PRIVACY POLICY

Last updated: 20 January 2025

This Privacy Policy describes the collection and processing of information about you that can directly or indirectly identify you, carried out by the mobile game “Incredible Jack” (the “App”) offered by BrainMount Ltd (“we”, “us”, “our”).

Contact details of the data controller:

Name: BrainMount Ltd
Address: Vasili Michailidi 9, 3026, Limassol, Cyprus
E-mail: [email protected]

Please read this Privacy Policy carefully, as it contains essential information about the following:

Personal data collection process
Details of processing
Data retention period
Automated decision-making or automated profiling
Sharing of your personal data with third parties
Data transfer
Your rights
Age limits
Other links

We may update this Privacy Policy from time to time. For the continued processing of your personal data, we will request your consent or renew it if it was previously obtained.

Personal data collection process

We collect and otherwise process your personal data in the following ways:

From you. For example, we may process your personal data when you email us.
From third parties. In some cases, we may receive personal data about you from third parties, such as analytics tools connected to the App or when you make purchases through third-party services.
Through automatic collection. Our App may connect with tools that automatically collect personal data, for example, to ensure the App works correctly.

Details of processing

We respect your privacy, and it is important to us that you understand how we handle your personal data when it comes into our possession. Below, we describe how personal data is used throughout your use of the App, including any relevant third-party involvement.

Incredible Jack

Processed personal data	Legal basis for the processing	Data retention period
Maintaining the correct operation of the App, tracking technical issues, and troubleshooting problems within the App
Device model, device OS, device OS version, device language, device time zone, country set in device settings, device screen resolution (the “Device Data”) App version Data contained in a receipt, such as payment status, date and time of purchase, list of subscriptions or paid functionality purchased, etc. (the “Payment Status Data”) (if you buy paid functionality)	Legitimate interest: Your interest is in using the App without technical problems. Our interest is in ensuring your satisfaction and providing a bug-free App.	3 years after the last interaction with the App or the last payment, whichever occurs later.
Tracking and analysing trends, usage, and actions related to the App to better understand its use and improve it
Device Data IP address and internet service provider, mobile carrier Identifiers (such as IDFA, IDFV, GAID, AppsFlyer ID, Google Firebase ID) Usage data, such as App version, install time, launch time, user agent, interactions with the App, actions within the App, features used, access times, and other data about your interaction (the “Usage Data”) Approximate geolocation information derived from an IP address (country and city) Payment Status Data (if you buy paid functionality) Information about the advertising campaign	Legitimate interest: Your interest is to have the App fit your preferences. Our interest is to improve our App and make it more user-friendly.	3 years after the last interaction with the App or the last payment, whichever occurs later.
Providing access to the App functionality
Device Data App version Payment Status Data (if you buy paid functionality)	Terms and Conditions and End User Licence Agreement	3 years after the last interaction with the App or the last payment, whichever occurs later.
Providing you with an answer to your question (technical support, exercising data privacy rights, or other assistance in connection with the App)
E-mail Other data you have provided in correspondence	Legitimate interest: Our interest in improving the quality of the App. Your interest in receiving an answer to your question or a solution to a problem.	3 months after the last communication with you.
Advertising our apps to attract new users
Identifiers (such as IDFA, IDFV, GAID, AppsFlyer ID, Google Firebase user_pseudo_id) Limited data about your interactions within the App Information about the advertising campaign	Consent	3 years after the last interaction with the App or the last payment, whichever occurs later.
Providing you with ads, including personalised ads, via third-party advertising platforms
Identifiers (such as IDFA, IDFV, GAID, AppsFlyer ID, Google Firebase ID) Approximate geolocation information derived from an IP address (country and city) Device Data Usage Data Other data that may be collected by third-party advertising networks	Consent (in case of personalised ads) OR Legitimate interest (for ads that are not based on your interests): Our interest in monetizing the App. Your interest in using the App for free.	3 years after the last interaction with the App or the last payment, whichever occurs later.

Data retention period

We understand the importance of keeping your personal data safe and retaining it only for as long as necessary. We have detailed how long we will keep your personal data for a specific purpose in the “Details of Processing” section.

Please note that there may be occasions when we are required to retain your personal data for longer than initially stated. This may include, but is not limited to, situations involving legal proceedings, investigations, or government inquiries. We will retain your personal data only for as long as necessary to comply with these legal obligations, and we will take appropriate measures to ensure its security and confidentiality during this period.

We regularly review our data retention practices to ensure that we keep only the personal data we need and that it is kept securely.

