Privacy & Data Policy

1. Introduction and General Terms

These terms apply to the use of games and other products developed by BRAVEBITS PTE. LTD. (“TS” / “we” / “us”). Our registered office is at 7030 Ang Mo Kio Avenue 5, #09-46 Northstar @ AMK, Singapore (569880).

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games including our website (the “Website”). Together the Game(s) and Website are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at [email protected].

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes.

2. Information We May Collect About You

a) Information provided by you when using the Games (“Basic Information”)

• Your mobile device’s unique device ID (Device ID);
• Your user preferences; and
• Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores, or the completion of certain activities during your gameplay.

b) Information used for serving advertisements (“Advertising Data”)

Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, including: the make, model and operating system of your device; device properties such as screen size, orientation, audio volume and battery; the mobile network operator; the Games played; country, time zone and locale settings; network connection type and speed; IP address; MAC address; the internet browser used; and the advertiser ID (an identifier unique to you that does not reveal your name).

c) Information collected for analytics (“Analytics”)

We may collect technical information about your use of the Online Services through tracking technologies and analytics, including: your Device ID; your user ID; your device operating system and version; device make and model; gameplay attempts, progression and results; session start, end and duration; purchase transaction types and spend; country of your device; the time, date and install source of your first download; advertisements viewed and clicked; and identification of crashes and defects.

d) Information collected from third parties (“Third Party Log In Information”)

When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information available on that provider, such as your name, profile picture, ID and other public data, provided you have expressly agreed to such use within the Games.

3. Why We Collect Information About You

a) To provide our Games to you — to record your progress and current status within a Game and to ensure the Games function properly.

b) To help us improve the Online Services and fix problems — to analyse and improve our Games, identify and correct bugs, and understand the effectiveness of our marketing at an aggregated level.

d) To acquire new users and engage current users — to encourage engagement and notify users about new virtual items or promotions, and to acquire new users including via ‘lookalike’ audiences that do not personally identify you.

e) To improve monetisation via in-app purchases — to understand how users use our Games and compile statistical reports, which may include dynamic pricing models offering temporary promotional discounts.

f) For advertising purposes — to show advertisements for third party services and to understand advertising performance. We will not pass or process your information for third party marketing unless you give consent, which you may withdraw at any time. We work with third party advertising networks including Chartboost, AdColony, Facebook, Unity and Google.

g) To prevent fraud and illegal activity — to ensure lawful, non-fraudulent use of the Online Services, enforce our legal rights and comply with our legal obligations. We work with Apple and Google to assist with fraud prevention and the detection of illegal activity.

4. Data Sharing

We will share your information with third parties only in the ways described in this Privacy Policy: with group members, personnel, suppliers or subcontractors (who do not make independent use of the information); in the event of a merger or acquisition; where required by law; for enforcement of our agreements; and with digital content stores (Google Play, iTunes, Amazon Appstore) to facilitate in-Game payments.

5. Automated Decision Making

We may use automated decision making methods to identify users suspected of cheating, by looking for excessive currency stores or content against actual completed gameplay and purchases. Affected users may experience an increase in the number of advertisements displayed and may be blocked. Blocked users will be notified and have the right to obtain human intervention, express their point of view, and contest the decision.

6. Consumer Control and Opt-Out Options

If you do not wish to be part of a lookalike campaign, receive notifications, or be served targeted advertisements, you can opt out by changing the advertising and notification settings on your device at any time.

7. Your Rights

You have the right to: (a) ask for a copy of the data we process about you and have inaccuracies corrected; (b) object to us processing data about you and ask us to restrict, stop processing, or delete your personal data; (c) obtain a machine-readable copy of your personal data to use with another service provider; and (d) make a complaint to a Supervisory Authority. To make a request, please email [email protected]. We aim to comply without undue delay, and within one month at the latest.

8. Data Retention

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

9. Children

We do not knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users under 13 from accessing our Online Services. If we learn we have collected personal information from a child under 13, we will delete it as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

10. Security

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Our databases are password protected and limited to essential employees only. Please be aware that, although we endeavour to provide reasonable security, no security system can prevent all potential security breaches.