy Policy

Updated October 14, 2021

This privacy policy informs you of what information Rewali, Inc., a Delaware corporation headquartered in Washington, and the publisher of braincandy.com, collects from our users, how we use and store that data, and what controls are available to our users.  We may update this policy from time to time.  We will notify our users of any material changes to the policy by links on the site and or by email.

1. What This Policy Covers and How it Applies

We collect several different types of data when our users engage with the website, set up and use accounts.  The table below highlights which types of data we collect, how we collect it, our lawful basis for processing and storing that data – specifically the performance of our contract with your and our legitimate business interests.   By using our website and services you’re acknowledging that you agree to our Terms of Use and have read and understood this Privacy Policy and Cookie Policy (COMING SOON). 

What We CollectHow We Collect ItHow We Use It (our Lawful Basis for Processing)
Name, Email & PasswordFrom you, to create your account

(a) Identifying your individual account and delivering our service

(b) To keep our records updated and for administration and IT services

General Location, Browser & IP AddressWe collect the IP Address of any user accessing out website and we derive the associated location from that address.  We also track what users do on our site and which browsers and devices they prefer to use on our site.

(a) To study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.

Communications which you send to us We have multiple places on our website which allow our users to send information directly to us, we have multiple corporate emails, and we occasionally create surveys for our users 

(a) Delivering our service to our users

(b) To keep our records updated, for administration and IT services, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

Information derived from Tags, Stacks, Library, Comments, Bookclubs, and any other meta data types When users add books to a stack, create a stack title and description, mark books owned, liked, have read, use premade tags, or create custom tags or use similar types of features, meta data is created in our servers associated with that user and books in our database.

(a) Delivering our service to our users

(b) To keep our records updated, for administration and IT services, to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

2. How This Information is Shared

When you create an account on braincandy.com, we associate your activities with your account which also includes your personal information.  If you request that we share your information with other account holders, potential users, or braincandy bookclubs we will do so.  We will stop sharing when you request it, which may prevent us from providing certain services to you.  

We do not share passwords, IP addresses, or your communications with us with any other members.

We may use third party services to provide certain functionalities, such as book purchases, payments, or communications, and we require that they use your information only for the purposes we’ve authorizedYou are responsible for reading and understanding the terms and conditions and privacy policy that applies to your use of any third-party services.

We may share anonymized and aggregated data that doesn’t directly identify you. We also fully reserve the right to disclose any information we collect about you to comply with the law or law enforcement, to prevent fraud and abuse, to protect our legal rights, property, and the safety of braincandy.com, Rewali, Inc. and our employees, users, and others.

3. Links to Other Websites and Services

Our site may contain links or embedded apis or applets etc. which are connected to other websites or services.  When you utilize those access points any information shared with those others is governed by their Terms of Service and Privacy Policy. 

4. Retention

We will retain your profile information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.  If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. Deactivating your account does not automatically delete your account or usage data from our database, but regardless of any retention policy we will make reasonable efforts to enable you to delete your profile and personally identifiable information from our database upon request.  

5. Data Transfers

While you have an open account, you have the right to download a .csv file or equivalent list of books you’ve added to your library and personalized tags you’ve added to the list for your own personal use.  

We are a United States company that creates software in the US.  We use a third-party cloud service to host our website.  The servers they utilize are located throughout the world.  This policy follows the rules and laws of the United States.  IF you use our service you agree to be governed by this policy even if the law in your country may be different.

6. Your Rights Regarding Your Personal Information

Users residing in certain countries are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. While these rights are not applicable globally, all braincandy.com users can manage their personal information, as further described below, in their account settings.

You can request a downloadable copy of your personal information from your account settings page.  To change or delete your personal information you must be logged in.  You may also delete your account from the settings page.  As specified in our terms of service, we may retain certain information as required by law or as necessary for our legitimate business purposes.

7. Notice for California Residents

This Notice for California Residentssupplements the information contained in our Privacy Policy and applies solely to Users who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ( the “CCPA”) and any terms  in this Notice have the same meaning as defined in the CCPA.

Categories of personal information we collect:

Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories, and some examples of what we may collect, are:

  • Identifiers and contact or registration information, e.g., your name, and email address. 
  • User-generated content, e.g., creation of stacks and participation in Bookclubs. 
  • Customer service information, e.g., questions and other messages you address to us directly through online forms, by email, over the phone, or by post.
  • Device information and device identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers
  • Connection and usage data, e.g., information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information
  • Geolocation, e.g., city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, based on your mailing address
  • Other Information, e.g., any other information you choose to directly provide to us in connection with your use of the Services

How we use your personal information

We use and share the categories of personal information we collect about you consistent with the various business purposes we discuss throughout this Policy.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

CCPA rights disclosure

If you are a California resident, the CCPA allows you or an authorized agent on your behalf to make certain requests about your personal information. Specifically, the CCPA allows you or your agent to request:

  • Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Policy.
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorized agent to subject certain requests of your behalf. To verify that your agent has been authorized to make a request on your behalf, we may require them to provide us with a signed written authorization or a copy of a power of attorney.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at [email protected] or by using the help form on braincandy.com.

Shine the Light

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

8. Email and Mobile Notification

We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt-out of any marketing communications we send.We will send you email relating to your activities on braincandy.com. 

You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time by adjusting your notification settings. We’ll also send you service-related announcements when it’s necessary to do so.

8. Security

We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so braincandy.com and Rewali, Inc. cannot guarantee its absolute security. Your account information is protected by a password, which you should choose carefully and keep secure. 

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time at [email protected]