PRIVACY POLICY
This Privacy Policy explains who we are, how we process (i.e. collect, record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, disseminate or otherwise make available, align or combinate, restrict, erase or destruct) personal information about you, and how you can exercise your privacy rights. We are Brick Stone Trading and Services Company Limited., a company under laws of Vietnam, with registered address at: 3/18A Nguyen Van Sang, Tan Phu dist., Ho Chi Minh, Vietnam (“BrickStone” or “we”), a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.
1. INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes directly from you when you play our Games or interact with third-party ads in our Games or with our ads in other publisher’s Games. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games and may include information that you submit to us when you voluntarily contact us. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (provided that we never receive your payment or credit card information).
The information that we may collect about you through the Services broadly falls into the following categories:
(a) Information that you provide voluntarily
Certain parts of our Services may ask you to provide personal information voluntarily. For example, we will ask for certain information in order for you to submit enquiries to us, such as:
- your name, email address or other details, necessary to process your inquiries;
- any information you submit to our support team via email.
The personal information that you are asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.
(b) Information that we collect automatically
When you use our Services, we may also collect certain information automatically from you and/or your device which may be considered personal information under applicable data protection laws, such as:
- Data and analytics about your use of our Services (e.g. in-game play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed, in-game references or just game preferences, the means by which you were referred to our Services)
- Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for more see here Advertising IDs and Device IDs)
- Your device type and the operating system that you use
- Your Service communications (e.g. in-game emotion signals which you exchange with other players)
- Broad geographic location (e.g. country or city-level location) based on your IP address
Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.
Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.
Some of this information may be collected through cookies as explained further under the heading Cookies below.
(c) Information we obtain from third-party sources
- Third-Party Social Network/s. Google Play Games Service, Apple Game Center, Facebook (“Third-Party Social Network/s”). You may choose to connect to our Services via your social media account. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as your username, gender, your friends playing the same Game. (See below also “Third-Party Social Networks”).
- Third party service providers. We may receive personal information about you from third-party sources. We may get your personal information for example when you installed our Game and prior to installing you have clicked an advertisement for the same Game.
- Advertising partners. From time to time, we may also receive personal information about you from other third-party sources. For example, if you clicked on an advertisement to direct you to one of our Services (such as an advert of one of our Games in another publisher’s game), we will be provided with information from which ad network and advertising campaign the install originated from (See below also “Advertising”).
A list of our current service providers and partners is available here.
(d) No special categories of information
We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Kindly be cautious when sharing this information about yourself (or others) in our forums.
2. HOW WE USE YOUR INFORMATION
2.1. In General
We use the information we collect about you/your device to deliver services and our Games to you and to operate our business. We use it also for improving our services and Games, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Games in our Games and also in other publisher’s apps and to display third-party advertisements to you. We use your information also for tracking and fraud prevention for advertising purposes and for complying with our legal obligations.
We use your information for the following purposes:
1. Delivering and improving our services. We use your information for developing, delivering and improving our Games and other products, services, and content, tailoring our products and services, providing Game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Games, and administering the Games.
2. Displaying advertisements. We use your information for showing advertisements for our Games in other publisher’s apps and for displaying third-party advertisements in our Games. Please see more in the Advertising Section of this Privacy Policy.
3. Cross-promotion. We use your information for cross-promoting our Games and services, meaning to promote one of our Games while you are playing a different Game of ours.
4. Tracking and fraud prevention for advertising purposes. We use your information for tracking how our advertising campaigns perform and for identifying and preventing fraud for our advertising campaigns.
5. Analytics and research. We use your information for understanding and analyzing trends in connection with the usage of the Games, gathering demographic information about our user base, data about where the Game was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Games and services, or to test our new game features and content.
6. Security. We use your information for enhancing the safety and security of our Games, products and services.
7. Customer Support. We use your information for providing customer support to you and to respond to your inquiries.
8. Our legal obligations. We use your information when we are required to do so by law, for example, we use your country or region for tax reporting purposes.
2.2. In-App Purchases
Our Games enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions for in-app purchases are completed through the app store via your App Store account, Google Play account or Amazon.com account. Any post-purchase processes are controlled by the Apple, Google and Amazom.com stores and are subject to specific terms of such Apple, Google and Amazon.com stores. Please review privacy policy and terms of service of your Apple, Google and Amazon.com stores.
3. HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Games by ourselves. We must, therefore, share collected information with third parties for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’ advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
We may share such information to:
- Our analytics providers. We use third-party analytics such as Unity, Firebase for the purposes of delivering our services, conducting analysis, and research. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. We can aggregate the data for benchmarking features.
- Our cloud service providers. We store information we collect from you on servers provided by our third-party cloud service providers such as iCloud, Google Cloud Platform;
- Our tracking and fraud prevention providers. For some of our Games we use tracking and fraud prevention providers, such as AppsFlyer, Adjust for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such providers may use APIs, and SDKs in our Games to enable them to collect and analyze user and device-related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.
- Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Games for free or at low cost.
- Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. They may use their own third-party tracking providers.
- Other third-party service providers. For our Games, we use Unity Software to develop such Games. For the data processing by Unity please see Unity’s privacy policy available at https://unity3d.com/legal/privacy-policy. For some Games, we partner with third-party development studios to develop such Games. Such third-party development studios do not have access to your personal information, they can only access aggregated data that they cannot trace back to you.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Games. These changes shall be updated from time to time or promptly in case of material changes in our data processing practices.
The list of our current service providers and partners is available here.
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.
For any additional questions about third-party information collection, please refer to [email protected].
4. ADVERTISING
4.1. In General
We use advertising to fund our Services and to make our games available for free. We offer our Games for free or at low cost and in order to do that we need to share information we collect from you with our third-party advertising partners. As a safeguard to protect your privacy, we only store personal information temporarily. The information collected helps us to improve our websites and Games and – at the same time – keep our Games free for a wide player base.
If you are an European Economic Area (EEA) – based user be aware that:
(a) When you use our Games, we rely on our legitimate interest to show advertisements to you. The legal basis to show ads to EEA-based users is the legitimate interest in accordance with the European data protection requirements under Art. 6 para. 1 lit. f GDPR, which we evaluated together with our data protection officer. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR .We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements.
(b) Before sharing any information with our advertising partners for the purposes of personalized advertising, we always ask for your consent, given when you press accept at relevant button at loading of the Game. We allow our advertising partners to show personalized ads to you only if you have pressed ACCEPT in relevant pop-up window and so consented to the sharing of your personal information for the purposes of personalized advertising. Our advertising partners use different technologies for the purposes of personalized advertising that process your personal information in different ways, so please review their data processing practices before you ACCEPT to show you personalized ads at loading of the Game. The list of our current advertising partners with links to their privacy policies is available here. The legal basis to show personalized ads to EEA-based users is consent in accordance with the European data protection requirements under Art. 6 para. 1 lit. a GDPR. In addition, a data processing agreements were concluded with external ad technology providers networks in accordance with the requirements of Art. 28 GDPR. We also ensure that our external service providers are committed to a high level of data protection by concluding data protection agreements. The purpose is to improve our Games and provide the player with more relevant ads. You have an option to withdraw your consent to sharing your personal information for the purposes of personalized advertising at all times. You can withdraw your consent by going to the Game settings and clicking the Terms & Privacy button therein, in section Personalized Ads Consent Withdrawal of the Privacy Policy you will be able to manage your preferences by choosing to which advertising you would like to get. When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.
4.2. In-game advertising (i.e. when you view ads in Our Games)
To enable us to show in-game ads, we may send your advertising ID and IP-address to advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. We do not control which specific ads are shown in our games (it is controlled by ad networks), but we do blacklist certain categories of ads.
Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:
- limit the number of times you see the same ad;
- ensure they are dealing with humans with real devices and not ‘automated’ bots;
- serve you with advertisements likely to be relevant to you based on your advertising ID engagement with other brands and ads, also recorded using your advertising ID and using your general geographic area. Other brands buy advertisement placement via an ad network or ad exchange to advertise their products in Our Games. The ad network or ad exchange acts as intermediary between the other game companies and Us. In order for an ad network to charge the company buying the ad, clicks from the ad and potentially installs of other developers’ applications party apps are tracked. Views, clicks, and installs from ads are measured using Advertiser ID;
- keep track what games you have used to market you similar kind of games. IP-address is typically used by advertisers to broadly see the general geographic area you are coming from for example country, state, and sometimes at city level).
