Privacy Policy
April 2025 , effective date: April 18 , 2025 )
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (defined below) and how we will treat it.
This Privacy Policy applies to our games, applications, websites and related services (collectively, the "Services" or each category's "Games", "Applications", "Websites"). This Privacy Policy explains how we collect, use, protect and/or disclose personal information of end users ("you" or "your") when you use our Services or otherwise process your personal information.
1. Information We Collect and How We Collect It
When using our Services, we may ask you to provide 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 through third-party partners or services. The Personal Data we collect includes:
Basic identifiers and contact information
We collect certain information from you when you provide it to us directly, such as via email or online forms, through support features embedded in our Services, or through other forms of inquiry. This information may include your name, email address, and phone number. If you apply for a position on our Site, the information you submit may also include a cover letter and any details contained in your resume or curriculum vitae (CV).
Device Information
When you download and use our services, we automatically collect information such as 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.
Usage Information
We automatically collect information about your activities through our Services (Usage Information), such as the dates and times you use the Services, the features you use, your in-app purchase history, subscriptions, your interactions with advertising, and data generated when you use our Services (for example, your game progress may be stored in iCloud on iOS devices and in some of our Services through Facebook via your Apple ID).
Place
When you download and use our services, we automatically detect your approximate location, i.e., country and state, from your IP address. Where applicable, we may collect additional location information, such as your city, from your IP address with your consent.
Media and other files
If you want to use certain features of our Services, we may request access to your camera. If you contact us through the in-app support feature and need to upload any media or files as attachments, we will request access to such files.
Information We Obtain from Third Parties
Your information is obtained from third-party service providers who collect it through our Services in accordance with their own privacy policies. A list of third parties operating on our Services can be found in Appendix B.
Information we obtain when you communicate with third parties
If we provide the option and you decide to connect our Services with your third-party account, such as Apple, Facebook, or Google, we may receive certain publicly available information about you, as well as any information you allow or your settings allow access to, including your Apple ID, Facebook user ID, Android gamer name, name, and email (with your permission). If you want to manage your use of Sign in with Apple, visit Apple's website for more information. If you want to edit your privacy and settings on Facebook, visit Facebook's website for more information. If you want to manage your use of Sign in with Google Play Games, visit Google's website for more information.
Information we get from Facebook
If you use our Services on Facebook or connect our Services to a Facebook account, we may receive any information you provide or allow to be provided to us through Facebook. This information may include your user ID and your use of our games, including with whom you share our games on Facebook, and your email address if you choose to provide this information or want to contact us for support. The information we receive depends on the Services you use, Facebook's Terms of Service and Privacy Policy, your privacy settings, and, if applicable, the privacy settings of your friends. If you are unsure what information Facebook shares with us, please visit the Facebook website to learn more about Facebook's privacy practices.
The information we receive from Facebook and other third parties will be stored and used by us in accordance with this Privacy Policy.
User-Generated Content We Obtain from You
We may collect information from posts or uploads on social networks or platforms, or contact you directly, subject to your consent (where applicable). Such content may include your name, social media username, image, likeness, voice, and other identifiable information provided in such user-generated content.
Cookies and Similar Data Collection Technologies
We and our third-party ad networks and their partners may use cookies and similar technologies (such as mobile "SDKs") to provide and personalize our services and to serve targeted ads. Some of these technologies can synchronize behavior across different mobile apps, devices, and websites to tailor ads to your interests. This process is called personalized advertising. In addition, we and certain ad networks may access your installed app inventory to avoid serving ads for installed apps. If you would like to opt out of receiving such personalized ads on your mobile device, please see the "Opt Out of Targeted Advertising" section.
Please note that while your browser settings may allow you to send “do not track” signals when you visit the Services, our Services (including applications and websites) are not configured to respond to “do not track” signals received from browsers.
2. Purposes for which we use your personal information
The following describes how we use your personal information, the legal bases we rely on, and, where applicable, provides you with options to opt-out of certain practices. We may use your personal information:
To provide and maintain our services, recognize you when you return to our applications, sync your progress across devices when you log into your account with third parties and perform necessary business operations, our legal basis for processing is the performance of the contract entered into with us when you downloaded our services and accepted our End User License Agreement .