Automated decision-making or automated profiling

We neither use automated decision-making nor rely on automated profiling.

Sharing of your personal data with third parties

We value your privacy and care about the security of your data. Sometimes, we need to share some information with other companies. Here’s why:

Compliance with applicable law.

We make every effort to comply with all applicable laws, regulations, and legal obligations. In certain instances, we may need to disclose your personal data to comply with legal requirements, such as responding to subpoenas, court orders, or other lawful government requests. In addition, we may disclose your personal data if we believe in good faith that such disclosure is necessary to protect our rights, enforce our Terms and Conditions and End User Licence Agreements, investigate fraud, or protect your safety.

Achieving purposes of processing.

We also partner with certain trusted companies to provide you with the best experience using our App. These partners may include hosting service providers, payment processors, analytics platforms, and others. We share only the necessary information with them to help them perform their functions, such as processing payments or analyzing the use of our App. We choose our partners carefully and require them to adhere to high standards of data protection.

We always strive to be as open and transparent as possible regarding the processing of your personal data. If you have any questions or concerns about the transfer of your personal data to third parties, please do not hesitate to contact us for more information.

We may involve the following third parties in the processing of personal data:

Third parties that collect and process data for analytical purposes.

We strive to improve our App to make your user experience more convenient and to ensure our App remains interesting to you. To do this, we invest in analyzing which App features are useful and which need improvement. We engage analytics services that help us collect, analyze, and interpret personal data to optimize performance and identify opportunities for growth.

The list of the analytical services that we use in the App:

Google Analytics – a web analytics service provided by Google Inc.
AppsFlyer – a SaaS mobile marketing analytics and attribution platform provided by AppsFlyer Ltd.

Third parties that collect and process data for marketing purposes.

We work with advertising networks to attract new users. Additionally, we may display ads (including personalised ones) in our App. These networks may collect certain personal data about how you interact with our App or other websites and apps, using this data to deliver ads based on your preferences and interests.

Below is a list of the advertising networks we use in our App:

Meta Ads – an advertising service provided by Meta Platforms, Inc.
Google Ads – an advertising service provided by Google Inc.
Apple Search Ads – a service that allows developers to promote their apps within the App Store search results, provided by Apple, Inc.

In addition, the following advertising networks may also be connected specifically to Incredible Jack:

Unity Technologies – an advertising network provided by Unity Technologies SF (USA).
IronSource – an advertising service provided by ironSource Mobile Ltd (Israel).
AppLovin – an advertising service provided by AppLovin Corporation (USA).
Vungle – an advertising service provided by Liftoff Mobile, Inc. (USA).
Pangle – an advertising service provided by Bytedance Pte. Ltd (Singapore).
DT Exchange – an advertising service provided by Digital Turbine, Inc. (USA).
InMobi – an advertising service provided by InMobi Pte Ltd (Singapore).

Third parties that provide us with storage servers.

We rely on trustworthy hosting providers to ensure the secure storage and processing of your personal data. These providers guarantee the availability and reliability of our App’s infrastructure, including servers, databases, and storage systems. Please note that the companies hosting our servers do not have access to your personal data.

The datacenter we use for storing your personal data is located in the EU.

Additionally, in some cases, we may use services that facilitate the secure transfer of personal data from us to other companies, as well as services that prevent unauthorized data transfer and ensure the smooth operation of our App.

Third parties that help us provide the functionality of the App.

In some cases, we use integrations of other services to improve the efficiency, speed, and quality of the functionality provided in the App. Specific companies and certain processing details can be found in the “Details of processing” section above.

Data transfer

Please note that some of these companies may be located outside the EU (international data transfers), including in countries that do not ensure an adequate level of protection for your personal data.

Such transfers are performed in compliance with the GDPR, using Standard Contractual Clauses to ensure that your data receives an adequate level of protection.

We ensure that such transfers comply with legal requirements by using Standard Contractual Clauses approved by the European Commission. These clauses require data recipients to protect data they process from the EEA in accordance with EU data protection law. Our procedures regarding data transfers are regularly reviewed to ensure compliance.

Your rights

As a data subject, you have certain rights regarding your personal information. We are committed to upholding these rights and ensuring that you can exercise them effectively.

