(Last Updated: 31 December 2019 with effective date 01 January 2020)
The data controller is Easybrain Ltd, with a registered address at 3 Krinou Street, 6th floor, The Oval, 4103 Limassol, Cyprus.
INFORMATION WE COLLECT AND HOW
While using our Services, we may ask you to provide us with certain personal data or personally identifiable information that can be used to identify you (“Personal Data”, or “data” or “information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes: Basic device identifiers and Contact Information
We also collect some information from you when you provide it to us directly, such as via an email or online form, through the support feature embedded in our Services, or through another form of inquiry. This information may include your name, email, and phone number. If you apply for a job on our website, information you submit may also include a cover letter and any details included in your resume or curriculum vitae (CV).
When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address.
We collect information automatically about your activity through our Services, such as the date and time you used a service, features you have used, your in-app purchases history, subscriptions, your interaction with advertisements, 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).
Location and Other Information
We may collect, with your consent, other information such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections. 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 third party service provider, who collect this information 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.
Information we obtain from Facebook
Cookies and similar data collection technologies
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways in which we use your Personal Data, the legal bases we rely upon to do so and to provide you with an option to opt-out of certain practices, where applicable. We may use your Personal Data:
To provide and maintain our Services, recognize you when you return to our apps, and 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 a 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 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 from receiving personalized advertisements, see the “Opt-out of targeted advertising” section below.
To respond to legal proceedings and other obligations or requirements under applicable law.
RETENTION OF PERSONAL 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 Services 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 Services. 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 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 Setting tab in any of our apps or under the privacy settings of your iOS or Android device.
For iOS 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. Note: Irrespective of your choice, and/or your device settings you will continue to see non-customized advertising and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites. For more information go to ‘APPENDIX A - Advertising networks and their partners’ below.
Exercise your privacy rights
Any requests to exercise your rights should be made through Privacy Setting tab in any of our apps located in Setting -> About -> and then Privacy Settings or in 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). Any requests regarding our game(s) available on Facebook should be made through the embedded support feature by going to the game -> click on the settings icon -> click help and place your request. You can also send us an email at [email protected], 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.
PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA
We may share the above categories of Personal Data for certain business purposes, including:
Sharing with our service providers and partners
We use certain service providers and partners to help us operate and improve our Services. These service providers and partners assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing.
We may also “sell” or otherwise share for valuable consideration the above categories of Personal Data for the following purposes, noting that "sell" of personal information does not have the literal meaning of the word “sell” as typically would someone understand such term but should be interpreted in accordance with CCPA (as defined further below):
We may share information with advertising partners who distribute advertising in our Services. For further information on the advertising networks which may receive this information, 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.
In addition to the above, we may share your Personal Data in the following circumstances or for the following purposes:
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 have 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
The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.
Social sharing features
You have the right to know and see what information we have collected about you over the past 12 months, including:
- The categories of information we have collected about you;
- The categories of sources from which the information is collected;
- The business or commercial purpose for collecting your information;
- The categories of third parties with whom we have shared your information; and
- The specific pieces of information we have collected about you.
Right to Delete
You have the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
- Complete your transaction;
- Provide you a good or service;
- Perform a contract between us and you;
- Protect your security and prosecute those responsible for breaching it;
- Fix our system in the case of a bug;
- Protect the free speech rights of you or other users;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Right to Opt-out
You have the right to “opt-out,” or direct us to stop “selling” or otherwise sharing your information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please follow the instruction under the ‘Opt-out of targeted advertising’ paragraph found above, to configure the Privacy Setting in any of our app or by checking your device privacy settings.
You can request certain information about our disclosure of your information to third parties for their own direct marketing purposes during the preceding calendar year (provided that we are doing such practice at that moment). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights
To request access to or deletion of your personal information, to opt-out, or to exercise any other rights under California law, please follow the instruction under the ‘Exercise your privacy rights’ paragraph, found above, and follow the necessary steps.
Response Timing and Format
We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
3 Krinou Street, 6th floor,
The Oval, 4103
For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). For more information on how to opt-out go to Opt-out of targeted advertising [hyperlink to take you above] further above. In addition, the advertising networks listed below, with the exception of Fyber, Mobfox, 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.
Amazon Developer is an advertising service provided by Amazon, Inc. (US). Amazon does not require opt-in or opt-out signals from users in our services, relevant signals are collected directly from the user upon creating an account in such service.
You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs
AppLovin is an advertising service provided by AppLovin Corporation (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) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our services, relevant signals are collected directly from the user upon creating an account in such service.
You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.
Fyber is an advertising service provided by Fyber Group. (Israel)
Google AdMob 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
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/
IQzone is an advertising service provided by IQzone, Inc (US)
IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.
Liftoff is an advertising service provided by Liftoff, Inc. (US)
Mobfox is an advertising service provided by Mobfox US LLC
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)
OpenX is an advertising service provided by OpenX Software Ltd (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.
PubMatic is an advertising service provided by PubMatic,Inc. (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.
PubNative is an advertising service provided by PubNative GmbH (Germany)
Smaato and their vendors
Smaato is an advertising service provided by Smaato, Inc. (US)
Stack (by Appodeal)
Stack is an advertising service provided by Appodeal Inc. (US)
Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Verizon Media and their vendors
Verizon Media, previously known as Oath, provides advertising services under their AOL, Yahoo and other brands.
For more information on VerizonAOL (OATH) Vendors, please visit: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/topics/thirdparties/index.html
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.
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.
Adjust is analytics service provided by Adjust GmbH (Germany)
AppFigures is an analytics service provided by AppFigures, Inc. (US).
AWS is cloud computing services provided by Amazon Web Services, Inc. (US).
Fabric is an analytics service provided by Google Inc. (US)
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 the Services.
Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.
Firebase is an analytics service provided by Google Inc. (US)
Flurry Analytics service is provided by Flurry, Inc. which is owned by Verizon.
Google reCAPTCHA is a spam protection service provided by Google LLC. (US)