Privacy Policy

1. Introduction

This Privacy Policy explains how Crann Moroney, trading as BulkBrains (“BulkBrains”, “we”, “us” or “our”), collects, uses, stores and shares personal data when you use BulkBrains websites, applications, software, plugins and related services.

BulkBrains is based in Ireland and is the data controller for personal information that we determine the purposes and means of processing.

In some situations, particularly where a customer uses a BulkBrains Service to process information relating to their own users, customers or clients, BulkBrains may instead act as a data processor on behalf of that customer.

If you have questions about this Privacy Policy or wish to exercise your data-protection rights, contact: support@bulkbrains.com.

2. Services Covered by This Policy

This Privacy Policy applies to BulkBrains-operated Services that link to or incorporate this Policy.

These may include, without limitation:

• bulkbrains.com;
• BulkBrains Console;
• id.bulkbrains.com;
• BulkBrains Heatmap;
• BulkBrains DataMate;
• BulkBrains Verdict;
• SnipTok;
• Qwiky;
• BulkBrains Essentials;
• BulkBrains Chaseless;
• ZAVE;
• RouteCard;
• BulkBrains plugins;
• private or product-integrated APIs; and
• other BulkBrains-operated Services that refer to this Policy.

Some Services may also provide additional privacy information where their processing differs materially from this general Policy.

3. Information We Collect

The information collected depends on which BulkBrains Services you use.

We may collect or process information including:

• email address;
• name;
• age provided during account registration;
• password hash and associated security information;
• account creation date;
• last login information;
• temporary device and browser information;
• country inferred from an IP address;
• service configuration and account preferences;
• subscription and billing identifiers;
• content submitted to particular Services;
• technical and security logs;
• support communications; and
• information processed through third-party integrations.

We aim to collect only information reasonably necessary to operate, secure and improve our Services.

4. Account Information

If you create a BulkBrains account, we may store:

• your email address;
• your name;
• your age as entered during registration;
• your password hash and associated salt where password authentication is used;
• your account creation date;
• your last login information; and
• information required to maintain your account and Services.

The age supplied during registration is used to help verify that users meet the minimum age requirement for BulkBrains Services.

We do not require your precise date of birth solely for this purpose.

5. Google Sign-In

BulkBrains may allow you to authenticate using Google.

When you use Google Sign-In, Google may provide us with basic information such as:

• your Google account identifier;
• your email address;
• your name; and
• your profile image.

BulkBrains uses this information for authentication and account identification.

We do not permanently store your Google profile image merely because it is provided during authentication.

Google's processing of information is governed by Google's own privacy policies.

6. Device and Session Security Information

BulkBrains may temporarily process information about your browser or device to protect accounts and authentication sessions.

This may include:

• browser or user-agent information;
• general device information;
• country inferred from network information; and
• session-related identifiers.

This information may, for example, help us detect whether an authenticated session cookie appears to have been copied to or used on another device.

This information is generally temporary and associated with the lifetime of the relevant login session or cookie rather than being retained as a permanent profile of the user.

7. Server and Technical Logs

When you access a BulkBrains website or Service, our servers may automatically generate technical logs.

Logs may include:

• IP address;
• requested URL or resource;
• date and time;
• browser or user-agent information;
• HTTP response status;
• referring page where available; and
• other routine server diagnostic information.

These logs are used for security, troubleshooting, abuse prevention and reliability.

Server and access logs are generally retained for up to 30 days, unless longer retention is reasonably necessary to investigate abuse, security incidents, fraud or legal issues.

8. Payments and Stripe

Payments may be processed using Stripe or another payment provider.

BulkBrains does not ordinarily receive or store your complete credit or debit card details.

We may store identifiers and billing information such as:

• Stripe customer ID;
• subscription ID;
• usage or metered billing identifiers;
• subscription status; and
• information necessary to associate payments with your account.

Stripe processes payment information under its own privacy policy and terms.

