, registered No: 3268529-4, address: Arabiankatu 4C 125, 00560 Helsinki, Finland (hereafter referred to as – "Mobisharks oy", "We", "Us", "Our"
) in order to describe how we may receive, collect, treat, process and use the information provided by you (hereafter referred to as – "You", "Your", "Yourself", "Users"
) regarding Your use of mobile application with the name Brain Game
that is owned by Us, and made available through the Google Play (hereafter referred to as – "Mobile Application"
), including any services, features, media and content that are connected with the Mobile Application (hereafter referred to as – "Services"
). The use of the Services is also regulated by Our Terms and Conditions (hereafter referred to as – "Terms"
In the ordinary course of the provision of Services by Us to You, We do not receive, collect and/or process information that is considered to be personal information.
We do not require any personal information from You in order to provide You with access to the Mobile Application and Services. Thus, Mobisharks oy is not a processor or controller within the meaning of the GDPR's definitions of "processor" and "controller," as We do not receive, process, or store the personal information of Users.
Personal information could include, but is not limited to:
- Your name;
- Your postal address;
- Your phone number;
- Your e-mail address;
- Your age;
- Your gender.
You agree that We could receive and collect the following categories of personal information in the ways described below, in order to use the Services:
- Your personal information, including any information required to use Services;
- cookies and another related type of technologies (e.g., log files, web beacons, eTags and script) (hereafter referred to as – "Cookies") to improve Your experience while using the Services. Cookies are small files that, when placed on Your device, allow Us to provide certain features and functionality. You may accept or decline all cookies by configuring the cookie retention mechanism on Your device. However, if You choose not to accept cookies, the Mobile Application may be unable to function properly;
- technical information about Your device, such as its IP address, whether it is connected to Wi-Fi or cellular data, the name of your Internet provider, the type of operating system on Your device, the device's battery status, the screen resolution on Your device, and the device's identifiers;
- a record of any correspondence between You and Us in the event that You contact Us;
- information that You provide in the event that You report a technical or other issue with the usage of the Services;
You agree that sometimes We could receive information from Third Parties, such as:
- Advertisers, regarding Your experiences or interactions with their offerings;
- Partners with whom We offer co-branded services or engage in joint marketing activities;
- Social networking sites ("SNS") (such as Facebook, Instagram and Twitter, etc.) and other similar Third Party's services that make Users' information available to others;
- Service providers that assist us in determining Your device's location based on its IP address in order to customize certain products to Your location.
You agree that We could receive the following information from Third Parties:
- Data for advertising and marketing purposes;
- Data to fight fraud (such as refund abuse or click fraud in advertising);
- Data we receive if You link a Third Party's tool in connection to use of the Services (such as Facebook, etc.);
- Order details (including services, date, quantity, status, description, and broad geographic area (e.g., state or city-level location));
- Analytics data, which We use to improve Our Services.
When You contact Our customer support team for help, We may collect and store the contact information You provide (typically, Your name and e-mail address), as well as information regarding Your use of the Services. Additionally, we shall retain any communication and any information included within.
When You buy Subscription using Our Mobile Application, We do not receive, collect, or use any payment information (Your name, payment card number, or payment account details). These are processed by Third Party payment processors, such as Google Play.3. How Your personal information may be used by Us
If We receive, collect and use Your personal information, We perform it in compliance with the provisions of applicable Data Protection Laws, in order to perform the following:
4. How long Your personal information may be kept by Us
- to provide You with the Services;
- to communicate with You, whether for customer service reasons or to inform You about Our Services;
- to allow You to communicate with Us;
- to manage Your account and to enhance Your use of Our Services;
- to develop and improve the Service and Your experience;
- to evaluate if Your device satisfies the minimal system requirements for usage of Our Services, as well as to provide information on compatibility and interoperability;
- to conduct research, surveys, and to communicate with You, for example through email or other forms of contact;
- in order to personalize Your Service experience;
- when it is necessary to do, as You have requested for sending You related information, security alerts, and support messages;
- to display customized adverts while using the Services and on Third Party websites and services (including email);
- to track the content that You access in connection with the Services and Your online behavior;
- to enable the delivery, targeting, and improvement of Our advertising and Services;
- to make available features that may be included in the Services;
- to make available to You Our offers via the Services and other websites and services;
- when it is necessary to analyze, profile, and segment data for the purposes of Our legitimate interests, except where such interests are superseded by the data subject's interests or fundamental rights and freedoms that require protection of personal information;
- when it is necessary to comply with a legal requirement to which Mobisharks oy is subject in order to maintain the Services and its features safe and fair, to fight fraud, prevent crime or cheating, and generally guarantee appropriate usage, take action against fraudulent or abusive Users.
