Brain Box Code Privacy Policy
Version 1.0
Effective January 30, 2024
Introduction
Brain Box Code , its partners, parent companies, subsidiaries, licensees, licensors and affiliates.(collectively, the “Company”, “we” or “us”) develop, publish, market and commercialize a variety of games for use on various platforms, including mobile devices (our “Applications”) through which we offer relating game play and social gaming services, including the ability to make purchases through the Applications (collectively, the “Services”).
Notice
We respect your privacy and are committed to protecting personal information that you provide in connection with your use of the Services. This Privacy Policy is intended to provide notice of the Company’s information practices, including the types of information gathered, how information is used and safeguarded, and how you may control the maintenance and sharing of your information.
WE USE DATA COLLECTION TOOLS, SUCH AS DEVICE IDs, TO OFFER YOU A BETTER EXPERIENCE WITH OUR SERVICES AND APPLICATIONS, PERSONALIZE CONTENT, TO ALLOW US AND OUR PARTNERS TO PROVIDE YOU WITH TARGETED ADVERTISEMENTS AND TO COLLECT ANONYMOUS STATISTICAL INFORMATION TO ENHANCE THE FUNCTIONALITY AND PERFORMANCE OF OUR SERVICES AND APPLICATIONS.
Types of Personal Information We Collect and How We Use It
When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
The types of personal information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Brain Box Code and the requirements of applicable law. Some of the ways that Brain Box Code may collect personal information include:
you may provide personal information directly to Brain Box Code through interacting with the Services, participating in Services feedback, questionnaires, surveys, or contests or participating in forums discussions, and requesting services or information; and
as you navigate the Services, certain passive information may also be collected about your visit, including through technologies as described below.
Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services. We endeavor to collect only that information that is relevant for the purposes of processing. Below are the ways we collect personal information and how we use it.
Types of Personal Information We Collect
Brain Box Code collects personal information regarding its current, prospective, and former customers, users, visitors, and guests (collectively “Individuals”).
Information Collected Directly from You:
When you use the Services or engage in certain activities, such as responding to surveys, requesting services or information, or contacting us directly, we may ask you to provide some or all of the following types of information. We will store that personal information on our systems and process it for the purposes described in this Privacy Policy.
Communications with Us. We may collect personal information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
Communications with Other Users. You may send non-public messages or invitations to other players, made directly through our Services or through a third-party service, like Facebook. If so, we will collect whatever information you choose to send to the other users, and if you connect your third-party service’s account, we may collect information about the friends and contacts you are connected to through the third-party service. You are responsible for ensuring your sharing of this personal information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information. We may also get personal information about you from other users. We process this personal information to help you and your contacts connect through our Services. If you want to remove personal information stored by us, follow any instructions in the Services or see Online Privacy Choices below.
User Reviews. From time to time, you may share your comments about our games and provide certain information that may include personal information. All information collected from your participation in such reviews is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
Fan Pages, Forums, and Posting on the Site. Brain Box Code may offer publicly accessible fan pages, blogs, private messages or community forums. You should be aware that when you disclose information about yourself on Brain Box Code ’s fan pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any personal information. We may keep such content on our servers to use it to protect the safety and well-being of our players; to protect our rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this. If you choose to submit content to any public area of the Site, such content will be considered public.
Registration for Contests. Occasionally, Brain Box Code may run contests. We ask those who enter the contests to provide contact information (e.g., an e-mail address). If you participate in a contest, your contact information may be used to reach you about the contest and for other promotional, marketing and business purposes. All contest entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
A note on sensitive personal information. While we typically do not request sensitive or special categories of personal information you may choose to provide this information to us. The meaning of sensitive or special categories of personal information changes from region to region but could include information about your health or, in certain places, types of financial or precise location information. For some Services, we may also ask you to voluntarily provide information about any accessibility requirements you may have to better understand the needs of players and to improve the accessibility of our Services.
Information Collected from Third Parties when Installing and Playing the Games
If you play any of the games or use any of the Services on connected third-party applications or connect the Services to any third-party applications, like Apple, Google, Amazon and/or from Social Networking Sites (“SNS”) such as Facebook, Brain Box Code may receive certain information about you from the provider of the third-party application. The information received depends on the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.
When you connect with the Services through an SNS, the information that Brain Box Code collects may include your first and last name, your SNS user identification number and/or user name, location, sex, the login e-mail you provided to that third-party application when you registered with the SNS, language of your application, time zone and the SNS user identification numbers for your friends who are also connected to the Services.
We may sell Virtual Items or Merchandise through our Services. When you make purchases through the Services, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, and Amazon App Store (together with any similar applications, “App Stores”) and SNS such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of Brain Box Code , including your name, email address, address and other billing information. App Stores do not share this information they collect from you with us. Brain Box Code does not have access to your credit card or bank account data. However, third-party payment processors may share non-financial information with us related to your purchases, like the items purchased to fulfill your order.
You can manage the information Brain Box Code receives about you from a third-party application on which you play our games, like Facebook. You will need to follow the instructions from that third-party application for changing your privacy settings. You also can manage some aspects of information collection and use by visiting the settings page of your mobile device and reviewing the permissions of each application.