Allow you to use third-party social networks (such as Google Play Games, Apple Game Center or Facebook) to back up and sync your game progress to our Services. Some of our Services offer the option to sync and back up your game progress between different devices when you log in through a third-party social network. These services are not automatically activated but require your explicit authorization. Please note that the third-party social networks mentioned in this section are subject to their own privacy policies, terms and end-user agreements, and we are not responsible for and cannot control the sharing practices or policies of third parties operating these websites. In addition, when you disable the backup function, some information may remain on your device or third-party social network. To delete this residual data, please access the settings of your device or third-party social network.
To administer and protect our services (including troubleshooting, data analysis, testing, support, anti-fraud, reporting and data hosting). Our legal ground for this processing is our legitimate interests in operating our business and providing administration and services.
Communicate with you about any career needs, contact forms, help desk support and understand how you use our services so that we can continually improve our services. Our legal basis is performance of contract, legitimate interest or, as the case may be, your consent to keep our users updated on our services and new features in line with your preferences and to continually improve the services we offer.
To opt-out of communications with our Services, please send us your request through the online Contact Us Support feature.
Conduct analytics to gain insights into how users interact with our products and services. We use first-party and third-party analytics tools to understand how users interact with our games. This helps us understand how users navigate through our games, what features they use, what actions they take, how long they play, and how often they return. This helps us gain insights into which parts of our games are popular and which parts need improvement. It also helps us understand what attracts users and what keeps them engaged. With this information, we can provide users with a better experience (for example, improving the gameplay experience, changing annoying features, or troubleshooting bugs and issues).
To opt-out or withdraw consent to the processing of your information for analytics purposes, subject to your local privacy laws, please see the “Exercising Your Privacy Rights” section below.
Cross-promote our services and products and send push notifications about changes to our services so that you can use new features of our services if you choose to do so. Our legal basis is legitimate interest, namely being able to promote our services and products to our users and keeping users informed of our services and new features based on your preferences.
To opt out of receiving advertising for our services and products, please send us a request through the in-app support function, go to our app settings (in some apps you click on the three dots (or more) -) -> click Help (or Support) -> then click Contact Us (or +) and send us your request, or go to app settings -> About -> then Privacy preferences.
You can opt out of receiving push notifications by turning them off at the device level through your device settings.
Use third-party ad networks to serve personalized ads on our Services. Our legal basis is legitimate interests in operating our business. However, if you are located in the European Economic Area, United Kingdom (“UK”), Norway, Switzerland, or Brazil, some of our third-party ad networks rely on your consent to process personal data in order to serve you personalized ads, so we will ask you for your consent to collect your mobile device advertising identifier and IP address so that they can provide a personalized ad experience. Easybrain participates in and adheres to the policies and technical specifications of the IAB European Transparency and Consent Framework (IAB TCF).
To opt-out or withdraw consent to receive personalized ads, please see the “Opt-Out of Targeted Advertising” section below.
Use user-generated content you provide, which contains your personal data. Our legal basis is your consent obtained directly through the medium used to obtain such content (e.g. email, social network, social platform).
You may withdraw your consent by providing us with written notice by sending an email to support@easybrain.com .
To respond to legal proceedings and other obligations or requirements under applicable law.
3. Retention of Personal Data
We will retain your Personal Data only for as long as necessary for the purposes described 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 analytical purposes and legitimate business interests, to improve the functionality of our Services, for business purposes, or when we are legally obligated to retain it for longer periods of time.
Your personal information collected through our services will be retained for the period permitted by applicable law or as needed for the purpose of collection, and will be deleted or anonymized when it is no longer used for one of the above purposes and no longer constitutes personal information. It should be clarified that in any case, the retention period shall not exceed 5 years from the date of collection. Once we delete or anonymize your personal information, you will not be able to exercise the right to access, erasure, rectification or data portability.
4. Purposes for which we share your personal information
We may share the categories of personal data listed above for certain business purposes, including:
Storage Our users'
personal data is stored in the data centers of our third-party service providers located in Canada and Germany, who act as data processors.
With our service providers and partners
We use certain service providers and partners to help us operate and improve our Services. These service providers and partners assist us with a variety of tasks, including hosting and maintenance, ongoing development, analytics, customer service, and marketing.
