PRIVACY POLICY
(Last Updated: February 2025 with effective date 12 February 2025)
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy applies to Easybrain’s games, apps, websites and related services (together, the “Services” or “games”, “apps”, “websites” for individual categories). This Privacy Policy explains how we, and affiliated companies (collectively, "Easybrain" or "we", "us", "our") collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.
The data controller is Easybrain Ltd, with a registered address at 335, 28th October Avenue, Trilogy Limassol Seafront, West Tower, Floor 14th, 3106, Limassol, Cyprus.
1. INFORMATION WE COLLECT AND HOW
While using our Services, we may process certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information” or “Personal Information”). The Personal Data we may process includes:
Basic Identifiers
such as mobile device ID’s, advertising ID (iOS Identifier for Advertiser, Android Advertiser ID), internal User ID’s and IP address.
Commercial Information
such as in-app purchase history and subscription details.
Device Information
including the type of device, operating system, resolution, application version, language and time zone.
Usage Information
information about how you interact with our Services, such as date and time of usage, features used, interaction with advertisements, and data generated during service use (e.g., game progress, levels completed, tournament participation).
Diagnostics
information that is collected about how our apps perform, such as crash logs, app performance data such as launch time, energy use and other diagnostic data collected for the purposes of measuring technical diagnostics related to the app.
Location Information
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
If you need to upload media or files as attachments through the in-app support feature, the service will request access to those files. We will also ask for access to your camera if you want to use certain service features.
Contact Information
such as your name and email address when you provide it to us directly through an email or online form, the support feature embedded in our Services, or through another form of inquiry.
Reviews and Communications
We will also process personal data and metadata of public reviews in App Stores, comments or contents of communication you have with us.
User-Generated & Community Content
Content you post or upload on social networks, platforms such as the App Store and Google Play Store, or direct contact with our social media sites, which may include your name, social media username, image, likeness, voice, and other identifiable information available in such user generated content. Our legal basis for this processing is your consent, which we obtain directly via the medium (e.g., email, social networks, or social platforms) used to share the content.
Cookies and similar data collection technologies
We, along with our third-party advertising networks, analytics partners, and service providers, may use cookies and similar technologies—such as mobile “SDKs”, pixels, and web beacons—to enhance and personalize your experience with our Services. These technologies help us deliver targeted advertisements, analyze performance, improve functionality, ensure security, and prevent fraud.
Some of these technologies enable the synchronization of behaviors and preferences across different platforms, devices, and apps. This allows us to tailor content, features, and advertisements to your interests. In addition, we and certain advertising networks may access your inventory of installed apps to avoid advertising already installed apps. In addition, they play a critical role in identifying and preventing unauthorized access, fraudulent activities, and other security risks to protect both you and our Services.
If you'd like to opt-out from having advertisements personalized in this way on your mobile device, please see the ‘Opt-out of targeted advertising’ section below.
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.
For more information on the use of cookies on our websites can be found HERE for Easybrain.com, HERE for Sudoku.com and HERE for Solitaire.net.
2. SOURCES OF DATA
How we obtain information depends on how you use the Services. For example, we may collect information:
you provide directly to us, such as when you contact us through email or online form, through the support feature embedded in our Services, or through another form of inquiry;
automatically when you download and use our Services, purchase or redeem one of our products or services, including in-app purchases and subscriptions or participating in an activity of functionality of our Services where you provide your information;
from third-party platforms, such as when you sync our Services with third-party accounts or post to our social media pages;
automatically, including through cookies and similar tracking technologies;
from third parties, such as advertising and marketing networks or business partners.
For more information on which third parties may provide us with your personal information in our Services, go to APPENDIX A and APPENDIX B.
3. 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:
Service Provision and Maintenance
We process your data to provide and maintain our services consistent with the terms of our End User License Agreement. This allows us to provide our apps and its functionalities, recognize returning users, maintain your preferences and settings, sync your game progress across various devices, provide technical and other support and conduct essential business functions.