Your personal information will also be deleted when You delete such information from Our services, although certain aggregated data derived from these may be maintained for restricted reasons according to relevant Data Protection Laws.
You agree that if You deactivate Your account or cease using Our Services, We may retain Your personal information as required to comply with Our legal requirements and obligations.5. How Your personal information may be shared by Us
You agree that We may share Your personal information with Third Parties for the following purposes:
- compliance with all applicable legal responsibilities and in accordance with Our reasonable interests, including, but not limited to:
- - protect and defend the Mobisharks oy's rights and property;
- - act in urgent circumstances to protect the safety of Users of Mobisharks oy Services;
- - adhere to a competent legal authority's order in any jurisdiction;
- - comply with the current legislation of any State.
You agree that We may share Your personal information with the following Third Parties:
6. Your rights This Section ("YOUR RIGHTS") applies to Users that are located in the European Economic Area (EEA) only.
- Advertisers. We may share Your personal information with companies such as Facebook, Twitter, and Google in order to support the targeting, distribution, and measurement of online advertising on Third Party services, or to facilitate the transmission of information that may be helpful, relevant, or of interest to You. Advertisers use Your personal information to improve advertising, targeting and measurement systems, which enables Us to provide You direct or targeted interest advertising based on Your interests. Additionally, the advertisers may use Third Party cookies and/or web beacons to collect a unique ID number in conjunction with information such as click stream data, browser type, time and date, and the topic of advertisements viewed or scrolled over during Your visits to other websites. Also, Our Services may include links to Third Party websites or services and Third Party plug-ins, such as the "share" button for Facebook, Twitter, and other social media platforms. This Privacy Statement is not applicable to any Third Party websites, services, or plug-ins;
- Partners in customer support. We may share Your personal information with Third Party customer and support partners with whom We cooperate in order to offer You relevant customer support services. These Third Parties may have access to Your personal information, which may include information You supply in response to customer service requests;
- Companies dedicated to anti-cheat and anti-fraud activities. We may share Your personal information with Third Parties for the sole purpose of detecting, investigating, and preventing fraud and cheat in the Mobile Application and Terms violations.
Under the GDPR, You have specific rights in regard to Your personal information that We may receive, collect, and process. Several of these are applicable only under particular conditions (as set out in more detail below). We shall reply to Your request to exercise such rights promptly and in any case within 30 (thirty) calendar days (though this may be extended by a further two months in certain circumstances). To exercise any of Your rights, please email Us at firstname.lastname@example.org.
- The right of access. You have the right to access, and receive a copy of, any personal information that We keep about You (subject to certain restrictions). In exceptional circumstances, We may charge a reasonable fee for providing such access but only where permitted by law.
- The right to rectification. You have the right to have Your personal information rectified if it is incorrect or outdated and/or completed if it is incomplete.
- The right to erasure/right to be forgotten. In some cases, You have the right to have Your personal information erased or deleted. Note this is not an absolute right, as We may have legal or legitimate grounds for keeping Your personal information. You may ask Us to correct information You think is inaccurate or completely delete all information that We hold about You.
- The right to object to direct marketing, including profiling, and any processing based on our legitimate interests. You can unsubscribe or opt-out of Our direct marketing communication at any time.
- The right to lodge a complaint with a supervisory authority. You have the right to contact the data protection authority of Your country in order to lodge a complaint against Our data protection and privacy practices. Do not hesitate to contact Us at the details below before lodging any complaint with the competent data protection authority as We will always seek to resolve your complaint in the first instance. It is Your right to lodge an objection to the use of Your personal information by emailing: email@example.com if You feel the "ground relating to Your particular situation" please apply.
