Issue Date: 23/05/2018
(Last Updated: December 2022 with effective date 01 January 2023)
The data controller is Easybrain Ltd, with a registered address at 3 Krinou Street, 6th floor, The Oval, 4103 Limassol, Cyprus.
1. INFORMATION WE COLLECT AND HOW
While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information” or “Personal Information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes:
Basic Identifiers and Contact Information
We 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 or advertising ID), language, time zone and IP address.
We collect information automatically about your activity through our Services (Usage Information), such as the date and time you used a service, features you have used, your in-app purchase 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, with your Google Play Games profile for Android Devices and with Facebook, in some of our Services).
When you download and use our Services, we automatically detect your general location, namely country and state through your IP address. We may collect, with your consent if applicable, other location information through your IP address, such as the city you are in.
Media and other files
We may ask for access to your camera in case you want to use certain features of our Services. In case you contact us through our in-app support feature and you need to upload any media or files as attachments, we shall ask for access to such files.
Information we obtain from third parties
We may receive information about you from our third party service providers, 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 when you connect with third parties
In cases we provide the option, and you decide, to connect our Services to your account with third parties like Apple, Facebook or Google, we may receive certain publicly available information about you, as well as any information that you allow or your settings enable to be accessed, including your Apple ID, Facebook user ID, Android Gamer Name, name and email subject to your permission. If you would like to manage your use of “Sign in with Apple” please go to Apple’s website to find out more. If you would like to edit the privacy and settings on Facebook, please go to Facebook’s website to find out more. If you would like to manage your use of “Sign in with Google Play Games” please go to Google’s website to find out more.
Information we obtain from Facebook
User generated content we obtain from you
We may collect content from posts or uploads on social networks or platforms or direct contact, subject to your consent if applicable. Such content may include, your name, social media username, image, likeness, voice, other identifiable information available in such user generated content.
Cookies and similar data collection technologies
Please note that, while your browser settings may allow you to transmit a “Do Not Track” signal when you visit the Services, our Services (including apps and websites) are not configured to respond to “Do Not Track” signals received from browsers.
For more information on how third parties may use tracking technologies in our apps, go to APPENDIX A and APPENDIX B further below.
2. 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, to sync your progress across devices when you log in to your account with third parties 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 allow you to back-up and sync your progress using third party social networks to our Services, such as Google Play Games, Apple Game Center or Facebook. Some of our Services provide the option to sync and back-up your progress across different devices when you log-in through third party social networks. These services are not activated automatically, but require explicit authorization by you. Please note that the third party social networks mentioned in this section are governed by their own privacy policies, terms and end-user agreements and we are not responsible for and have no control over the sharing practices or policies of the third parties that operate those sites. Further, when you disable the back-up feature, certain information might remain on your device(s) or the third party social network. To delete these remaining data, please visit your device’s or third party social network settings.
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 or by going to the app Setting -> About -> and then Privacy Settings.
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, the United Kingdom (the "UK"), Norway, Switzerland or Brazil, 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. Easybrain participates in, and complies with the policies and technical specifications of, the IAB Europe Transparency and Consent Framework (IAB TCF). Easybrain’s identification number within the framework is #350 (TCF v2.0 CMP Private). For our website sudoku.com, and in particular if you are based in the European Economic Area and the UK, OneTrust operates the consent management platform with the identification number 28.
To opt-out or withdraw your consent from receiving personalized advertisements, see the “Opt-out of targeted advertising” section below.
To use user generated content which has been provided by you and such content includes Personal Data. Our legal basis is consent which is obtained directly by you from the medium (e.g. e-mail, social networks, social platforms) used to obtain such content.
You may withdraw your consent by providing us with written notice by email at [email protected].
To respond to legal proceedings and other obligations or requirements under applicable law.
3. RETENTION OF PERSONAL DATA
We will also retain Personal Data and Usage Information for internal analysis purposes and legitimate business interest to the extent necessary to improve the functionality of our Services, for business purposes or when we are legally obligated to retain this data for longer time periods.
Your Personal Data collected through our Services will be retained for as long as permitted by applicable law or necessary depending on the respective purpose of collection and shall be deleted when they no longer serve one of the above-mentioned purposes or shall be anonymized and therefore will no longer constitute Personal Data. It is clarified that in no case the retention period should exceed the 5 years from the date of collection. Once we have deleted or anonymized 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.
