Privacy Policy

Last updated: January 28, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SC Brain Games SRL, Camil Ressu 53, District 3, Bucharest.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Romania

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to Houston, accessible from https://houstonteam.app

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

On what legal basis do we process your data?

To fulfill contractual obligations (article 6 (1) (b) GDPR): We process your Data in order to fulfill our contractual obligations to you. For example, we need your name and address to issue you an invoice. If you have concerns or requests to us, we need, for example, your e-mail address or phone number in order to contact you.

To fulfill legal obligations (article 6 (1) (c) GDPR): The processing of your Data may be required to fulfill our legal obligations (in particular for the storage of business papers and contractual documents).

On the basis of your consent (article 6 (1) (a) GDPR): If you have given us your consent to the processing of your Data – for example in the setting of cookies – this processing will only be carried out in accordance with the purposes specified in the respective declaration of consent and to the extent agreed therein.

You can withdraw your given consent at any time with effect for the future in writing by e-mail or letter to our e-mail address play@brainiup.com. The withdrawal of consent does not affect the lawfulness of the processing of your Data based on your consent before its withdrawal.

For the purposes of the legitimate interests (article 6 (1) (f) GDPR): If it is necessary for the purposes of our legitimate interests or the legitimate interests of third parties, we process your Data. Our legitimate interest in processing your Data includes own and third-party marketing purposes, customer loyalty or advertising. In addition, we have a legitimate interest in processing your Data for administrative purposes and for the exercise or defence of legal claims.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. 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 parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functional, marketing and statistical cookies

These cookies are not technically necessary for the presentation of the Website and are only activated with your given consent. You can withdraw your consent at any time and in the settings of your browser.

Name

Function

Storage period

Persistent Cookies

These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. 

1 year

houston_consent

Used to track if a visitor has provided consent for functional, marketing or statistical cookies.

1 year

_ga

Used to distinguish between different users in order to be able to get analytical data about the use of the Website.

2 years

_gat

Used to limit the collection of analytics data on high traffic sites.

10 minutes

_gid

Used to distinguish between different users in order to be able to get analytical data about the use of the Website.

1 day

Additionally, we use pixels and tags from the following third parties (which may in turn place cookies):

Third Party

Description

Privacy Policy

Google Analytics

We use Google Analytics to help measure how users interact with our websites.

https://policies.google.com/privacy

Facebook

We use Facebook Custom Audiences to deliver targeted advertisements to individuals who visit our websites.

https://www.facebook.com/policy.php

LinkedIn

We use LinkedIn Custom Audiences to deliver targeted advertisements to individuals who visit our websites.

https://www.linkedin.com/legal/privacy-policy

You have the right to block cookies by configuring your browser’s preferences or settings to stop accepting cookies or prompt you before accepting a cookie from a website that you visit.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.

To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Retention of Your Personal Data

The Company 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.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Your rights in the context of the processing of your Data (GDPR)

The GDPR is a set of regulations coming into effect on May 25, 2018 that enhances the data privacy rights of EU individuals. Brainiup is committed to upholding GDPR compliance among our Products and Services.

We have updated our internal policies and external contracts to ensure compliance with the GDPR prior to the official launch. Brainiup processes personal data on the following legal bases: (1) with your consent; (2) as necessary to provide our Products and Services; and (3) as necessary for our legitimate interests in providing the Products and Services where those interests do not override your fundamental rights and freedom related to data privacy. Brainiup has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities and the use of consent mechanisms.

Right to lodge a complaint, Customer or others that interact with Brainiup that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. The contact details for data protection authorities are available here.

Individual Rights, if you are a resident of the EEA or Switzerland, you are entitled to the following rights once the GDPR becomes effective. Please note, that in order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

The right to access and correction, you have the right to request access to, and a copy of, your personal data at no charge, as well as certain information about our processing activities with respect to your data. You have the right to request correction or completion of your personal data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy.

The right to request data erasure, you have the right to have your data erased from our Website if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

The right to object to our processing, you have the right to object to profiling or other processing if your legitimate interests outweigh the legitimate interests of Brainiup and so long as it does not interfere with a task carried out for reasons of public interest.

Data breach notification policy, Brainiup will follow all applicable rules and regulations of the GDPR, along with guidance and instruction from the applicable data protection authorities, in handling, responding, and resolving a data breach.

Data governance obligations, Brainioup has established procedures for periodically verifying implementation of and compliance with the GDPR Principles. Brainiup conducts ongoing assessments of our data protection practices to verify the attestations and assertions of our privacy practices are have been implemented properly.

Privacy by Design, Brainiup has implemented various technical and organizational measures to protect and minimize the amount and use of personal data we receive. We have designed our systems and processes to ensure the necessary safeguards of data protection are met.

Details of staff training and competence, Brainiup has trained all necessary staff on the privacy regulations in effect.

Links to Other Websites

Our Service may contain links to other websites 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 Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: play@houstonteam.app

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