privacy

PRIVACY POLICY

(last updated 15 May 2017)

Definitions used in this privacy policy:

1. Apps – means Our mobile applications and any services provided through the Apps, it is a part of the Services which We provide to You. 
2. Company (“SPEGAME”, “We”, “Us”, “Our”) – means Easybrain Ltd, the company registered in Cyprus, registration number HE 345807, having registered office at Christaki Kranou 33, 2nd floor,4041, Germasogeia, Limassol, Cyprus.
3. Device – means an authorized smartphone or a tablet or other mobile device, which You own or otherwise legally control solely for your lawful, personal, and non-commercial use.
4. EEA – means the European Economic Area.
5. EULA – means the End User License Agreement, which is the legal agreement between You and Us, and together with all the related documentation it sets forth the terms and conditions governing the use of any of Our Apps downloaded by You or other related Services.
6. Policy – means this privacy policy, which describes how We collect, use, process, store and share information that We collect about You.
7. Services – means Apps, Our products, services and websites, which You download, install, use and/or visit.
8. USA – means the United States of America.
9. You – means the person, who uses Our Services under the EULA and whose data is collected, stored, processed, used and shared according to this Policy.
10. Your information – means Your personal data and other related information further described in more detailed way under the section „What We Collect and How” below.

1. We are the developers of the Services, which You are about to download, install and/or use. We, including our affiliates collect, store, process and use Your personal information as a data controller in connection with and in order to provide and develop the Services according to this Policy.
2. Protecting Our customers' privacy is an important priority at the Company and We are committed to maintaining strong and meaningful privacy provisions. The privacy and security of Your information is a significant responsibility and We value the trust You place in Us.
3. By downloading, installing and/or using the Services, You consent that Your information is processed in accordance with this Policy. Please do not download, install or use the Services, if You do not agree with this Policy. You shall always retain the right to object the processing of Your information upon contacting Us, however, please note that this may impair the quality of the Services and in some cases makes it impossible.
4. The Policy is subject to change from time to time. We appreciate that Your information and the ways it is handled is of the utmost importance, therefore We will promptly notify You of any material amendments by an in-app message and/or by e-mail. If You continue using the Services after such changes to the Policy are made, this shall mean the acceptance of the Policy amendments. If You do not agree with any amendment to this Policy, You shall discontinue using the Apps or any related Services and shall uninstall and remove the Apps from Your Device. In order to uninstall and remove the Apps, please use the application manager provided with Your Device or consult Your Device manual for reference.
5. The provisions of this Policy are governed by the laws of the Republic of Cyprus.

WHAT WE COLLECT AND HOW

7. We may collect data from Your Device and the Apps, including the information, which directly or indirectly identifies You. Your information may be kept in an identifiable format, or in an aggregate format, which means that You cannot reasonably be identified from it.
8. We may collect the information about You when You use the Services and the specific features thereof, including the following: (a) Information about Your name, email address and other similar contact data when You interact with Us such as when You report a problem, contact or communicate with Us and share this information; (b) We may collect certain device data and electronic identifiers such as Your mobile operating system details (version), model and type of Your Device (phone/tablet); (c) advertiser IDs (IDFAs in case of an Apple device or Android Ad IDs in case of an Android device); (d) other identifiers may include IP addresses, Android ID for Android platform; (e) in case the authorization to Our services is made via Facebook, We may collect Your Facebook username, Facebook ID, location, time zone, birthday day, email address, first name, last name, full name, gender, list of Facebook friends, date of registration at Facebook;
9. When You will be using the Apps, We will collect certain information automatically. This will include certain technical data about Your Device, carrier as well as other technical data related to the use of Your Device.
10. The ways how We receive Your information include, but are not limited to: (i) by using Our Services or visiting Our websites, (ii) registration for Services, contests and special events; (iii) accessing Services using a third party ID, such as social networking sites or gaming services; (iv) subscribing to newsletters; (v) purchasing a product or services within the Apps; (vii) requesting technical support; and (viii) otherwise through use of Our Services where personal data is required for use and/or participation.
11. You may provide some of Your information directly, some of it depending on how You interact with the Apps, receiving performance reports or usage data from the Apps running on Your Device.