Billing, accounting and transaction records may be retained after account deletion where required for taxation, accounting, fraud prevention, dispute resolution or other legal obligations.

9. Qwiky

Qwiky provides shortened URLs and may provide analytics to the creator of a shortened link.

When someone visits a Qwiky link, the visitor's IP address is received temporarily by our systems as part of the network request.

We do not store the visitor's raw IP address as part of Qwiky analytics.

The IP address may instead be immediately used to determine an approximate country, after which the raw IP address is not retained as Qwiky analytics data.

Qwiky analytics may include:

• approximate country;
• broad device category such as mobile, desktop or tablet; and
• the shortened link that was accessed.

Qwiky does not currently store detailed browsing history, referring websites or precise location information as part of these analytics.

Qwiky analytics may remain available for as long as the creator maintains the shortened link, unless deleted sooner.

The creator of a Qwiky link may delete associated analytics.

10. BulkBrains Heatmap

BulkBrains Heatmap processes analytics relating to Roblox experiences.

The Service may receive:

• a Roblox Universe ID; and
• player coordinate information.

BulkBrains Heatmap does not intentionally collect Roblox usernames, display names or Roblox User IDs for player-position analytics.

Player coordinates are converted into aggregated map-block or similar analytics values.

The stored heatmap data is not intended to provide a movement history for an individually identifiable player.

BulkBrains does not attempt to identify individual players from this analytics information.

The developer using Heatmap controls the relevant Roblox experience and is responsible for ensuring that their collection and use of analytics complies with applicable law and Roblox requirements.

Heatmap information may remain stored until the developer resets, reinitialises or deletes the relevant map or analytics information.

11. DataMate

DataMate allows authorised users to access and view Roblox DataStore information through Roblox Open Cloud.

Users may provide Roblox Open Cloud API credentials to enable this functionality.

BulkBrains stores credentials where necessary to operate the requested DataMate functionality and takes reasonable technical and organisational measures to protect those credentials.

Users are responsible for:

• keeping their Roblox credentials secure;
• using appropriately restricted API credentials where possible;
• ensuring they are authorised to access the relevant Roblox data; and
• ensuring personal data contained in their DataStores is collected and stored lawfully.

DataStore contents may pass through BulkBrains servers so that DataMate can retrieve and display them to the user.

BulkBrains does not ordinarily retain copies of retrieved DataStore values after they have been processed for display.

Where DataStore contents include personal data belonging to the DataMate customer's users, BulkBrains generally processes that information on behalf of the customer rather than determining why that information was originally collected.

12. BulkBrains Verdict

BulkBrains Verdict allows users to compare documents or submissions against specified requirements.

When a user selects a document for analysis, the document is processed in the user's browser and converted into text on the client side.

The original uploaded document is not ordinarily uploaded to or stored on BulkBrains servers.

The extracted text required for analysis is transmitted to Google Gemini to perform the requested analysis.

BulkBrains does not ordinarily store the resulting analysis after it is returned to the user.

Users may submit documents containing personal information. Users are responsible for ensuring that they are permitted to process and submit that information.

You should avoid submitting sensitive or special-category personal data unless it is genuinely necessary and you have an appropriate legal basis for doing so.

13. SnipTok

SnipTok may process information supplied by users for assisted or AI-powered video generation.

This may include:

• prompts;
• scripts or text supplied by the user;
• voice selections; and
• generated video output.

Prompt and generation instructions may be sent to Google Gemini through its API to perform requested AI functionality.

BulkBrains does not ordinarily retain the underlying prompts solely for AI processing after they are no longer needed.

Generated video output may be retained for up to approximately 30 days, unless removed sooner.

14. Chaseless

Chaseless allows customers to send automated reminders to individuals or organisations from whom documents or information are required.

Chaseless may process recipient information including:

• name;
• email address;
• company or organisation;
• details of the requested document or item;
• due dates;
• reminder history;
• whether a recipient has responded;
• submission instructions or destination; and
• other information entered by the Chaseless customer.