4.3. View of Our ads on third-party services
We also advertise Games in other apps by asking ad networks to serve them to audiences that will be interested in them (determined using Advertising IDs).
The Advertising IDs are used by the ad networks for a number of purposes (please refer to the Privacy Notices of our advertising partners listed here) including:
- measuring ad effectiveness (looking at aggregated views, clicks and installs they generate through their advertising in other publishers’ games);
- informing players, that have not been playing for a while, about new content in the Game. We give a list of these users in the form of Advertising IDs to an ad network. Ad network then shows these users ads about the new content;
- not showing ads on a game which a player is already playing. We can send a list of active players in the form of Advertising IDs to an ad network. Ad network then excludes these players from seeing the ad;
- marketing games to a group of potential players.
4.4. WHO CAN SHOW PERSONALIZED ADS TO YOU?
Please see the list of advertising providers that are allowed to show personalized advertising and review their data processing practices, including the technologies they use for the purposes of personalized advertising here.
4.5. HOW CAN YOU TURN OFF PERSONALIZED ADS?
Besides specific instruments available to EEA-based users via the Game you can use your device settings.
iOS
Open the “Settings” application of iOS and select the “Privacy” menu item and then the “Advertising” sub-item. If you activate the “Limit ad tracking” option, we can only take limited measures such as identifying unique users or combating fraud. In the same menu you can always delete the IDFA (“Reset Ad-ID”), then a new ID is created which is not merged with the data collected earlier.
Android
Open the “Settings” application and select the “Google” menu item. Depending on your device, this option may not be visible on the main menu but you may use the search function at the top of the Settings menu to find it. From there, select the “Ads” sub-item and activate the option “Opt out of Ads Personalisation” to prevent the creation of profiles and the display of personalized advertising. You can delete the advertising ID in the same menu at any time (“Reset advertising ID”), then a new ID will be created which will not be merged with the previously collected data.
5. THIRD-PARTY SOCIAL NETWORKS
5.1. Connecting to Third-Party Social Networks
Some of our Games use third-party services such as Google Play Games Service, Apple Game Center, Facebook (“Third Party Social Network/s”). Such Games enable you to log in to your Third-Party Social Network account to connect our App by using the “Log in” feature in our App. You may also share the content you create within the App on Third-Party Social Networks. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end-user agreements and we are not responsible for and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions, contact us at [email protected].
5.2. Information We May Receive When You Connect to Third-Party Social Networks
The information you allow us to access varies by App and is affected by the privacy settings you establish on those Third-Party Social Networks. You can control and find out more about these settings from the Third-Party Social Network in question. When you use the “Log in” feature, we may access and store some or all of the following information, as allowed by you, Third-Party Social Networks and your preferences: (i) your basic information from your public profile, such as your nickname, profile picture; (ii) login ID and/or player identifier string; (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the “Log in with” process. We may share your name and your game data (such as moves, Game progress and scores) with respect to the applicable App, with your friends who have also used the “Log in with” or “Connect to” feature in connection with such App or with your contacts in applicable Third-Party Social Media Network account.
The App may further ask you to allow us to post on such Third-Party Social Networks on your behalf (e.g. status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly.
5.3. How You Share Your Information On Third-Party Social Networks
If you use Third-Party Social Networks to participate in game-related activities, such as leaderboards and multiplayer games, you share your information with other players and Third-Party Social Networks (for example, scores, rankings, and achievements).
6. COOKIES
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some options of our Service.
7. CHILDREN’S PRIVACY
We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian's prior permission.
We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.
If we consider that any of our Services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the Services or from providing information and/or limit the collection of information from such users as described below in more detail.
No personal information should be submitted to BrickStone by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their state of residence.
Such a user cannot:
- display their real name or any information in the games
- access the chat, leaderboard, forums, SNS (Facebook, Game Center, etc.)
- subscribe to newsletters
- use any other feature where users could appear under their real names
With respect to such a user, we will prevent the collection and use of their precise geolocation data and display to them contextual advertising only (excluding any behavioral advertising).
Children can be invited to take part in testing our games (playtests) with their parents' or guardians’ authorization and/or their parents' or guardians’ physical presence being required depending on the state where the playtest is conducted.
Parents must exercise their privacy rights for their children. Please refer to the "Your rights" section of this Privacy Policy.
8. YOUR RIGHTS
If you are EEA-based user you have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by following the instructions below or sending us relevant requests to [email protected].
