(Last Updated: October 2018 with effective date 31 October 2018)
The data controller is Easybrain Ltd, with a registered address at 3 Krinou Street, 701, The Oval, 4103 Limassol, Cyprus.
INFORMATION WE COLLECT AND HOW
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us. The information we collect include:
When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, and the mobile device identifiers (such as your device ID, advertising ID), language and time zone and IP address.
We collect information automatically about your activity through our Services, for example date and time you used a service, features you have used, in-app purchases history, subscriptions, and advertising that you click on, and data generated when you use our Services, for example your game progress which may be stored with your Apple ID on iCloud for iOS Devices or with your Google Play Games profile for Android Devices in some of our Services.
We may collect upon your permission other information such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.
Information we obtain from third parties
We may receive information about you from our analytic service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found in the APPENDIX B below.
We collect some information from you when you provide it to us directly, such as via an online form such as name, email, phone number and curriculum vitae (CV) or when you contact us through our in-app support feature or when you send us an email directly.
Cookies and similar data collection technologies
PURPOSES FOR WHICH WE WILL USE YOUR INFORMATION
We have set out below a description of the ways in which we use your information, the legal bases we rely upon to do so and provide opt-out, where applicable:
To provide and maintain our Services, recognize you when you return to our apps, and to perform essential business operation, our legal basis for processing is performance of a contract with you which you entered into with us when you download our Services and accept our End User License Agreement.
To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data), our legal basis for processing is legitimate interests for running our business, provision of administration and services.
To communicate with you about any career requests, contact forms, helpdesk support and to understand how you use our Services so that we can continuously improve our offerings, our legal basis is performance of a contract, legitimate interests or consent depending on the particular case to keep our users updated about our Services and our new features in accordance with your preference, and to continue to improve the Services we offer.
To opt-out of communication with us for our Services, send us your request through the online contact us support feature.
To cross-advertise our Services and products and to send push notifications for changes to our Services, to allow you to participate in new features of our Services when you choose to do so, our legal basis is legitimate interests to be able to advertise our Services and products to our users and keep our users updated about our Services and our new features in accordance with your preference.
To opt-out of receiving advertisements for our Services and products, send us request through the in-app support feature, by going to our app -> click on three dots (or more) -> click help (or support) -> and then click Contact us (or +) and send us your request.
You can opt-out of from receiving push notifications by turning them off at the device level through the settings of the device.
To serve personalized advertisements in our Services using third-party advertising networks, our legal basis is legitimate interests to run our business. However, if you are in the European Economic Area, Norway or Switzerland, some of our third-party advertising networks, will rely on your consent to process Personal Data in order to provide personalized advertising to you, therefore you will be asked whether you consent to the collection of your mobile device advertising identifier and IP address so that they can provide a personalized advertisement experience.
To opt-out or withdraw your consent of receiving personalized advertisements, see below ‘Opt-out of targeted advertising’.
RETENTION OF DATA
We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Your Personal Data collected through our apps will be deleted when they no longer serve one of the above-mentioned purposes but in any event your Personal Data will be deleted after 14 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
Your Personal Data collected through our Get in Touch forms will be deleted after 2 years from the date of receipt. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
YOUR RIGHTS AND OPTIONS
Access personal data we hold about you.
You have the right to request access to your Personal Data collected through our apps. Following your request, we will provide you a copy of your Personal Data in an electronic format.
For Personal Data you send us through our Get in Touch form on our website, simply send us your data access request through the same form as a Customer Support ticket.
You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your personal data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such a withdrawal.
To show you personalized advertisements in our apps we use third-party advertising networks and their partners, including those that need your consent and listed in ‘APPENDIX A - Advertising networks and their partners’ below, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple's ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure.
You can opt-out from personalized advertisement experience, at any time by checking the privacy settings of your Android or iOS device.
For Apple Devices:
- Open Settings
- Select Privacy
- Select Advertising and enable "Limit Ad Tracking"
For Android Devices:
- Open Settings
- Select Google
- Select Ads and enable "Opt out of Ads Personalization"
When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests.