Below, you will find the information regarding your rights as a data subject under EU legislation:

Right of access	This right allows you to request access to the personal data we hold about you.
Upon receiving your request, we will provide you with a copy of the personal data we process in the form you have requested. Please note that in some cases, we may charge you a reasonable fee for providing this information. If we are unable to fulfill your request for any reason, we will provide you with an explanation and inform you of your rights to appeal.
Right to rectification	This right enables you to request the correction or updating of any inaccurate or incomplete personal data we hold about you.
Upon receiving your request for rectification, we will review the accuracy and completeness of your personal data and make any necessary corrections or updates.
Right to erasure	This right allows you to request the deletion or destruction of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or processed.
Upon receiving your request for erasure, we will assess whether the conditions for erasure are met and, if so, promptly delete or anonymize your personal data from our systems and notify any third parties to whom the data has been disclosed.
Right to restrict processing	This right allows you to request the restriction of processing of your personal data in certain circumstances, such as when the processing is unlawful, when we no longer need the personal data, or when you have objected to the processing.
Upon receiving your request to restrict processing, we will not process your personal data (except for storage) unless it is based on consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest.
Right to data portability	This right allows you to receive a copy of your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
Upon receiving your request for data portability, we will provide you with a copy of your personal data in the requested format, where technically feasible.
Right to object	This right enables you to object to the processing of your personal data in certain circumstances, such as where the processing is based on legitimate interests or for direct marketing purposes.
Upon receiving your objection to processing, we will assess the validity of your objection and, if valid, cease processing your personal data for the purposes to which you have objected.
Right to withdraw consent	You have the right to withdraw your consent to the processing of your personal data at any time. If we are processing your personal data based on your consent, you have the right to revoke that consent.
Upon receiving your request to withdraw consent, if we do not have any other legal basis for processing your personal data, we will stop processing it.
Right to lodge a complaint	If you believe that our processing of your personal data violates applicable legislation, you have the right to lodge a complaint with a supervisory authority.

If you wish to exercise any of these rights, please write to us at the email address provided in the “Contact details of the data controller” section. Please note that these rights are subject to certain limitations and exceptions as provided by applicable law. We will address your request as soon as possible and no later than one month from receipt. This period may be extended by up to two further months where necessary, taking into account the complexity and number of requests. In this case, we will inform you of the extension and explain the reasons for the delay.

If you are a California resident, you have certain rights under the CCPA and other applicable laws regarding the collection, use, disclosure, and sale of your personal data. This section of our Privacy Policy outlines those rights and explains how you can exercise them.

Right to know	California residents have the right to request that we disclose the categories and specific pieces of personal data that we have collected about them, the categories of sources from which the personal data was collected, the purposes for which the personal data was collected, and the categories of third parties with whom we have shared the personal data.
Upon receiving and verifying your request, we will promptly provide you with the requested information for the 12-month period preceding your request free of charge in a readily usable format, unless an exception applies.
Right to delete	California residents have the right to request the deletion of the personal data that we have collected, subject to certain exceptions as permitted by applicable law.
Upon receiving and verifying your request, we will delete your personal data from our records and direct our service providers to do the same, unless an exception applies.
Right to opt-out	California residents have the right to opt out of the sale of their personal data. “Sale” is defined broadly under the CCPA.
We do not, and will not, provide your personal data in direct exchange for money. However, we have disclosed certain categories of personal data we collect to third parties for business purposes as explained under “Details of processing.” To the extent that this practice is construed as a “sale” under the CCPA, we will respect your right to opt out.
Right to non-discrimination	California residents have the right to non-discrimination, under which we cannot refuse to provide goods or services, charge you a different price, or provide goods or services of a different level or quality because you exercised your rights under the CCPA.
We will not deny our services, charge different prices, or provide a different level or quality of services based on your exercise of CCPA rights.
Right to correct	California residents have the right to ask us to correct inaccurate personal data that we have about them.
Upon receiving and verifying your request, we will promptly review your personal data and make corrections as appropriate, ensuring that it is accurate and complete.
Right to limit	California residents have the right to direct us to use sensitive personal data only for limited purposes, such as providing requested services. Sensitive personal data may include social security numbers, financial account information, precise geolocation data, or genetic data.
We do not process such sensitive personal data.

If you want to exercise your rights as described above, please contact us via the email address provided in the “Contact details of the data controller” section. According to CCPA regulations, we need to verify your identity before proceeding with your request. If we need more time (up to 90 days), we’ll notify you in writing of the reason and the extension period.

If you have any concerns about how we handle your personal data, please inform us, and we will review your feedback. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the relevant authority.

Age limits

We do not knowingly collect or request personal data from individuals under the age of 18, nor do we allow such individuals to use our App. If you are under 18, please refrain from providing us with any personal data. If we become aware that we have inadvertently collected personal data from someone under 18, we will promptly delete it. If you believe that we may have personal data from or about someone under 18, please contact us using the information provided.