Your rights include:
- Right to withdraw your consent in accordance with Art. 7 para. 3 GDPR (e.g. you may withdraw your consent to show personalized ads to you, by loading Terms & Privacy from your Game settings and following instructions in section Personalized Ads Consent Withdrawal in Privacy Policy (available to EEA-based users only))
- Right to access your data in accordance with Art. 15 GDPR (e.g. you may check what data we store about you, for this purpose please load Terms & Privacy from your Game settings and follow instructions in section Request a Summary of Personal Data in Privacy Policy (available to EEA-based users only))
- Right to correct your data in accordance with Art. 16 GDPR (e.g. you can contact us if your email address has been changed and we should replace your old email address)
- Right to have your data deleted in accordance with Art. 17 GDPR (e.g. you can contact us if you want us to delete certain data that we have stored about you, please load Terms & Privacy from your Game settings and follow instructions in section request Personal Data to be removed in Privacy Policy (available to EEA-based users only))
- Right to restrict processing of your personal information in accordance with Art. 18 GDPR (e.g. you can contact us if you want to restrict processing)
- Right to take your data with you in accordance with Art. 20 GDPR (e.g. you can contact us to receive your data if you want to upload it to another service)
- Right to object how your data is handled in accordance with Art. 21 GDPR (e.g. you can contact us if you do not agree with any user analytics procedures as described within this privacy policy)
- Right to send complaints to the supervisory authority in accordance with Art. 77 para. 1 f GDPR (e.g. you can contact the data protection supervisory authority directly).
- Right to opt-out of targeted advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android).
- Right to opt-out of the sale of personal data (if any sale takes place), and/or profiling that supports decisions that produce legal or similarly significant consequences for them.
9. ADDITIONAL INFORMATION FOR CALIFORNIAN USERS
The California Consumer Privacy Act of 2018 (CCPA) permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has collected, shared with, and/or sold to third parties for a business or commercial purpose during the immediately preceding calendar year.
9.1. How to access your data
You can request a copy of your personal data by contacting us at BrickStone or within your account settings
Users can contact developer's email to delete their personal data
If we sell your personal data, you also have the right to know what personal data was sold and what categories of third parties bought it.
If we share your personal data, you have the right to know what categories of personal data were disclosed.
9.2. How to Opt Out of a Sale
As a Californian consumer, you also have the right, at any time, to opt out of any type of selling of your personal information.
9.3. How to request deletion of your data
You can request deletion of your personal data by following these instructions:
- Contact us by email, phone or postal mail
- Users can contact developer's email to delete their personal data
If we are able to verify your request, we will delete your personal data from our records. In order to verify a request we may ask for identifying information provided by you to match the personal data the app already maintains. We will direct any service providers to do the same. Please note that there are exceptions, such as when the data needs to be saved for legal reasons or to protect the security of our apps.
We also may not be able to delete your personal data if it is needed to:
- Perform our contractual obligations to you, such as completing a transaction, fulfilling the terms of a warranty or recall, or providing a good or service requested by you;
- Maintain and protect our business, our websites, and our apps, including detecting and preventing security incidents, or prosecuting those responsible for illegal activity;
- Identify and fix errors that impact the intended user experience or functionality;
- Exercise our legal rights, or ensure that others can exercise their legal rights, including the right to free speech;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed research in the public interest, as long as we received your informed consent;
- Comply with an existing legal obligation; or
- Use your personal data internally, in a lawful and reasonable manner, in the context that you provided it.
9A. Your Colorado, Connecticut, Utah, and Virginia Privacy Rights
These additional rights and disclosures apply only to residents of Colorado, Connecticut, Utah, and Virginia. Terms have the meaning ascribed to them in the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”), as applicable.
DATA SUBJECT REQUESTS
You may have the following rights under applicable law:
- To confirm whether or not we are processing your personal data
- To access your personal data
- To correct inaccuracies in your personal data
- To delete your personal data
- To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format.