Cookies

12. When You use and access the Service, Our website may send cookie files to Your web browser. Cookies are small pieces of text, stored in Your web browser and allowing the Service or a third-party to recognize You and make Your next visit easier and the Service more useful to You. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on Your Device when You go offline, while session cookies are deleted as soon as You close Your web browser.
13. We use both session and persistent cookies on the Service and We use different types of cookies to run the Service: (a) Essential cookies. We may use essential cookies to authenticate users prevent fraudulent use of user accounts, and (b) Analytics cookies. We may use analytics cookies to track information how the Service is used so that We can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how Our users react to them.
14. In addition to Our own cookies, We may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
15. If You'd like to delete cookies or instruct Your web browser to delete or refuse cookies, please visit the help pages of Your web browser. Please note, however, that if You delete cookies or refuse to accept them, You might not be able to use all of the features We offer, You may not be able to store Your preferences, and some of Our pages might not display properly.

PURPOSES AND WAYS OF USING YOUR INFORMATION

16. We collect Your information to operate the Services effectively and provide You with the best customer experience. We use Your information to provide and improve the Services; perform essential business operations; advertising of our Services and products, including third party products; enforce Our terms, conditions and policies and personalize Your experience. This includes operating the Services, maintaining and improving the performance of the Services, including developing new features, optimal functionality and operation of the Services, research, providing customer support, performing research and analysis about Your use of, or interest in, Our/third parties products, services, or content, communicating with You by e-mail, postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to You either from Us or third parties. We may also use Your information to develop and display content and advertising tailored to Your interests and/or location and to measure its effectiveness. If You do not wish to receive in-app advertising, in some cases You can upgrade to the paid version of the App.

Analytics

17. We use Your information to perform Our own analytics and to enable analytics provided by third parties. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations.

Advertising

18. We may use Your information in connection with advertising. We may also use Your information to help a third party deliver advertisements that are tailored to You based on a determination of Your characteristics or interests. Advertisers on mobile devices sometimes use advertising (or ad) identifiers to enable and optimize their advertising. Ad identifiers are non-permanent, non-personal device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). You can choose to prevent Your Device's ad identifier being used for interest based advertising, or You can reset Your Device's ad identifier, by changing the settings of Your Device.
19. We will also use the information about Your particular Device in order to show You advertising which work properly on that Device, or to measure the effectiveness of Our advertising campaigns. We may also retain information about how many times You have seen a particular advertisement so We can stop You from seeing it too many times.
20. When We advertise our Services in mobile applications or media published by other companies, We may use various third party advertising partners, including ad exchanges, ad networks and ad servers.
21. We and third parties who advertise on our Services may use cookies or similar technologies such as tracking pixels in their advertising. These technologies operate either by: (i) placing a small file, which stores some information on Your Device; and/or (ii) by accessing information on Your Device. These technologies allow the collection of data, such as Your Device's model, operating system and screen size, the other applications installed on Your Device, and information about how You use our Services
22. We may also allow third parties to display advertisements in the Apps or other apps or use Your information for the purpose of advertising and direct marketing. These third parties may use technologies to collect data about users, including location data, to help them produce relevant ads and content, analyze and measure effectiveness of the adds.

Customer support

24. We use Your information, including data that you provide directly to Us in communications, to provide You with support through Our customer service channels when You need it. We may also use it to contact You, for example as part of customer service or to send You updates about Our Services. Finally, We will use Your data to manage Your account and relationship with Us and improving Your experience when you use Our Services.

Other

25. We may use and combine Your information across different Apps used by You. Please note, that We may use the elements of Your information and combine it with other information which We legally possess.
26. When We collect Your geolocation data (subject to Your consent) via the device's cellular, Wi-Fi, GPS or Bluetooth connection, We do so to provide You with Our location related products and services.
27. When You share Your information with Us via a social network provider like Facebook, We use this to show information on Your social network profile (subject to Your privacy setting and preferences for such social network) and to allow You to share information about Our Services with Your connections or on Your social network profile.