You additionally have the following rights that are guaranteed to You under the California Consumer Privacy Act of 2018 ("CCPA"), If You are the resident of California State (USA):
- The right to request Mobisharks oy to disclose to You the categories of personal information that Mobisharks oy has collected from You and the purpose for which the categories of personal information shall be used; the source from which the personal information is collected. However, Mobisharks oy shall provide such information only upon Your request and not more than twice in a 12-month period.
- The right to request Mobisharks oy delete any personal information about You, which has been collected by Mobisharks oy from You.
- The right to request Mobisharks oy to disclose to You categories of Third Parties with whom We share Your personal information.
- The right to receive information on whether Your personal information has been sold by Mobisharks oy to a Third Party. This right provides that You have the right to request information on the categories of personal information that have been sold and the categories of Third Parties to whom Your personal information has been sold. However, Mobisharks oy does not sell any personal information to any Third Parties and has never tried to sell any personal information.
- The right to direct Mobisharks oy not to sell personal information to Third Parties, and to prohibit re-sale of personal information. However, Mobisharks oy does not sell any personal information to any Third Parties and has never tried to sell any personal information.
If you are a California resident seeking to exercise your rights under the CCPA or have any questions or concerns, please email Us at firstname.lastname@example.org.
You may request to know what personal information we collected, disclosed, used, and sold, as well as to request that We delete Your personal information at any time, for any of the personal information described above.
To exercise your right to know and right to deletion, please submit a request at: email@example.com with the subject line "California Rights Request". Until we may process Your request, we will need to verify Your identity. We will typically need that You provide Us with sufficient information that matches the information We have about you in Our systems, in order to verify Your identity. We may decline a request to exercise the right to know and right to deletion, particularly where We are unable to verify Your identity. After verifying Your request, We will delete (and direct Our service providers to delete) Your personal information from Our records, unless the information is required to complete the transaction with You, detect security incidents or fraud, correct errors, exercise free speech or another legal right, comply with legal obligations, or for other internal and lawful purposes.
In some cases, You are allowed to use an authorized agent to submit requests on Your behalf where:
- You submit sufficient evidence in writing to establish that the requestor is an authorized agent authorized to act on Your behalf; and
- You successfully verify Your own identity with Us.
We intend to respond to Your access or deletion requests within 45 (forty-five) calendar days after receipt. If We need further time, We shall notify you in writing of the cause and the duration of the extension.7. Collection information from children
We do not knowingly collect personal information from children under the age of 16. If We discover that We have collected personal information from a child under the age of 16, We will take measures to delete the information from Our systems.
You agree that We may keep information about Our Users on servers located in different countries.
Additionally, we may outsource the storage and share Your personal information to Third Parties based outside of Your home country.
For example, data collected inside the European Economic Area and Switzerland may be transmitted to and processed in countries outside the European Economic Area and Switzerland. 9. Links to sites of Third Parties
The Services may include links to other websites and services maintained and offered by Third Parties, including Third Parties You enter into a transaction with.
We have no control over the links to Third Party websites and disclaim all responsibility for their content, privacy policies, practices or services.
Sometimes, Mobisharks oy processes Your personal information when it is necessary for the performance of a Terms to which You are a party, such as to provide the Services to you.
Additionally, We may process Your personal information in order to reply to Your enquiries about Our goods and services.
In other circumstances, We process Your personal information in accordance with current laws and as required by applicable regulations.
Furthermore, if required, We may process Your personal information to defend Your or Our legitimate interests or the legitimate interests of a Third Party.
We process Your personal information when it is required to avoid fraud. Additionally, We may process Your personal information for the purpose of developing Our Services. If the processing of personal information is required and there is no other legal basis for it, We will generally ensure that consent has been obtained from You.
You are entitled to withdraw Your consent to the processing of personal information at any time. 11. Security Safeguards
Mobisharks oy takes reasonable steps to safeguard Your information against unauthorized access, loss, abuse, and modification by Third Parties. While We take reasonable steps to maintain information obtained via the Services in a secure operating environment that is not accessible to the public, We cannot guarantee the complete security of such information during transmission or storage on systems that We use. Furthermore, while We make reasonable efforts to maintain the integrity and security of network and systems that We use, We cannot guarantee that Our security measures will prevent Third Party "hackers" from acquiring unauthorized access to this information.
However, We will always retain Our commitment to protect Your privacy.
Arabiankatu 4C 125, 00560 Helsinki, Finland