Issue Date: 23/05/2018

PRIVACY POLICY

(Last Updated: December 2022 with effective date 01 January 2023)

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 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:

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:

3. 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.

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.

Other rights

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:
  1. Open app Settings
  2. Select About/About Game
  3. Select Privacy Setting
  4. Select Advertising Preferences (or “Do Not Sell or Share my Personal Information”)
  5. 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:
  1. Open device Settings
  2. Select Privacy (& Security)
  3. Select Tracking and disable "Allow Apps to Request to Track" or disable permissions for specific app
For iOS 13 and older:
  1. Open device Settings
  2. Select Privacy
  3. Select Advertising and enable "Limit Ad Tracking"
For Android:
  1. Open device Settings
  2. Select Google
  3. 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:

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.

In addition to the above, we may share your Personal Data in the following circumstances or for the following purposes:

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

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.

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.

For more information about specific pieces of information we collect, please visit the “INFORMATION WE COLLECT AND HOW” section above.

9. SUPPLEMENTAL VIRGINIA PRIVACY NOTICE AND RIGHTS

This Supplemental Virginia Privacy Notice only applies to our processing of personal information that is subject to the Virginia Consumer Data Protection Act (“CDPA” or “VCDPA”). The VCDPA provides Virginia residents with certain rights listed here. To exercise these rights, see the “Exercising Your Virginia Privacy Rights” subsection below.

10. 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.

11. 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:

Dimis Georgiades
Easybrain Ltd
3 Krinou Street, 6th floor,
The Oval, 4103
Limassol, Cyprus
[email protected]

APPENDIX A - Advertising networks and their partners

(Last Updated: February 2023 with effective date 22 Febryary 2023)

For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, the UK, Norway, Switzerland or Brazil, 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, content 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 Privacy Policy Opt-out of targeted advertising further above. In addition, the advertising networks listed below, with the exception of Fyber, Index Exchange 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.

Acuity Ads

Acuity Ads is an advertising service provided by 140 Proof Inc. (US).
Privacy Policy: https://privacy.acuityads.com/technology-privacy-policy.html

AdColony

AdColony is an advertising service provided by AdColony Inc. (US).
Privacy Policy: https://www.adcolony.com/privacy-policy/

Amazon Developer

Amazon Developer is an advertising service provided by Amazon, Inc. (US).
Privacy Policy: https://aws.amazon.com/privacy/
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)
Privacy Policy: https://www.applovin.com/privacy

BidMachine

BidMachine is an advertising service provided by BidMachine Inc. (US)
Privacy Policy: https://bidmachine.io/privacy-policy/

Criteo

Criteo is an advertising service provided by Criteo GmbH.
Privacy Policy: https://www.criteo.com/privacy/

Epsilon

Epsilon (formerly known as Conversant) is an advertising service provided by Epsilon International UK Ltd, which is part of the Publicis Groupe (France).
Privacy Policy: https://www.epsilon.com/emea/privacy-policy-services

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.
Privacy Policy: https://www.facebook.com/about/privacy/

You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.

Fyber

Fyber is an advertising service provided by Digital Turbine
Privacy Policy: https://www.digitalturbine.com/privacy-policy/

Ad Manager by Google​

Ad Manager by Google is provided by Google Ireland Ltd (Ireland)
For more information on how Ad Manager uses the collected information, please visit the Privacy Policy of Google: https://policies.google.com/privacy
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 how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/
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

Google AdSense

Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
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

Index Exchange is an advertising service provided by Index Exchange Inc.(Canada)
Privacy Policy: https://www.indexexchange.com/privacy/

InMobi

InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)
Privacy Policy: https://www.inmobi.com/privacy-policy/
Opt-out: https://www.inmobi.com/page/opt-out/

ironSource

ironSource is an advertising service provided by ironSource Mobile Ltd (Israel)
Privacy Policy: https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Liftoff

Liftoff is an advertising service provided by Liftoff, Inc. (US)
Privacy Policy: https://liftoff.io/privacy-policy/

LoopMe and partners

LoopMe is an advertising service provided by LoopMe Limited (UK).
Privacy Policy: https://legal.loopme.com/privacy-center#contract-hyartvn1o

Mintegral

Mintegral is an advertising service provided by Adlogic Technology Pte. Ltd (Singapore)
Privacy Policy:  https://www.mintegral.com/en/privacy/

MobileFuse

MobileFuse  is an advertising service provided by MobileFuse LLC. (US)
Privacy Policy: https://mobilefuse.com/privacy-policy/
Note: It is used only for users in the US.