This information is generally provided by the customer using Chaseless, not directly by the reminder recipient.

In relation to this information, the Chaseless customer will normally act as the data controller and BulkBrains will normally act as a data processor providing the Chaseless Service.

The Chaseless customer is responsible for:

• having a lawful basis for supplying recipient information;
• keeping client and recipient information accurate;
• providing any privacy notices required by law;
• responding appropriately to data-protection requests; and
• deleting information when it is no longer required.

Recipients may stop Chaseless reminders where this functionality is provided.

Where a recipient opts out of reminders, relevant information may remain stored so that the Chaseless customer can maintain their records and so that the recipient is not unintentionally re-enrolled in the same reminder process.

Recipient information may otherwise remain stored until the Chaseless customer deletes the relevant record or account.

Chaseless does not ordinarily require the requested documents themselves to be uploaded to BulkBrains.

15. RouteCard

RouteCard allows users to create and save route information.

RouteCard may process:

• route coordinates;
• GeoJSON or similar route data;
• route configuration;
• saved route information; and
• information required to generate route-related data.

Route information saved to a user's account may remain stored for as long as the user keeps the route saved.

Temporary route-processing information that is not saved may be discarded after processing.

RouteCard does not currently collect or continuously track the user's live GPS location.

Route information may be transmitted to external providers where required to calculate or retrieve route-related information.

Providers currently used may include:

• OpenRouteService;
• Open-Meteo; and
• NOAA / National Centers for Environmental Information services.

These third parties process information according to their own privacy policies and terms.

16. ZAVE

ZAVE is a price-comparison service that may display information obtained through affiliate networks including Awin.

Users do not ordinarily need a BulkBrains account to browse ZAVE.

ZAVE does not currently create behavioural profiles based on products viewed or maintain its own persistent visitor tracking for product browsing.

When you follow an affiliate link, the relevant affiliate network or retailer may receive information about the referral.

Their subsequent processing is governed by their own privacy policies.

BulkBrains does not currently receive detailed purchaser information back from Awin merely because a user follows an affiliate link.

17. Artificial Intelligence Providers

Certain BulkBrains Services use third-party artificial intelligence providers.

These providers currently include services from:

• Google Gemini; and
• OpenAI where used by a particular BulkBrains Service.

When you use an AI-enabled feature, information necessary to perform the request may be sent to the relevant AI provider.

This may include prompts, extracted document text, configuration information or other content required to produce the requested output.

BulkBrains does not currently use customer content to train its own AI models.

Third-party AI providers may process data under their own contractual, security, retention and privacy arrangements.

18. Cookies

BulkBrains uses cookies and similar storage where necessary to operate account and website functionality.

Necessary cookies may be used for:

• keeping users signed in;
• authentication;
• security;
• session management;
• maintaining preferences; and
• protecting accounts from unauthorised session use.

Strictly necessary cookies may be used without optional consent where permitted by applicable law because they are required for requested functionality.

19. Advertising and Google AdSense

Certain BulkBrains Services may display advertising using Google AdSense.

AdSense may currently be used on Services including:

• BulkBrains Essentials; and
• DataMate.

Google and participating advertising providers may use cookies, device identifiers or similar technologies to serve, measure and personalise advertising where permitted.

Where consent is required by applicable law, non-essential advertising technologies will be subject to an appropriate consent mechanism before being used.

Users may be provided with controls to accept, reject or manage optional advertising-related processing.

Google's processing is also governed by Google's own privacy and advertising policies.

20. Email and Support Communications

BulkBrains may use your email address to send necessary communications relating to:

• account verification;
• account security;
• billing;
• subscription information;
• Service changes;
• Terms or Privacy Policy changes;
• support requests; and
• other operational matters.

BulkBrains does not currently use account email addresses for general marketing email campaigns.

Support correspondence may be retained indefinitely where reasonably useful for maintaining support history, resolving recurring technical problems, documenting disputes, preventing abuse or protecting BulkBrains' legal interests.

We may delete older support correspondence where it is no longer reasonably necessary.