In addition to the above, we may also share your personal information in the following circumstances or for the following purposes:
For corporate transactions
We may transfer your information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, in whole or in part.
When required by law
We may also share information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property or safety of our business, our customers, or others.
Exercising legal rights
We may also share information: (i) if disclosure may mitigate our liability in actual or threatened litigation; (ii) when necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; or (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will clearly state the reasons for sharing the information.
Cross-border data transfer
Information sharing sometimes involves cross-border data transfers, including transfers outside the European Economic Area where required by law. We only transfer personal data to third country entities that have implemented appropriate safeguards to ensure a level of data protection consistent with this Privacy Policy and applicable laws, and in accordance with standard contractual clauses deemed adequate by the European Commission for the protection of personal data.
Social sharing function
Some of our Services offer social sharing features that allow you to share your actions on our Services with other media. You must be at least the minimum age required by law in each jurisdiction to use any social sharing features integrated into our Services. Using such features, you may share information with your friends or with the public, depending on the settings established between you and the entity providing the social sharing feature. Our Services include social features from the following providers: Facebook - https://www.facebook.com/about/privacy/
Instagram - https://help.instagram.com/519522125107875?helpref=page_content
5. Age Limit
We understand the need to provide additional privacy protections for child users. Our Services are intended for a general audience over the age of 16, so children under the age of 16 (or over the age of 16 as required by applicable jurisdictions) should not download or use our Services. We do not knowingly collect personal information from children. If you believe that we might have collected personal information from a device under the age of 16 (or otherwise as applicable), or for any other relevant reason, please send us a request to delete and restrict the processing of your personal data and opt out of targeted advertising using the in-app privacy settings (for our apps, go to Apps -> Settings -> Privacy Preferences).
6. Links to other websites
Our Privacy Policy may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party 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.
7. Your Rights and Choices
Under the General Data Protection Regulation (GDPR), you have certain rights in relation to your personal data. These rights include:
Right of access: You have the right to request access to the personal data we hold about you.
Right to rectification: You have the right to ask us to correct any inaccuracies in your personal data.
Right to erasure: You have the right to ask us to erase your personal data in certain circumstances.
Right to restrict processing: The right to ask us to restrict processing of your personal data in certain circumstances, for example if you contest the accuracy of the data
Right to data portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit that data to another data controller.
Right to object: You have the right to object to the processing of your Personal Data in certain circumstances, including where we are processing your Personal Data for direct marketing purposes or to object to our continued processing of your Personal Data in certain other circumstances, such as where processing is carried out for our legitimate interests.
The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you
In addition to the rights listed above, if we process your personal data based on your consent, you can choose to withdraw your consent at any time.
"Exercising Your Privacy Rights" section and follow the necessary steps. Please note that exercising certain rights may affect our ability to provide you with our services. We will inform you of any such impact when you make a request to exercise your rights.
8. Supplemental Privacy Notice and Rights of U.S. Residents
We are committed to protecting your privacy and ensuring that your personal information is handled in compliance with applicable U.S. privacy laws, including the California Consumer Privacy Act, Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, and Utah Consumer Privacy Act (“U.S. Privacy Laws”). For more information on specific states, please visit the relevant section below.
the "Exercising Your Privacy Rights" section below and take the necessary steps.
We strive to respond to your access or deletion request within 45 days of receiving it. If we need more time, we will inform you of the reason and the extension period in writing. If we cannot meet your request, we will respond to you and explain why we refused to act. If you wish to appeal this decision, you can contact us as provided in the "Contact Us" section below.
California
This California Supplemental Privacy Notice applies only to our processing of personal information pursuant 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 additional rights listed here. To exercise those rights, please see the “Exercising Your Privacy Rights” section below.
The right to know what personal information is collected (right of access)
You have the right to know and review the information we have collected about you in the past 12 months, including:
For more information about the specific information we collect, please visit the “Information We Collect and How We Collect It” section above.
Right to erasure
You have the right to request that we delete your information that we have collected (and to instruct our service providers and third parties to whom your information has been “sold” or “shared”) to do the same, unless this proves impossible or requires disproportionate effort. However, there are some exceptions, including but not limited to where we or a third party needs the information to do any of the following:
Right to Opt-Out
You have the right to "opt out" and instruct us to stop "selling" or otherwise sharing your information with third parties for monetary or other valuable consideration. To submit an opt-out request, please follow the instructions in the "Opt-out of Targeted Advertising" paragraph below, or configure the privacy settings in any of our applications, or check your device privacy settings.