If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy. If you are unclear about what information a third-party application is sharing with us, please go to that third-party application to find out more about their privacy practices and any options available to you regarding such sharing.
Automated Information Collection
When you use any of the Services, games or applications on a mobile platform, Brain Box Code may collect and record certain information such as your unique device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (“IDFA”), the version of your operating system ("OS"), your device name, Game Center ID, and your location based on your Internet Protocol ("IP") address. This information is useful to Brain Box Code for troubleshooting and helps Brain Box Code understand usage trends.
As further described in our Cookie Notice, we use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, software development kits (SDKs) and device identifiers) to recognize you and/or your device(s) on, off, and across different Services and devices. We also allow others to use cookies and similar technologies in our Services as described in our Cookie Notice. Neither we nor any third party uses cookies or other similar tracking technology on our Sites. You can control or opt out of the use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising, as described in our Cookie Notice.
We, our service providers, and our business partners use these cookies and other similar technologies within our games to collect and analyze certain kinds of technical information, such as your IP address, cookie identifiers, mobile advertising identifiers, your mobile device’s identifiers like your IDFA, Game Center ID, the type of mobile device you are using, your device's OS, version, model, hardware type and other device identifiers that are automatically assigned to your device, language, hardware type, operating system, Internet service provider, and other actions taken through use of the Services such as preferences. We may also collect the approximate physical location of your device. This data collection will be made clear by the operating systems that you are using the Services on.
In some cases, we will connect this information with your social network ID, Device ID, Game Center ID or IDFA.
We use “Google Analytics” to collect information about your use of the Services. Google Analytics collects information such as how often users access the services, what pages they access when they do so and what other sites, they used prior to using the services. We use the information we get from Google Analytics only to improve the services. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit https://www.google.com/policies/privacy/partners/ and the Google Analytics Opt-Out browser add-on page.
Social Media Widgets
The Services include social media features, such as the Facebook and Twitter button, and Widgets, such as the “Share” button or interactive mini-programs that run on the Services. These features may collect your IP address and which page you are visiting on the Services and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third-party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it.
How We Use Your Information
Our primary goals of using the information that we collect and store are to provide a better gaming experience, provide the Services to you, improve the Services, protect you and others, contact you, conduct marketing and research activities, create reports for internal use, for business continuity reasons and to comply with legal rights and obligations. We store information on servers located in the United States and in the European Union via Amazon Web Services and may store information on servers, cloud technologies and equipment in other countries.
The main reason we process your personal information is to provide you with Services and to improve your gaming experience, but there are other reasons as well. We collect, store, use and process personal information for a variety of business purposes, including:
to operate, improve and optimize our games and other Services;
to create game accounts and allow users to play our games;
to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience;
to provide access to certain areas, functionalities and features of our Services;
to notify you about in-game updates, new products or promotional offers that may be of interest to you;
to notify you about rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our business partners;
to tailor and deliver advertising and marketing and promotional information to you;
to enable players to communicate with each other in games or on our social media accounts;
to respond to your comments and inquiries and provide customer support services;
to prevent potentially prohibited or illegal activities and protect our players;
to measure interest in our Services;
to send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages;
to comply with our legal obligations, to resolve any disputes we may have with you or other players and to enforce our agreements with third parties;
to conduct research;
to ensure internal quality control; and
to verify Individual identity.
Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:
Establish and perform our contract with you (i.e., our Terms of Services);
For our or our partners’ legitimate interests;
Consent (where applicable);
Compliance with a legal obligation;
Protect your vital interests or those of another person (for example, another player); and
While we typically do not collect sensitive or special category personal information, where we do this, it will be on the ground of consent or other applicable lawful basis.
If you have questions, need further information about the legal grounds for processing your personal information, or want to withdraw your consent please see the Contact Information section below.
How We May Disclose Your Information
We may share your information with third parties or allow third parties to collect this information from our Services in the following circumstances.
Service Providers. We may share any information we receive with Service Providers. The types of service providers to whom we entrust personal information include Service Providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; (v) analytics; and (vi) in connection with the provision of the Services. As required by applicable data protection laws, Brain Box Code has executed appropriate contracts with the Service Providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners and Affiliates. Brain Box Code may share personal information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with the Services that you have requested. Brain Box Code may also provide personal information to business partners with whom we may jointly offer products or Services. In such cases, our business partner’s name will appear, along with Brain Box Code . As required by applicable data protection law, Brain Box Code requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which Brain Box Code provided it.
Displaying to Friends and Other Users. Our Services allow you to interact with other players. If you play our games through a social network or register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity, communicate with you within our Services if you use the chat feature of our games and view your game profile, which may include your name or a “game name” and your profile photo. In certain cases, your profile photo can reveal your social network ID or player ID, and access to a social network ID or player ID may allow others to view the public information associated with your related social network profile or the game account. Also, the content you post may be displayed in the chat feature of the Games. We are not responsible for privacy practices of the other users who will view and use the posted information.
Third-Party Advertising Including Interest-Based Advertising. We use advertising to enable us to offer some of our games, game features, and other Services for free. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Brain Box Code .