Moloco

Moloco is an advertising service provided by Moloco, Inc.
Privacy Policy: https://www.moloco.com/advertising-policy

Ogury

Ogury is an advertising service provided by Ogury Ltd (UK)
Privacy Policy: https://ogury.com/privacy-policy/

OpenX

OpenX is an advertising service provided by OpenX Software Ltd (US)
Privacy Policy: https://www.openx.com/legal/privacy-policy/

Pangle

Pangle is an advertising service provided by Bytedance Pte. Ltd. (Singapore)
Privacy Policy: https://www.pangleglobal.com/privacy

Data of users based in the Chinese Mainland is processed by Shanghai Jinri Toutiao Technology Co., Ltd/Chuanshanjia whose: 
Privacy Policy is available at https://www.pangle.cn/en/privacy/partner
Compliance Guide is available at: https://www.pangle.cn/terms/compliance-guide

PubMatic

PubMatic is an advertising service provided by PubMatic,Inc. (US)
Privacy Policy: https://pubmatic.com/legal/privacy-policy/
Opt-out: https://pubmatic.com/legal/opt-out/

PubNative

PubNative is an advertising service provided by Verve Group Europe GmbH (Germany)
Privacy Policy: https://pubnative.net/privacy-notice/

Rise Engage

Rise Engage is an advertising service provided by TypeA Holdings Ltd (Israel).
Privacy Policy: https://risecodes.com/video-advertisement-player-privacy-policy/

ReklamUp

ReklamUp is an advertising service provided by Commit IT Consultancy Ltd (UK)
Privacy Policy: https://reklamup.com/privacy.php

Rubicon Project

Rubicon Project is an advertising service provided by Magnite, Inc. (US)
Privacy Policy: https://www.magnite.com/legal/advertising-technology-privacy-policy/

Sharethrough

Sharethrough is an advertising service provided by Sharethrough Inc (Canada).
Privacy Policy: https://www.sharethrough.com/privacy-center/consumer-privacy-notice

Smaato and their vendors

Smaato is an advertising service provided by Smaato, Inc. (US)
Privacy Policy: https://www.smaato.com/privacy/ For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/

Smart

Smart is an advertising service provided by Smart Adserver SAS (France)
Privacy Policy: https://smartadserver.com/end-user-privacy-policy/

TripleLift

TripleLift is an advertising service provided by Triple Lift, Inc.
Privacy Policy: https://triplelift.com/privacy/

Unity Ads

Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Privacy Policy: https://unity3d.com/legal/privacy-policy

Verve

Verve is an advertising service provided by Verve Group, Inc.(US)
Privacy Policy: https://www.verve.com/privacy-policy/

Vungle

Vungle is an advertising service provided by Vungle, Inc. (US)
You can opt-out from Vungle service by following the instructions as described by Vungle on their Privacy Policy page: https://vungle.com/privacy/

Xandr

Xandr is an advertising service provided by Xandr,Inc. (USA)
Privacy Policy: https://www.xandr.com/privacy/platform-privacy-policy/

Yahoo and partners

Yahoo, previously known as Verizon Media/Oath, is  an advertising service provided by Yahoo Ad Tech LLC (USA)
Privacy Policy: https://legal.yahoo.com/us/en/yahoo/privacy/index.html
For more information on Yahoo partners, please visit:
https://legal.yahoo.com/ie/en/yahoo/privacy/topic/ourpartners/index.html

Yieldmo

Yieldmo is an advertising service provided by Yieldmo, Inc. (US)
Privacy Policy: https://www.yieldmo.com/privacy-policy/

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

Adjust is analytics service provided by Adjust GmbH (Germany)
Privacy Policy: https://www.adjust.com/privacy-policy/

AppFigures

AppFigures is an analytics service provided by AppFigures, Inc. (US).
Privacy Policy: https://appfigures.com/privacy

AWS

AWS is cloud computing services provided by Amazon Web Services, Inc. (US).
Privacy Policy: https://aws.amazon.com/privacy/

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.
Privacy Policy: https://www.facebook.com/about/privacy/

Facebook Analytics

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.
Privacy Policy: https://www.facebook.com/about/privacy/

Firebase

Firebase is an analytics service provided by Google Inc. (US)
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://www.google.com/intl/en/policies/privacy/

Flurry Analytics

Flurry Analytics service is provided by Flurry, Inc. which is owned by Verizon.
Privacy Policy: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/index.html

Google Analytics

Google Analytics is an analytics service provided by Google Inc.
Privacy Policy: https://policies.google.com/privacy

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

Google reCAPTCHA is a spam protection service provided by Google LLC. (US)
It is primarily used to distinguish whether an input is made by a natural person or abusive by automated processing. The service includes sending data required by Google for the reCAPTCHA service to Google. Additional information about Google reCAPTCHA and Google's privacy policy can be found at https://policies.google.com/privacy.