Other Rights
You can request certain information, such as the information we disclosed about you to third parties for their direct marketing purposes in the preceding calendar year (provided we have shared the information for such purposes within the required period). This request is free and can be made once a year. In certain circumstances, you also have the right to have inaccurate personal information we hold about you corrected. You also have the right not to be discriminated against for exercising any of the rights listed above.
Colorado, Connecticut, Virginia, Utah, Oregon, and Texas
This Supplemental Privacy Notice applies only to our processing of personal information that is subject to the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), and the Texas Data Privacy and Security Act (“TDPCA”). These state laws provide residents of their respective states with specific rights as listed below. To exercise these rights, please see the “Exercising Your Privacy Rights” section below.
Right of access
You have the right to ask us for confirmation as to whether we are processing their personal data and to obtain a copy of the personal data you have previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Right to rectification
Depending on the region you are in, you have the right to request that we rectify inaccuracies in your personal data, depending on the nature of the personal data and the purposes for which we process your personal data.
Right to erasure
You have the right to request that we delete the information we have collected from you.
Right to object/opt-out
You have the right to “opt out” of targeted advertising, the sale of your personal data, or, depending on your state/province, profiling for legal or similar significant decision-making. To submit an opt-out request, please follow the instructions in the “Opt-out of targeted advertising” paragraph above, configure the privacy settings in any of our apps, or check your device privacy settings.
Non-discrimination
In some states, residents have the right not to receive discriminatory treatment from us for exercising rights afforded by U.S. state law.
9. Exercising your privacy rights
To exercise your rights, please visit the "Privacy" tab in any of our apps by navigating to your app's homepage, clicking the gear icon (three or more dots), and selecting "Privacy" to select the specific right you wish to exercise. Alternatively, you can contact us through the support feature in our apps: go to your app's homepage, click the gear icon, select Help or Support, and then click the "Start a Chat" button to initiate a conversation.
In addition, you can choose to contact us by email at: privacy@easybrain.com. However, please note that we may redirect you to use an in-app support feature that more easily identifies you, or ask you to provide more information to facilitate your request. All requests are free of charge and will be processed promptly, usually within one month. You may also contact your local data protection authority or relevant national authority within the European Economic Area or the UK for unresolved complaints.
Opting Out of Targeted Advertising
You can opt out of personalized advertising experiences at any time by checking the Privacy Settings tab in any of our apps or the privacy settings on your iOS or Android device.
Method 1 (depending on your local privacy laws) - App settings:
Method 2 - Device Setup:
For iOS 13 and earlier:
For Android:
When you opt-out, ad networks will treat this choice as a withdrawal of consent for a personalized ad experience, and they will display contextual ads instead of ads personalized based on your interests.
NOTE: Regardless of your selections and/or device settings, you will still see non-customized ads (such as “contextual” ads) and you may continue to receive personalized ads from our third-party ad networks for which you have consented on other apps and/or websites.
Opt out of analytics (depending on your local privacy laws)
For analytics in our applications, we use first-party and third-party analytics tools to gain insights into how users interact with our products and services. To do this, we use personal and non-personal information, such as device identifiers, device data, and/or other tracking technologies, to enable and optimize this process.
For third-party analytics, in countries where applicable laws and regulations require us to do so, your consent is the legal basis for the processing.
On the other hand, we collect user data for our own internal analytics tools based on our legitimate interest in creating better games and providing a more enjoyable experience for our users. The collected data is only used for our own analytics tools and is not shared with any third parties.
You can withdraw your consent or object to processing for profiling purposes based on legitimate interests at any time by checking the "Privacy Settings" tab in any of our applications.
Method (depending on your local privacy laws) - Application Settings:
10. Changes to this Privacy Policy
This Privacy Policy may change from time to time, and we recommend that you review it regularly. Your continued use of our Services constitutes your acceptance of the changes to this Privacy Policy.
In some cases, we may inform you of changes to this Privacy Policy through a prominent notice on our Services (for example, through a notification or pop-up window) before the changes take effect 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 at: lvzhiming1122@163.com