Privacy Policy

This Privacy Policy applies to Genioworks’s Apps, websites and related services (together the “Services”). This Privacy Policy explains how we, and affiliated companies (collectively, „Genioworks“ or „we“, „us“, „our“) collect, use, secure, and/or disclose end users’ (“you” or “your”) or otherwise process your personal information when you use our Services.

This Privacy Policy governs the collection, use, and handling of personal data (also referred to as personal information) that we gather when you access or use our mobile game applications, forums, websites, and other online products and services (collectively referred to as the “Services”), or when you engage with us through other means.

The data controller is Genioworks Consulting & It-Services UG (haftungsbeschränkt), with a registered address at Karlheinz-Stockhausen-Straße, 30, 50171 Kerpen, Germany.

California residents may have different or additional rights. Please see the section titled Privacy Notice for California Residents.

Acceptance of this Privacy Policy

By using the App You express Your acceptance of this Privacy Policy, as such Policy may be amended from time to time.

If You do not agree to be bound by this Privacy Policy then, please, do not use the App. The current version of this Privacy Policy shall be always available at https://brainsoft-apps.com/privacy-policy/.

Information we collect

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to identify you (“Personal Data”). Our Services are designed to avoid collecting information such as your name, address, email address or other similar contact data unless you provide such data to us. The information we collect includes:

Device Information

When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, and the mobile device identifiers (such as your device ID, advertising ID), language and time zone and IP address.

Usage Information

We collect information automatically about your activity through our Services, for example date and time you used a service, features you have used, in-app purchases history, subscriptions, and advertising that you click on.

Other information

We may collect upon your permission other information such as precise geolocation (latitude and longitude) using information including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.

Information collected or obtained from third parties

We may receive information about you from our analytic service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found below.

Information that you provide

We collect some information from you when you provide it to us directly, such as via an online form or when you contact us through our in-app support feature or when you send us an email directly.

Advertisement serving technologies

We and our advertising networks and their partners may use cookies and similar technologies to provide and personalize our Services and provide targeted advertisements. Some of these technologies can synchronize behavior across different mobile apps, devices, and websites so that advertisements can be tailored to your interests. This process is called personalized advertisement experience.

Purposes for which we will use your information

We have set out below a description of the ways in which we plan to use your information, the legal bases we rely upon to do so and provide opt-out, where applicable:

• To provide and maintain our Services and to perform essential business operations, our legal basis for processing is performance of a contract with you which you entered into with us when you download our Services and accept our End User License Agreement.
• To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data), our legal basis for processing is legitimate interests for running our business, provision of administration and services.
• To notify you about changes to our Services, to allow you to participate in new features of our Services when you choose to do so and to understand how you use our Services so that we can continuously improve our offerings, our legal basis is legitimate interests to keep our users updated about our Services and our new features in accordance with your preference, and to continue to improve the Services we offer.
• To advertise our Services and products and to send push notifications, our legal basis is legitimate interests to be able to advertise our Services and products to our users.

To opt-out of receiving advertisements for our Services and products, send us a request through the in-app support feature.

You can opt-out of receiving push notifications by turning them off at the device level through the settings of the device.

• To serve personalized advertisements in our Services using third-party advertising networks, our legal basis is legitimate interests to run our business.

For European Economic Area, Norway or Switzerland, our third-party advertising networks rely on your consent to process Personal Data in order to provide personalized advertising to you, therefore you will be asked whether you consent to the tracking that enables personalized advertisement experience.

To opt-out of receiving personalized advertisements, see below ‘Opt-out of targeted advertising’.

Retention of data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

Your Personal Data will be deleted when they no longer serve one of the above-mentioned purposes but in any event your Personal Data will be deleted after 26 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

Privacy Notice for California Residents

California Privacy Rights Summary

This California Privacy Notice applies to personal information covered by the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA). It grants California residents specific rights outlined below.

Right to Know (Access)

You have the right to request details about the personal information we’ve collected over the past 12 months, including:

• Categories of data collected.
• Sources of data collection.
• Business purposes for collecting your data.
• Third parties with whom your data was shared.
• Specific data pieces collected about you.

Right to Delete

You can request the deletion of personal information we’ve collected, unless retention is necessary for:

• Completing transactions or providing services.
• Security, bug fixes, or legal compliance.
• Research or lawful internal purposes aligned with your data’s original context.

Right to Opt-Out

You can opt out of the “sale” or sharing of your data with third parties for monetary or other benefits. To opt out, adjust the privacy settings in our apps or your device’s privacy settings.