We may share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. We do not directly share personal information that identifies you with third-party advertisers for their advertising purposes unless you give us your consent, where legally required. To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:
performance data (like the number of clicks on an advertisement);
certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
a unique identifier, such as your social network ID or Brain Box Code player ID; and/or
other contextual data about your game play (like your level and session length).
In addition to serving you with relevant ads, the information collected may be used to:
measure how effective ads are;
offer you targeted advertising (both on and off our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
undertake web analytics to analyze traffic and other player activity to improve your experience.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Brain Box Code or the social network through which you are playing Brain Box Code ’s games.
If you do not want to receive tailored in-application advertisements from third parties, please see the Online Privacy Choices section below. For more information on controlling the use of cookies and similar technologies, please see our Cookie Notice. Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies. If you have any questions about how these third-party services use your information, you should review their policies and contact them directly.
Security, Safety, and Compliance with Law. We may access, preserve, and disclose your personal information, other account information and content if we believe doing so is required or appropriate: (i) to satisfy any applicable legal obligations; (ii) when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement or legal process, such as a court order or subpoena; (iii) to respond to your requests; (iv) to protect your, our or others’ rights, property or safety; (v) to enforce Brain Box Code ' policies or contracts; (vi) to collect amounts owed to Brain Box Code ; (vii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (viii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes—e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies, so they may identify users in connection with their investigation of the unauthorized activities.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Brain Box Code will endeavor to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.
Other Third Parties. In addition to the sharing described above, we may share your information with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.
What Choices Do You Have Regarding Our Use of Your Personal Information?
We may send periodic promotional or informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the e-mail. Please note that it may take up some time for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you e-mails about your account or any Services you have requested or received from us.
If you want to request to review, delete, or change the information we have about you; request that we no longer make active use of your information; or if you have additional questions, please send an email to us at gokiludin2@gmail.com.comwith your request and identifying information in the body of the email, including your first name, last name, e-mail address or login name you use to access our Application and Services. We will respond to your email as soon as possible. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have previously allowed us to access your precise geolocation data or receive push notifications through your device, you can stop making precise geolocation available to us or receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself. In some instances you can also stop or limit the type of device IDs or cookies you allow (See our Information We Collect Automatically; Device IDs, Cookies, and Other Tracking Technologies
above).
What Choices Do You Have Regarding Our Use of Your Personal Information?
We may send periodic promotional or informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the e-mail. Please note that it may take up some time for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you e-mails about your account or any Services you have requested or received from us.
If you want to request to review, delete, or change the information we have about you; request that we no longer make active use of your information; or if you have additional questions, please send an email to us at gokiludin2@gmail.com.comwith your request and identifying information in the body of the email, including your first name, last name, e-mail address or login name you use to access our Application and Services. We will respond to your email as soon as possible. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have previously allowed us to access your precise geolocation data or receive push notifications through your device, you can stop making precise geolocation available to us or receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself. In some instances you can also stop or limit the type of device IDs or cookies you allow (See our Information We Collect Automatically; Device IDs, Cookies, and Other Tracking Technologies
above).
European Data Protection Rights
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
You can request access to, and rectification or erasure of, personal data;
If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;
You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances; and
For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, contact us at gokiludin2@gmail.com. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
California Privacy Rights
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by contacting us at gokiludin2@gmail.com.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, you may email us at gokiludin2@gmail.com.
Right to Opt-Out. Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this privacy statement may be considered a “sale” under those definitions. In the past 2 months, we have sold cookie IDs, device IDs, and IP addresses. To opt-out from “sales” of personal information, please visit our “Do Not Sell My Personal Information” page. We do not knowingly sell the personal information of minors under 16 years of age.
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking for your name and your email address or the username associated with your account.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by e-mailing gokiludin2@gmail.com. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To request that we remove content or information you have publicly posted, email us at gokiludin2@gmail.com. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Security of Your Personal Information
We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, mobile device and computer by, among other things, signing off choosing a robust password that nobody else knows or can easily guess and keeping your password private. You should never share your password with anyone or use the same password with other sites or accounts.
Any email or other communication requesting your password or asking you to provide sensitive account information via email should be treated as unauthorized and suspicious and should be reported to us immediately through our contact page. If you do share your password or your mobile device with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately. If you believe that an unauthorized access has already occurred please report it immediately to us.
We may have access to your password and may use such password to access your account for debugging, quality assurance, or other internal purposes.
Governing Law
This Privacy Policy is governed by the laws of the State of California without giving effect to any principles of conflict of law. The exclusive jurisdiction and venue of any action with respect to the subject matter of this Privacy Policy will be the state and federal courts located in the San Francisco, California and each of the parties hereto waives any objection to jurisdiction and venue in such courts.
Effective Date; Policy Changes
Each time you use the Site, Applications or Services, the current version of the Privacy Policy will apply. Accordingly, when you use the Site, Applications or Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version. This Privacy Policy is subject to change from time to time. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.
Contact Us
To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of the Site, Applications or Services, or to contact our Data Protection Officer, please email us at gokiludin2@gmail.com.