To exercise any of these rights, please follow the instructions for data subject requests in the Your Privacy Choices section above. Please note these rights are subject to exceptions. We will respond to your request within 45 days. We may require specific information from you to help us confirm your identity and process your request. If we are unable to verify your identity, we may deny your request. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
AUTHORIZED AGENT
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.APPEALS
If we refuse to take action on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint as follows:
For Colorado residents, to the Colorado AG at https://coag.gov/file-complaint/
For Connecticut residents, to the Connecticut AG at https://www.dir.ct.gov/ag/complaint/
For Virginia residents, to the AG at https://www.oag.state.va.us/consumercomplaintform
Your Nevada Privacy Rights
If you are a Nevada consumer, you have the right to direct us not to sell certain information that we have collected or will collect about you. To exercise this right, please follow the instructions for submitting a data subject request in the Your Privacy Choices section above.
Your European Privacy Rights
These additional disclosures and rights apply only to individuals located in the European Economic Area, Switzerland, or the United Kingdom (collectively, “Europe”). Terms have the meaning ascribed to them in the General Data Protection Regulation (“GDPR”).
ROLES
Company acts as a controller with respect to personal data collected as you interact with our Service.
BASIS FOR PROCESSING
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
DATA SUBJECT REQUESTS
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please follow the instructions for data subject requests in the Your Privacy Choices section above. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. For details on our retention practices for personal data, see the Retention section below.
You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.
DATA PRIVACY FRAMEWORK AND INTERNATIONAL TRANSFER
We are based in the U.S. and the information we and our Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.
GMH complies with the EU-US Data Privacy Framework (“EU-U.S. DPF”) and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from the European Union and Switzerland to the United States, respectively. GMH has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) and the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) (collectively, the “Principles”) with regard to the processing of personal data received from the European Union and Switzerland respectively. If there is any conflict between the terms in this privacy policy and the Principles, the Principles shall govern.
In accordance with our obligations under the DPF we hereby affirm our commitment to subject to the Principles all Personal Information transferred from the European Union and Switzerland in reliance on the DPF. This means that, in addition to our other obligations under the Principles, we shall be liable to you for any third party agent to which we transfer your Personal Information and that processes such Personal Information in a manner that violates the Principles, unless we can demonstrate that we are not responsible for the resulting damages. GMH is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In the event that you have any inquiry, dispute, or claim arising out of or relating to our compliance with the DPF, please email us. If we are unable to resolve your complaint directly, you may submit your complaint at no cost to you to JAMS at JAMSADR. In the event there are residual complaints that have not been resolved by JAMS, or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the DPF.
To learn more about the DPF, and to view GMH’s certification, please visit https://www.dataprivacyframework.gov/s/participant-search.
10. GENERAL
Your information privacy and security is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We have appointed data protection officer to help us ensure compliance with EEA data protection laws. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners (see the List of our current Partners here) as for the purposes described above in “How We Share Your Information” Section, which may include a transfer of your personal information outside of the European Economic Area (the “EEA”). Please check regularly for changes to our Privacy Policy.
11. LEGAL BASES
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.
The legal bases that we rely upon are the following:
- Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Games (such as in-app chat feature, multiplayer feature, leaderboards and other third-party social network features), to deliver content of the in-app purchase you make.
- Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Games free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, tracking and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
- Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before sharing any information with our advertising partners for the purposes of personalized advertising and before conducting any surveys.
- Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance, is to maintain records for tax purposes.
12. SECURITY
We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.
13. INTERNATIONAL TRANSFER
Your personal information may be transferred to and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
This means that when we collect your personal information, we may process it in other countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and third party service providers and partners, which require us to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.
14. RETENTION
We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all of our Games has ceased.
When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data we will delete your data as described above in “Your Rights” Section.
15. CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://brickstone.live//privacy-policy.html.
For previous versions of this Privacy Policy, please contact us via [email protected].
16. CONTACT US
If you have questions or concerns about this Privacy Policy, please contact us through one of the following ways:
1. for privacy questions and exercising your rights via our privacy email: [email protected] ;
2. if you have a concern or compliance regarding our treatment of your personal data you can contact the relevant data protection authority. You can find contact details of data protection authority at https://edpb.europa.eu/about-edpb/board/members_en. For more information on which authority to contact, please email us here [email protected].
3. for general information, please feel free to contact us via our contact service page: https://brickstone.live//contact-us/ .
For information collected under this Privacy Policy, the data controller is Brick Stone Trading and Services Company Limited., a company under laws of Vietnam, registered at 3/18A Nguyen Van Sang, Tan Phu dist., Ho Chi Minh, Vietnam.