4. 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.
Opt-out of targeted advertising
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 i.e. the Android advertising ID and/or Apple's ID for advertising (IDFA), device data 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.
Method 1 (depending on your local privacy laws) - App Settings:
- Open app Settings
- Select About/About Game
- Select Privacy Setting
- Select Advertising Preferences (or “Do Not Sell or Share my Personal Information”)
- Switch off the Enable All toggle, and then click Confirm Choices (Android) or Save & Exit (iOS)
Method 2 - Device Settings:
For iOS 14 and later:
- Open device Settings
- Select Privacy (& Security)
- Select Tracking and disable "Allow Apps to Request to Track" or disable permissions for specific app
For iOS 13 and older:
- Open device Settings
- Select Privacy
- Select Advertising and enable "Limit Ad Tracking"
- Open device Settings
- Select Google
- Select Ads and enable "Opt out of Ads Personalization" or "Delete advertising ID" accordingly.
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 (e.g. “contextual” 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 or the UK or a relevant national authority for unresolved complaints.
5. PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA
We may share the above categories of Personal Data for certain business purposes, including:
Personal Data of our users are stored in our data centers of our third party service providers in Canada and Germany, who act as data processors
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 and marketing.
For California residents, we may also “sell” or “share” your Personal Information, as defined under the California Consumer Privacy Act, and as amended by the California Privacy Rights Act for the purposes set out below. For more information about your rights as a California resident, please visit the “California Privacy Notice and Rights” section below.
For Virginia residents, we may also share or otherwise “sell” your Personal Data, as defined by the Virginia Consumer Data Protection Act (the “VCDPA”) for the purposes set out below, noting that a “sale” of personal data does not have the literal meaning of the word “sell” and as broadly defined by the VCDPA, includes exchanging of your personal data with third parties for “monetary consideration”. For more information about your rights as a Virginia resident, please visit the “Virginia Privacy Notice and Rights” section below.
We may share your 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. If you'd like to withdraw consent, or opt-out from having advertisements personalized in this way, please see the ‘Opt-out of targeted advertising’ section above.
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 are 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:
6. AGE LIMITS
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 and therefore children under the age of 16 years old (or older pursuant to applicable jurisdiction) should not download or use our Services. We do not knowingly collect personal information from children. If you believe that we may have collected personal information from a device of a child under the age of 16 years old (or otherwise as applicable), or for any other relevant reason, please send us a request for deletion and restriction of processing of Personal Data and opt-out from targeted advertising using the in-app Privacy Settings (for our apps go to the app -> Setting -> About -> and then Privacy Settings).
7. LINKS TO OTHER SITES
8. SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE AND RIGHTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The California Consumer Privacy Act (“CCPA”), as amended and expanded by the California Privacy Rights Act (“CPRA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.
Right to know what personal information is collected (Right of Access)
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 and third parties where your information has been “sold” or “shared” to do the same), unless this proves impossible or involves disproportionate effort. 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 instructions under the ‘Opt-out of targeted advertising’ paragraph found above, to configure the Privacy Setting in any of our apps 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 (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. In certain cases, you may also have the right to correct inaccurate personal information we hold about you. 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. If we cannot satisfy your request, we will respond to you with our justification for declining to take action. If you wish to appeal this decision, you can contact us through the method provided in “Contact Us” below.
9. SUPPLEMENTAL VIRGINIA PRIVACY NOTICE AND RIGHTS
Right of Access
You have the right to request from us to confirm whether or not we are processing their personal data and to obtain a copy of the personal data that you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right of Rectification
You have the right to request that we correct inaccuracies in their personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data
Right of Erasure
You have the right to request that we delete the information we have collected from you.
Right to object / Right to opt-out
You have the right to “opt-out,” from targeted advertising, to the sale of your personal data, or to profiling in furtherance in decisions that produce legal or similarly significant events. To submit an opt-out request, please follow the instructions under the ‘Opt-out of targeted advertising’ paragraph found above, to configure the Privacy Setting in any of our apps or by checking your device privacy settings.