Email services may be provided using third parties including Zoho.

21. Why We Process Personal Data

We may process personal information to:

• create and maintain user accounts;
• authenticate users;
• provide requested Services;
• process subscriptions and payments;
• provide customer support;
• secure accounts and infrastructure;
• prevent fraud and abuse;
• operate third-party integrations;
• diagnose faults;
• maintain and improve Services;
• comply with legal and tax obligations;
• enforce our Terms of Service;
• protect BulkBrains, our users and third parties; and
• provide advertising where applicable and permitted.

22. Legal Bases for Processing

Where the GDPR or similar data-protection law applies, BulkBrains relies on one or more lawful bases depending on the activity.

22.1 Contract

We process information where it is necessary to provide a Service you have requested or to perform our agreement with you.

This may include:

• account creation;
• authentication;
• subscriptions;
• payments;
• saved projects;
• requested AI processing; and
• other product functionality.

22.2 Legitimate Interests

We may process information where necessary for legitimate interests, provided those interests are not overridden by your rights.

These interests may include:

• security;
• fraud prevention;
• abuse detection;
• service reliability;
• technical diagnostics;
• protecting infrastructure;
• responding to disputes; and
• reasonable product improvement.

22.3 Legal Obligations

We may process and retain information where necessary to comply with tax, accounting, regulatory, court or other legal obligations.

22.4 Consent

Where required, we rely on your consent for optional activities such as non-essential advertising cookies or similar technologies.

Where processing is based on consent, you may withdraw that consent at any time.

23. Information Received from Customers About Other People

Some BulkBrains Services allow customers to supply information relating to other individuals.

Examples include Chaseless reminder recipients or information contained in customer-controlled Roblox DataStores.

In these circumstances, the BulkBrains customer is generally responsible for determining whether they are legally permitted to collect and supply the information.

Where BulkBrains acts solely on the customer's instructions, BulkBrains will generally act as a data processor and the customer will act as the data controller.

24. Sharing Personal Information

BulkBrains does not sell or rent personal information.

We may share information with service providers where reasonably necessary to operate BulkBrains.

These providers may include:

• Vultr for hosting;
• Stripe for payment processing;
• Google for authentication, AI and advertising functionality;
• OpenAI for certain AI functionality;
• Zoho for email services;
• Roblox for Roblox-integrated functionality;
• Awin for affiliate-related functionality;
• route, mapping and weather providers;
• other API providers used by a particular Service; and
• professional advisers where reasonably necessary.

We may also disclose information where required by law or where reasonably necessary to respond to lawful requests from courts, regulators, tax authorities or law-enforcement bodies.

25. Business Transfers

If BulkBrains or a relevant Service is sold, transferred, reorganised or combined with another business, relevant personal information may be transferred as part of that transaction.

Any such transfer will remain subject to applicable data-protection law.

26. International Transfers

BulkBrains' primary server infrastructure and databases are currently hosted by Vultr in Frankfurt, Germany.

Personal data stored directly by BulkBrains is therefore primarily hosted within the European Economic Area.

Some third-party providers may process information outside Ireland or outside the European Economic Area.

Where required, such transfers are carried out using legally recognised transfer mechanisms or safeguards relied upon by BulkBrains or the relevant provider.

Examples may include adequacy decisions, standard contractual clauses or other mechanisms recognised under applicable data-protection law.

27. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or justified.

Retention periods vary by Service.

For example:

• server logs are generally retained for up to 30 days;
• account information may be retained for the life of the account and during the account deletion process;
• inactive accounts may be removed after prolonged inactivity in accordance with our Terms;
• billing and tax records may be retained for legally required periods;
• Qwiky analytics may remain while the relevant link remains active;
• Heatmap analytics may remain until the developer deletes or resets the map;
• RouteCard routes may remain while the user keeps them saved;
• Chaseless records may remain until the relevant customer deletes them;
• SnipTok generated videos may be retained for approximately 30 days;
• support correspondence may be retained for an extended or indefinite period where reasonably necessary; and
• security or legal records may be retained for longer where required.