Other Rights

• Request information about data shared for direct marketing purposes in the past year (if applicable).
• Correct inaccurate personal data.
• Be free from discrimination for exercising your privacy rights.

Privacy Notice for Residents of Colorado, Connecticut, Virginia, Utah, Oregon, and Texas

This notice applies to personal information processed under state laws such as the Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CDPA), Utah Consumer Privacy Act (UCPA), Oregon Consumer Privacy Act (OCPA), and Texas Data Privacy and Security Act (TDPSA). These laws grant residents specific privacy rights, summarized below.

• Right of Access: Request confirmation of whether we process your data and receive a portable copy of data you’ve provided.
• Right of Rectification: Request correction of inaccuracies in your personal data.
• Right of Erasure: Request deletion of personal data we have collected from you.
• Right to Opt-Out: Opt-out of targeted advertising, sale of your personal data, or profiling that produces significant decisions. Adjust privacy settings in our apps or your device to submit an opt-out request.
• Non-Discrimination: You are entitled to equal treatment regardless of exercising these rights.

Your rights and options

Access personal data we hold about you

You have the right to request access to your personal data. This can be done by using “Contact us” through the in-app support feature in our Services. Following your request, we will provide you a copy of your personal data in an electronic format.

Other rights

You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your personal data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such a withdrawal.

Opt-out of targeted advertising

To show you personalized advertisements in our apps we use specific advertising networks and their partners to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple’s ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure. For further information on advertising networks go to ‘Advertising networks and their partners’ below.

You can opt-out from personalized advertisement experience at any time by checking the privacy settings of your Android or iOS device.

For Apple devices

1. Open Settings
2. Select Privacy
3. Select Advertising and enable „Limit Ad Tracking“

For Android devices

1. Open Settings
2. Select Google
3. Select Ads and enable „Opt out of Ads Personalization“

When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests.

Exercise these rights

Any requests to exercise your rights should be made through our support feature located in our apps. You can also send us an email at info@brainsoft-apps.com, however we may still redirect you to make the same request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

Social sharing features

Some of our Services offer social sharing features which let you share actions you take in our Services with other media. You must be over the minimum age limit that is prescribed by the legislation in the individual jurisdictions to use any social sharing features integrated in our Services. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. Our Services has social features from the following providers:

• Facebook — https://www.facebook.com/about/privacy/
• Instagram — https://help.instagram.com/519522125107875

Protecting children’s privacy

We do not knowingly collect or process personal data from or with respect to children under the age of 13, and you must be 13 years of age or older in order to use Services.

If you are a parent or legal guardian and believe that your child under the age of 13 has submitted his or her personal data or other data without your consent, permission, or authorization — please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

Links to other sites

Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.

Data security

We take the security of your personal data seriously. We implement technical and organizational measures to protect your data, including:

• Encryption of sensitive data during transmission.
• Regular monitoring of our systems to prevent unauthorized access.
• Restricting access to personal data to authorized employees and partners.

Despite our efforts, no security measure is completely foolproof, and we cannot guarantee absolute security.

Changes to this Privacy Policy

This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.

In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of a notification or pop-up), before the changes become effective and update the „effective date“ at the top of this Privacy Policy.

Contact Information

If you have any questions about this Privacy Policy, please contact us using the in-app support feature in our Services, which is the preferred method to be able to quickly respond to your requests or contact our data protection officer at the address provided below:

Genioworks Consulting & It-Services UG (haftungsbeschränkt)
Karlheinz-Stockhausen-Straße, 30
50171 Kerpen, Germany

Commercial Register: 90444
Registration court: Amtsgericht Cologne
VAT ID (Sect. 27 a UStG): DE310780221

Phone: +49 157 34517168
Email: info@brainsoft-apps.com

Advertising networks and their partners

Below, you can find a list with all third-party advertising networks and their partners, with whom we work to provide you with a personalized advertisement experience within our apps. The advertising networks listed below, with the exception of Fyber who acts as a data processor upon our instructions, are independent data controllers in respect of your personal data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.

In order to provide personalized advertisements to our users, those listed below use device information that include personal and non-personal information, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize this advertising procedure. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple’s ID for advertising (IDFA).

1. BidMachine

Provided by BidMachine Inc. (US).
Privacy Policy: bidmachine.io/privacy-policy

2. Blis

Provided by Blis Corp Limited (United Kingdom).
Privacy Policy: blis.com/blis-privacy-policy

3. Criteo

Provided by Criteo GmbH.
Privacy Policy: criteo.com/privacy

4. Epsilon

Epsilon (formerly known as Conversant), provided by Epsilon International UK Ltd, part of the Publicis Groupe (France).
Privacy Policy: epsilon.com/emea/privacy-policy-services

5. Facebook (Meta)

We utilize Meta Business Tools and Meta Audience Network provided by Meta Ireland Platform Limited or Meta Platforms, Inc. (“Meta”). These tools collect data using cookies, Pixels, and similar technologies to deliver targeted advertisements.
Privacy Policy: facebook.com/policy.php
Manage Ad Preferences: from your Facebook account.