Virginia residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CDPA.
Exercising Your Virginia Privacy Rights
To request access to or deletion of your personal information, to opt-out, or to exercise any other rights under Virginia law, please follow the instruction under the ‘Exercise your privacy rights’ section found above, and follow the necessary steps.
Response Timing and Format
We aim to respond to your 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. If we cannot satisfy your request, we will respond to you with our justification for declining to take action. If you wish to appeal this decision, you can contact us through the method provided in “Contact Us” below.
11. CONTACT US
3 Krinou Street, 6th floor,
The Oval, 4103
APPENDIX A - Advertising networks and their partners
(Last Updated: June 2023 with effective date 1 June 2023)
Acuity Ads is an advertising service provided by 140 Proof Inc. (US).
AdColony is an advertising service provided by AdColony Inc. (US).
Amazon Developer is an advertising service provided by Amazon, Inc. (US).
You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs
AppLovin and Applovin MAX
AppLovin is an advertising service and Applovin Max is an advertising mediation platform provided by AppLovin Corporation (US)
BidMachine is an advertising service provided by BidMachine Inc. (US)
Criteo is an advertising service provided by Criteo GmbH.
Epsilon (formerly known as Conversant) is an advertising service provided by Epsilon International UK Ltd, which is part of the Publicis Groupe (France).
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, except for users who are based in California and exercise their right to opt-out.
You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.
Fyber is an advertising service provided by Digital Turbine
Ad Manager by Google
Ad Manager by Google is provided by Google Ireland Ltd (Ireland)
You can opt-out from Ad Manager by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
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: https://www.google.com/ads/preferences/
Index Exchange is an advertising service provided by Index Exchange Inc.(Canada)
InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)
ironSource is an advertising service provided by ironSource Mobile Ltd (Israel)
Liftoff is an advertising service provided by Liftoff, Inc. (US)
LoopMe and partners
LoopMe is an advertising service provided by LoopMe Limited (UK).
Mintegral is an advertising service provided by Adlogic Technology Pte. Ltd (Singapore)
MobileFuse is an advertising service provided by MobileFuse LLC. (US)
Note: It is used only for users in the US.
Moloco is an advertising service provided by Moloco, Inc.
Ogury is an advertising service provided by Ogury Ltd (UK)
OpenX is an advertising service provided by OpenX Software Ltd (US)
Pangle is an advertising service provided by Bytedance Pte. Ltd. (Singapore)
Data of users based in the Chinese Mainland is processed by Shanghai Jinri Toutiao Technology Co., Ltd/Chuanshanjia whose:
Compliance Guide is available at: https://www.pangle.cn/terms/compliance-guide
PubMatic is an advertising service provided by PubMatic,Inc. (US)
PubNative is an advertising service provided by Verve Group Europe GmbH (Germany)
Rise Engage is an advertising service provided by TypeA Holdings Ltd (Israel).
ReklamUp is an advertising service provided by Commit IT Consultancy Ltd (UK)
Rubicon Project is an advertising service provided by Magnite, Inc. (US)
Sharethrough is an advertising service provided by Sharethrough Inc (Canada).
Smaato and their vendors
Smaato is an advertising service provided by Smaato, Inc. (US)
Smart is an advertising service provided by Smart Adserver SAS (France)
Tappx s an advertising service provided by TAPPCELERATOR MEDIA, S.L (Spain)
TripleLift is an advertising service provided by Triple Lift, Inc.
Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Verve is an advertising service provided by Verve Group, Inc.(US)
Vungle is an advertising service provided by Vungle, Inc. (US)
Xandr is an advertising service provided by Xandr,Inc. (USA)
Yahoo Japan is an advertising service provided by Yahoo Japan Corporation
You can opt out: https://btoptout.yahoo.co.jp/optout/index.html
Note: It is used only for users in Japan.
Yieldmo is an advertising service provided by Yieldmo, Inc. (US)
APPENDIX B - Analytics and other service providers
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).
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 Analytics is an analytics service provided by Google Inc.
For more information visit the site “How Google uses data when you use our partners' sites or apps” available at https://policies.google.com/technologies/partner-sites
Google reCAPTCHA is a spam protection service provided by Google LLC. (US)