28. Account Deletion

Users may request deletion of a BulkBrains account by contacting support@bulkbrains.com.

Following deletion, account information may take up to approximately 30 days to be removed from active systems.

Residual copies may remain temporarily in backups before being overwritten or removed.

Some information may continue to be retained where necessary for:

• tax or accounting obligations;
• fraud prevention;
• security;
• legal claims;
• dispute resolution; or
• other lawful obligations.

29. Security

BulkBrains uses reasonable technical and organisational measures intended to protect personal information from unauthorised access, alteration, disclosure or destruction.

Measures may include:

• password hashing;
• authentication controls;
• access restrictions;
• session security;
• server security measures;
• network protections;
• monitoring for suspicious activity; and
• restricted administrative access.

No internet-connected system can be guaranteed to be completely secure.

Users are also responsible for keeping account credentials, API keys and integrations secure.

30. Sensitive Personal Data

BulkBrains Services are not generally designed to require special-category or highly sensitive personal data.

This can include information relating to health, biometric identifiers, racial or ethnic origin, political opinions, religion, sexual orientation or similar sensitive categories.

Users should avoid submitting sensitive personal information unless it is necessary for their use of a Service and they have a lawful basis for processing it.

This is particularly relevant when users submit text derived from documents to AI-enabled Services such as Verdict.

31. Automated Decision-Making

BulkBrains does not currently use personal information to make solely automated decisions about individuals that produce legal or similarly significant effects.

Some Services may use artificial intelligence to produce recommendations, analysis or informational outputs, but these are not intended to replace human judgment in significant decisions.

32. Children's Privacy

BulkBrains Services are intended for users aged 18 or older.

We do not knowingly offer BulkBrains accounts or Services to children.

If we become aware that an account has been created in violation of our age requirements, we may delete or restrict the account and associated information.

33. Your Data Protection Rights

Depending on your location and applicable law, you may have rights regarding your personal information.

These may include the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing relies on consent; and
• complain to a data-protection supervisory authority.

These rights are not absolute and may be subject to legal exceptions.

34. Exercising Your Rights

To exercise a privacy or data-protection right, contact: support@bulkbrains.com.

We may need to verify your identity before responding to a request.

Where BulkBrains processes information solely on behalf of another controller, such as a Chaseless customer, we may refer your request to that controller or assist them in responding.

35. Right to Object

Where BulkBrains relies on legitimate interests as the lawful basis for processing personal information, you may have the right to object to that processing.

You may submit an objection to support@bulkbrains.com.

We will consider the circumstances and stop the processing where required by applicable law.

36. Complaints

If you have concerns about how BulkBrains handles personal information, we encourage you to contact us first at support@bulkbrains.com.

You also have the right, where applicable, to lodge a complaint with a data-protection supervisory authority.

As BulkBrains is based in Ireland, the relevant supervisory authority is the Data Protection Commission of Ireland.

37. Links to Third-Party Websites

BulkBrains Services may contain links to third-party websites, retailers, APIs or platforms.

This Privacy Policy does not govern how independent third parties process information after you leave a BulkBrains Service.

You should review the privacy policies of those third parties before providing them with personal information.

38. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our Services, technology, providers, legal requirements or data-processing practices.

Minor changes may take effect when the updated Policy is published.

Where a change materially affects how we process personal information, we may provide additional notice, such as by email or through the relevant Service.

The Effective Date at the top of this Policy indicates when the current version became effective.

39. Relationship With Our Terms of Service

This Privacy Policy should be read alongside the BulkBrains Terms of Service and any additional privacy notices or product-specific terms that apply to a particular Service.

This Privacy Policy explains how personal data is handled and does not replace contractual terms governing use of the Services.

40. Contact

Questions, requests or complaints concerning privacy or personal data may be sent to:

Crann Moroney trading as BulkBrains
Email: support@bulkbrains.com