DISCLOSURE, TRANSFER AND SHARING OF YOUR INFORMATION

28. Your information may be disclosed, transferred to or shared with third parties including those located outside the European Union or the EEA countries in accordance with requirements set by the applicable legislation and this Policy. We may use third parties to collect and process Your information on Our behalf and according to Our instructions. We are not liable for the acts and omissions of these third parties, except as provided by the applicable law.
29. We use other companies and individuals to perform certain functions on Our behalf. Examples include providing customer service and marketing assistance, performing business and sales analysis, supporting our Apps functionality, and supporting marketing promotions, surveys and other features offered through Our Apps, analyzing data, providing marketing assistance, providing search results and providing customer service. They have access to personal information We legally possess, including Your information, needed to perform their functions, but may not use it for other purposes.
30. We sometimes cooperate and use third parties, such as advertising networks, for the purposes of developing and displaying the content, advertising and offers specifically tailored to Your interests and location. We may share Your information with these third parties by inclusion into Our Apps a bit of a special computer code, enabling them to have a limited access and collect the part of Your information needed to perform their functions. They use Your information in accordance with their privacy policies, but in any case they are not permitted to share or otherwise use Your information for any other purposes than those indicated in this Policy.
31. We may disclose Your information (a) under a court order, or a request from a law enforcement or other government agency; (b) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (c) to protect and defend the rights, property or safety of Our Company, Our users, Our employees; (d) to comply with applicable law or cooperate with law enforcement; (e) to enforce Our Apps EULA or other agreements or policies; and (f) in connection with a substantial corporate transaction, such as the sale of Our business or the Apps.
32. In addition, We may share aggregated information, including Your information, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note, that such aggregated information will not include any information, which allows third parties to identity You.
33. We may need to transfer Your information to other group companies or service providers in countries outside EEA. This may happen if Our servers or suppliers and service providers are based outside the EEA, or if You use our services and products while visiting countries outside this area.
34. We may also share Your information with partner organizations We’ve chosen carefully, so they can contact You about their products and services.
35. The information that We collect from You may be transferred to, and stored at, a destination outside of Your country and the EEA and, in particular, the USA, which may have different or less protective privacy laws than those in Your country. Your Information may also be processed by any service providers appointed by Us who operate outside the EEA and their staff, and/or Our own staff based outside of the EEA. By submitting or permitting Us to collect Your information, You agree to this transfer, storing or processing outside of the EEA. Your information transferred will be treated in accordance with the requirements of applicable laws and this Policy.

PROTECTION AND RETENTION OF YOUR INFORMATION

37. We maintain technical, administrative and physical safeguards in place to help protect against unauthorized access to, use or disclosure of Your information We collect or store. Under Our practices and policies, access to sensitive personally identifiable information is authorized only for those who have a business need for such access.
38. Although We work hard to protect Your information that We collect and store, no program is 100% secure and We cannot guarantee that Our safeguards will prevent each and every possible unauthorized attempt to access, use or disclose Your information. We maintain security and incident response plans to handle incidents involving unauthorized access to Your information We collect or store.
39. Personally identifiable and other sensitive records are retained only as long as reasonably necessary for business, accounting, tax or legal purposes, it is promptly deleted thereafter. Please note, that We do not verify the correctness of Your information.
40. Your Information collected by Us under this Policy will be retained as long as You use the Apps, as well as for any further period of time that is needed for us to duly perform all Our obligations under EULA, this Policy and to comply with all the mandatory provisions of applicable laws. After you stop using the Apps, we may retain certain information (mostly as a part of a generalized statistical data) that would be used by Us for certain limited business operational and analytical purposes with the view to improving Our Services.

CHILDREN

41. We appreciate the need to provide extra privacy protections to users who are children. We do not knowingly collect personal information from children under 13 years of age. If We find out the We have inadvertently gathered personal data from children under 13 years of age, We will take reasonable measures to promptly delete such personal data from Our records.

MODIFICATION AND DELETION OF YOUR INFORMATION

CONTACTS

43. Should you have any questions regarding this Policy, or any other queries, please, contact Us by email as follows: xubaozhongdashabi001@gmail.com