Issue Date: 23/05/2018
(Last Updated: June 2023 with effective date 01 July 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.
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.
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 perform analytics in order to gain insights into how our users interact with our products and services. We use first and third party analytical tools to understand how our users interact with our games. It helps us understand how users navigate in our games, what features they use, what actions they take, how long they play the game and how often they return. This helps us get insights into which parts of our games are popular and which parts need improvement. It also helps us understand what brought our users to our games and what keeps users engaged. With this information, we can give users a better experience (like making changes to our gameplay experience, changing annoying features, or troubleshooting bugs and problems).
Depending on your local privacy laws, to opt-out or withdraw your consent from processing of your information for Analytic Purposes, see the “EXERCISE YOUR PRIVACY RIGHTS” section below.
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 Settings (in certain apps you tap on the 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 Preferences.
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. 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.
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 certain USA residents, we may also “sell” or “share” your Personal Information, as defined under their respective State’s privacy laws, for the purposes set out below. For more information about your rights as a US resident, please visit the “SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS” 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’. 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.
In addition to the above, we may share your Personal Data in the following circumstances or for the following purposes:
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.
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.
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.
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.
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:
Facebook - https://www.facebook.com/about/privacy/
Instagram - https://help.instagram.com/519522125107875?helpref=page_content
5. 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 -> Privacy Preferences.
6. LINKS TO OTHER SITES
7. YOUR RIGNTS AND OPTIONS
Under the General Data Protection Regulation (GDPR), you have certain rights regarding your personal data. These rights include:
In addition to the above rights, you also have the option to withdraw consent if we are processing your personal data based on your consent, at any time.
To exercise any of these rights, please follow the instructions under the “EXERCISE YOUR PRIVACY RIGHTS” section found below, and follow the necessary steps. Please note that exercising some of these rights may impact our ability to provide our services to you. We will inform you of any such impact when you make a request to exercise your rights.
8. SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS
We are committed to protecting your privacy and ensuring that your personal information is handled in accordance with applicable privacy laws in the United States, including the California Consumer Privacy Act, Virginia Consumer Data Protection Act, the Colorado Privacy Act and the Connecticut Data Privacy Act (“US Privacy Laws”). For more information about specific states, please visit their relative section below.
To exercise any other rights conferred under US Privacy Laws, please follow the instruction under the “EXERCISE YOUR PRIVACY RIGHTS” section found below, and follow the necessary steps.
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.
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act (“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 “EXERCISE YOUR PRIVACY RIGHTS” subsection below.
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.
For more information about specific pieces of information we collect, please visit the “INFORMATION WE COLLECT AND HOW” section above.
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.
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 below, 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.
COLORADO, CONNECTICUT AND VIRGINIA
This Supplemental Privacy Notice only applies to our processing of personal information of personal data that is subject to the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) and the Connecticut Data Privacy Act (“CDPA”). These State Laws provide their respective state’s residents with certain rights listed here. To exercise these rights, see the “EXERCISE YOUR PRIVACY RIGHTS” subsection below.
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.
Depending on your area, 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
You have the right to request that we delete the information we have collected from you.
You have the right to “opt-out,” from targeted advertising, to the sale of your personal data, or depending on your state, 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.
In certain states, residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the US State Laws.
9. EXERCISE YOUR PRIVACY RIGHTS
To exercise your rights, please visit the Privacy Rights tab in any of our apps by navigating to your app’s homepage, clicking on the Gear Icon (three dots or more), then selecting Privacy Rights to choose the specific rights you wish to exercise. Alternatively, you can reach out to us through the support feature in our apps by going to your app’s homepage, clicking on the Gear Icon, selecting help or support, and then initiating a conversation by clicking the Start Conversation button.
Additionally, you have the option to contact us via email at [email protected]. However, please note that we might redirect you to use the in-app support feature where your identification is easier to achieve, or request additional information to facilitate your request. All requests are free of charge and will be promptly addressed, typically 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.
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 are listed in 'APPENDIX A - Advertising networks and their partners’, 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 Privacy Preferences (or “Do Not Sell or Share my Personal Information”)
- Click on “Withdraw Consent to All", 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’.
Opt-out of analytics (depending on your local privacy laws)
To perform analytics in our apps we use first and third party analytic tools in order to gain insights into how our users interact with our products and services. To do so, we use personal and non-personal information such as device identifiers, device data and/or other tracking technologies to enable and optimize this procedure.
For third-party analytics, in countries where the applicable laws and regulations require us to do so, your consent is the legal basis for processing. For more information about our third party partners, please visit “APPENDIX B - Analytics and other service providers”.
On the other hand, we collect user data for our own internal analytics tools, which is based on our legitimate interest to create better games and provide a more enjoyable experience for our users. The data collected is solely used for the purpose of our own analytics tool and is not shared with any third parties.
You can withdraw your consent or object to the processing based on legitimate interests for analytics purposes, at any time by checking the Privacy Setting tab in any of our apps.
Method (depending on your local privacy laws) - App Settings:
- Open app Settings
- Select Privacy Preferences
- Select “View Partners” and scroll until you reach the analytics section where you can change your preferences
11. CONTACT US
3 Krinou Street, 6th floor,
The Oval, 4103