6. Digital Turbine

Provided by Digital Turbine (IL) Ltd.
Privacy Policy: digitalturbine.com/privacy-policy

7. Google Advertising Products

Including AdManager, AdMob, and AdSense.
Privacy Policy: policies.google.com/privacy
Manage Ad Preferences: myadcenter.google.com

8. Index Exchange

Provided by Index Exchange Inc. (Canada).
Privacy Policy: indexexchange.com/privacy

9. InMobi

Provided by InMobi PTE Ltd (Singapore).
Privacy Policy: inmobi.com/privacy-policy
Opt-out: inmobi.com/page/opt-out

10. ironSource and Advertising Partners

Provided by ironSource Mobile Ltd (Israel).
Privacy Policy: developers.is.com (privacy policy)
Advertising Partners: developers.is.com (partners)

11. Liftoff

Provided by Liftoff, Inc. (US).
Privacy Policy: liftoff.io/privacy-policy
Opt-out: vungle.com/opt-out

12. LoopMe and Partners

Provided by LoopMe Limited (UK).
Privacy Policy: legal.loopme.com/privacy-center

13. Media.net

Provided by Media.net Advertising FZ-LLC (UAE).
Privacy Policy: media.net/privacy-policy

14. Minute Media

Provided by Pro Sportority (Israel) Ltd.
Privacy Policy: minutemedia.com/policies/privacy-policy

15. Mintegral

Provided by Adlogic Technology Pte. Ltd (Singapore).
Privacy Policy: mintegral.com/en/privacy

16. MobileFuse

Provided by MobileFuse LLC (US). Used only for users in the US.
Privacy Policy: mobilefuse.com/privacy-policy

17. Moloco

Provided by Moloco, Inc. (US).
Privacy Policy: moloco.com/advertising-policy

18. Nexxen

Provided by Nexxen Group LLC (US).
Privacy Policy: nexxen.com/privacy-policy

19. Ogury

Provided by Ogury Ltd (UK).
Privacy Policy: ogury.com/privacy-policy

20. OpenX

Provided by OpenX Software Ltd (US).
Privacy Policy: openx.com/legal/privacy-policy

21. Pangle

Provided by Bytedance Pte. Ltd. (Singapore).
Privacy Policy: pangleglobal.com/privacy
Chinese Mainland users: pangle.cn/en/privacy/partner, compliance guide

22. Primis

Provided by M.D. PRIMIS TECHNOLOGIES LTD (Israel).
Privacy Policy: primis.tech/privacy-policy

23. PubMatic

Provided by PubMatic, Inc. (US).
Privacy Policy: pubmatic.com/legal/privacy-policy
Opt-out: pubmatic.com/legal/opt-out

24. Verve

Provided by Verve Group, Inc. (US).
Privacy Policy: verve.com/privacy-policy

Analytics services

1. Adjust

Provided by Adjust GmbH (Germany).
Privacy Policy: adjust.com/privacy-policy

2. Firebase Analytics

Provided by Google Inc. (US). You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google.
Privacy Policy: google.com/policies/privacy

3. Google Analytics

Provided by Google Inc.
Privacy Policy: policies.google.com/privacy

4. Facebook Ads Conversion

Provided by Facebook, Inc. (US). This service connects data from the Facebook advertising network with actions performed within our applications.
Privacy Policy: facebook.com/about/privacy

5. Tenjin

Provided by Tenjin, Inc. (US). It collects and analyzes user data to track app performance, advertising attribution, and monetization metrics.
Privacy Policy: tenjin.com/privacy-policy

Advertising and measurement tools

Facebook (Meta)

We utilize Meta Business Tools and Meta Audience Network provided by Meta Ireland Platform Limited or Meta Platforms, Inc. (“Meta”). These services employ cookies, Pixels, and similar technologies to collect and analyze data from our applications and deliver targeted advertisements. Meta may process some of the collected information as a Joint Controller. For detailed information about their data practices and how to exercise your rights, refer to their Privacy Policy:
facebook.com/policy.php

Cloud computing services

AWS (Amazon Web Services)

Provided by Amazon Web Services, Inc. (US).
Privacy Policy: aws.amazon.com/privacy