Syncing and Backup via Third-Parties
With your explicit permission, we use your data to provide backup and sync functions via third-parties like Google Play Games and Apple Game Center. Please note that these third parties 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 backup feature, certain information might remain on your device(s) or the third party servers. To delete these remaining data, please visit your device’s or third party settings.
Administering and Protecting Our Services
We process your data based on our legitimate interest of administering and protecting our services and business. This includes actions such as troubleshooting issues, data analysis, testing, fraud prevention, and data hosting.
Communication and Continuous Improvement
We use your data to communicate with you, respond to your requests, and improve our services. These data are processed pursuant to performance of our End-User Licence Agreement, or based on our legitimate interests to keep our users updated about our Services and our new features in accordance with your preference.
To opt-out of communication with us for our Services, send us your request through the online contact us support feature.
Analytics
We analyze your data using our own as well as third-party analytical tools to better understand how our services are used. This helps us learn about user behavior within our games, including navigation habits, feature usage, actions taken, duration of play, and frequency of return. These insights allow us to enhance user experience by improving gameplay, revising less popular features, and fixing any bugs or issues. Processing personal data through our first-party analytics tools is based on our legitimate interests in improving our games, developing new services, conducting analyses to modify our software or content, and providing an overall better experience for our users. When it comes to third-party analytics, we rely on your explicit consent as the legal basis for processing in jurisdictions where necessary. For more information about our third-party partners, kindly visit “APPENDIX B - Analytics and other service providers”.
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.
Marketing
We use your data for marketing purposes to enhance your experience and inform you about our latest games and services, based on our legitimate interests in advertising to existing users. This includes promotions within games and, if you have consented, push notifications, which you can disable in your device’s settings. We also advertise through third-party websites, apps, and internet connected devices, using anonymized or aggregated data shared with our marketing partners. Our marketing partners help us by combining data we share, with information they have collected to improve the effectiveness of our ads. Additionally, we may use third-party data provided by our marketing partners when they have obtained your consent or have another legal basis to share this information with us. 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.
Personalised Advertisements
We and third party advertising networks will use information to be able to technically deliver ads to your device, and to enhance your experience, specifically through the personalization of advertisements, ensuring that the ads you encounter are of higher value, ultimately creating a more engaging and satisfying user experience.
For users who are located in the European Economic Area, the United Kingdom (the "UK"), Norway, Switzerland or Brazil we use a Consent Management Platform to gather your consent and preferences and to communicate them to our third-party advertising networks. 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 v2.2 CMP Private).
For our websiteswebsite Sudoku.com and for Solitaire.net, 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
Where local laws allow, this processing will be based on our legitimate interests to deliver content that is more aligned with your preferences and interests, continue providing our services for free, sustaining our business operations, helping us to grow, innovate, and continuously improve the services we offer.
Community Engagement
We process user-generated or community content provided directly by you through email, social networks, or social platforms. This content may include Personal Data, and we may use it for specific purposes, such as showcasing your contributions to our community (e.g., reposting on our social media channels or platforms) and promoting our services or engaging with our audience through marketing initiatives.
You may withdraw your consent by providing us with written notice by email at [email protected].
Legal Requirements
We may process your data to respond to legal proceedings and other obligations or requirements under applicable law.
4. RETENTION OF PERSONAL DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, provide our Services and enforce our legal agreements and policies.
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.
5. 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 Service Providers and Partners
Purpose: We use third party service providers, contractors and partners to assist in operating and improving our services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. These include personal data storage, hosting and maintenance, ongoing development, analytics, customer support, and marketing
Third Party Advertising
Purpose: Information may be shared with advertising partners who distribute advertising within the services. Details about these advertising networks can be found in ‘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.
For certain USA residents, we may also “sell” or “share” your Personal Information, as defined under their respective State’s privacy laws, for this purpose. For more information about your rights as a US resident, please visit the “SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS” section below.
