Privacy Policy - Basirah App

Last Updated: November 25, 2025

This privacy policy covers how the Basirah App (developed by Financial Labs Oy, Isokatu 25, 90100 Oulu, Finland, hereinafter "Service Provider") collects and treats information about its users.

Anyone who downloads, saves, installs, uses, accesses, attempts to use or access the Basirah App, or connects/integrates another service with the app shall by so doing be deemed to have agreed to the terms of this privacy policy and such collection, use and other processing of data as set forth below.

All capitalized terms used and not otherwise defined herein have the meanings ascribed to them in the Terms of Service.

Nothing herein is intended to limit the user’s statutory data processing rights.

Processing of Personal Data

The Service Provider only processes personal data necessary for the performance of its contractual obligations to the user according to the Terms of Service, or in order to take steps at the request of the user prior to entering into the Terms of Service.

The Basirah App is designed for children participating in structured training programs and their families. We are committed to protecting the privacy of all users, especially children.

We do not intend to process special categories of personal data (such as data on racial or ethnic origin, political opinions, religious beliefs, etc.) unless strictly necessary for the educational purpose and with explicit consent. We will only process such data when the user (or their guardian) submits such data to the app at their own will, for example, to track progress in specialist education programs.

How Personal Data Is Collected Through Use Of Basirah App

We may collect information (including personal data) about Data Subjects (Users):

• (a) Account Creation & Management: When a user (parent/specialist) creates an account, subscribes to a program, or modifies a user profile.
• (b) App Usage: When a child or specialist uses the Interactive Activities, Remote Sessions, or Home Practice features. This includes progress data, milestones, and usage logs required to provide visual progress updates.
• (c) Remote Sessions: During secure virtual sessions between the child and their specialist.
• (d) Technical Data: When a user downloads, installs, updates, or accesses the app (e.g., device information, crash logs).

Storage Period For Personal Data

We will keep personal data for as long as necessary to fulfill contractual obligations towards the Data Subject, as specified in the Terms of Service (e.g., maintaining progress history for the duration of the education program). Personal data will be deleted or anonymized as soon as possible after the termination of the User’s account unless it must be stored in order to fulfill statutory legal obligations.

Where Personal Data Is Processed

The data controller is Financial Labs Oy, a company based in Oulu, Finland. We may use sub-suppliers and transfer personal data to these sub-suppliers, including sub-suppliers in countries not considered to provide adequate protection for personal data. In such cases, we will only transfer personal data subject to appropriate safeguards provided by sub-suppliers, such as standard data protection clauses adopted by the EU Commission.

Transfer Of Personal Data To Others

We will not transfer or provide access to a Data Subject’s personal data to any third party except:

• With the Data Subject’s (or guardian's) consent.
• As required by law.
• As necessary to perform obligations under the Agreement (e.g., sharing progress data between the Child's account and their supervising Specialist/Family account).

Customer's Rights

• Access: Upon request, we will grant the Data Subject access to all Personal Data maintained about them.
• Rectification or Erasure: If any Personal Data proves to be incorrect or misleading, the Data Subject is entitled to have the data rectified. Users can correct certain data through their profile settings.
• Data Portability: The Data Subject has the right to receive their personal data in a structured, commonly used, and machine-readable format.

Children's Privacy

The Basirah App is designed for children. We encourage parents and guardians to take an active role in their children's online activities. We do not knowingly collect personal information from children without the consent of a parent or guardian. If you believe we have collected information from a child without appropriate consent, please contact us.

Notification

All requests, inquiries, complaints, and other communications regarding this privacy policy or data processing should be submitted via email to Financial Labs Oy.

Jurisdiction

Any dispute that may arise between the Data Subject and the Service Provider in connection with this privacy policy shall be subject to the jurisdiction specified in the Terms of Service.

Change of Policy

We may amend this privacy policy at any time by posting a revised version in the app or on our website.