Exercise these rights.
Any requests to exercise your rights should be made through our support feature located in our apps (by going to the particular app -> click on three dots (or more) -> click help (or support) -> and then click Contact us (or +) and place your request). You can also send us an email at email@example.com, however we may still redirect you to make the same request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
STORAGE, DISCLOSURE, TRANSFER AND SHARING OF YOUR INFORMATION
Share with our service providers and partners
We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.
For further information on advertising networks go to ‘APPENDIX A - Advertising networks and their partners’ below and for further information on analytics service provides go to ‘APPENDIX B - Analytics and other service providers’ below.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
When required by law
We may also share information if we also under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
Cross-border data transfers
Social sharing features
Some of our Services offer social sharing features which let you share actions you take in our Services with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in our Services. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. Our Services has social features from the following providers:
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.
LINKS TO OTHER SITES
3 Krinou Street, 701,
The Oval, 4103
Below, you can find a list with third-party advertising networks and their partners, with whom we work to provide you with a personalized advertisement experience within our apps. The advertising networks listed below, with the exception of Fyber and PubNative who act as data processors upon our instructions, are independent data controllers in respect of your personal data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.
In order to provide personalized advertisements to our users, those listed below use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA).
AOL (OATH) and their vendors
AOL is an advertising service provided by AOL, Inc. (US) part of Verizon family, which includes Yahoo, Inc.
For more information on AOL (OATH) Vendors, please visit: https://advertising.aol.com/specs/vendors
Amazon Developer is an advertising service provided by Amazon, Inc. (US)
AdColony is an advertising service provided by AdColony, Inc. (US)
Chartboost is an advertising service provided by Chartboost, Inc. (US)
Facebook Audience Network
Facebook Audience Network is an advertising service provided by Facebook, Inc. (US)
Fyber is an advertising service provided by Fyber Group. (Israel)
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
AdMob by Google and their partners
AdMob by Google is provided by Google Inc. (US)
For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903
You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
HyprMX is an advertising service provided by HyprMX Mobile LLC (US)
IronSource is an advertising service provided by IronSource, Inc. (US)
IQzone is an advertising service provided by IQzone, Inc (US)
Liftoff is an advertising service provided by Liftoff, Inc. (US)
Maio is a video advertisement service provided by iMobile Inc. (Japan)
Note: It is used only for users in Japan.
MoPub and their partners
MoPub is provided by MoPub, Inc. (US)
For more information on MoPub Partners, please visit: https://www.mopub.com/legal/partners/
You can opt-out from MoPub service by following the instructions on MoPub Opt-out page: http://www.mopub.com/optout/
MyTarget is an advertising service provided by My.Com B.V (Netherlands)
Nend is an advertising service provided by F@N Communications, Inc. (Japan)
Note: It is used only for users in Japan.
PubNative is an advertising service provided by PubNative GmbH (Germany)
Smaato and their vendors
Smaato is an advertising service provided by Smaato, Inc. (US)
Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Vungle is provided by Vungle, Inc. (US)
Yandex is an advertising service provided by Yandex LLC (Russia)
Note: It is used only for users in Russia.
YouAppi is an advertising network provided by YouAppi Inc. (US)
We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.
AppFigures is analytics service provided by AppFigures, Inc. (US).
AWS is cloud computing services provided by Amazon Web Services, Inc. (US).
Adjust is analytics service provided by Adjust GmbH (Germany)
Facebook Ads conversion
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on this Application.
Firebase is analytics service provided by Google Inc. (US)
Fabric is analytics service provided by Google Inc. (US)
Flurry Analytics service is provided by Yahoo! Inc. (US)
You can opt-out from Flurry Analytics service to prevent Flurry Analytics from using and sharing your information by visiting the Flurry's Opt-out page: https://dev.flurry.com/secure/optOut.do
Google reCAPTCHA is a spam protection service provided by Google LLC. (US)
FraudScore helps us detect fraudulent activity: conversion, install, registration, etc. provided by RT FRAUDSCORE
ANALYTICS LTD (CY)