For Corporate Transactions
Purpose: To transfer information in events like mergers, sales, acquisitions, restructuring, bankruptcy, or other changes of ownership or control.
When Required by Law
Purpose: To comply with legal obligations, protect the rights, property, or safety of the business, customers, or others.
Enforce Legal Rights
Purpose: 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
Purpose: Personal Data may be shared with third parties if you give consent or request such sharing. The reasons for sharing will be clearly communicated to you.
Social Sharing Features
Purpose: Services may offer social sharing features allowing you to share actions you take within the services with other media. These features require you to be over the minimum age limit prescribed by the legislation in your jurisdiction. The use of such features enables sharing of information with friends or the public, based on your settings with the entity providing the social sharing feature. Providers of these social features include Facebook and Instagram, among others. In all instances, we aim to ensure that Personal Data is shared responsibly, in accordance with user preferences, legal obligations, and industry standards for data protection.
6. CROSS-BORDER DATA TRANSFERS
Sometimes involves transferring data across borders, including outside of the EEA. Transfers are made to countries that provide an adequate level of data protection, or to entities that will provide sufficient guarantees that personal data will be processed in line with this privacy policy and applicable law, under standard contractual clauses approved by the European Commission.
7. 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.
8. LINKS TO OTHER SITES
Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.
9. YOUR RIGHTS 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.
10. 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, Colorado Privacy Act, the Connecticut Data Privacy Act, the Montana Consumer Data Privacy Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Law (SB255) and the New Jersey Data Protection Act (SB 332) (hereinafter referred to as “US State 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.
CALIFORNIA
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.
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.
For more information about specific pieces of information we collect, please visit the “INFORMATION WE COLLECT AND HOW” section above.
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 below, to configure the Privacy Setting in any of our apps or by checking your device privacy settings.
Other Rights
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, DELAWARE, IOWA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TEXAS, UTAH AND VIRGINIA
This Supplemental Privacy Notice applies specifically to our processing of personal information for residents of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah And Virginia as governed by their respective US State Privacy Laws. These laws grant residents certain rights regarding their personal data, which are outlined below. To exercise these rights, see the “EXERCISE YOUR PRIVACY RIGHTS” subsection below.
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
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
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 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.
Non Discrimination
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.
11. EXERCISE YOUR PRIVACY RIGHTS
Any requests to exercise your rights should be made through the Privacy Setting tab in any of our apps located by going to your home page and tapping the Gear Icon, three dots (or More), or the "Me" button, depending on the app > Privacy Rights and select which rights you want to exercise. You can also contact us through our support feature located in our apps by going to your home page and tapping the Gear Icon, three dots (or More), or the "Me" button, depending on your app -> click help (or support) -> and then click on the Start Conversation button, 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.
Opt-out of targeted advertising
To show you personalized advertisements in our apps that are tailored to you based on a determination of your characteristics or interests 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’.
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:
- Open the Settings on your iOS device
- Navigate down and select Privacy (& Security).
- Select Tracking Advertising (depending on your device's operating system).
- If you selected Tracking, enable or disable "Allow Apps to Request to Track" and/or this particular app from the list of apps.
- If you selected Advertising, enable or disable “Limit Ad Tracking” accordingly
For Android:
- Open the Settings on your Android device
- Navigate down and select either Privacy or Google (depending on your device operating system)
- If you selected Privacy, now choose Ads.
- If you selected Google, select Ads under the All Services section.
- Tap on Reset Advertising ID / 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
12. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.
In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.
13. CONTACT US
If you have any questions about this Privacy Policy, please contact us using the in-app support feature in our Services, which is the preferred method to be able to quickly respond your requests or contact our data protection officer at the address provided below:
Easybrain Ltd
335, 28th October Avenue
Trilogy Limassol Seafront
West Tower, Floor 14th
3106, Limassol, Cyprus
[email protected]