Privacy Policy

As used in this Privacy Policy, “Brainiac Games”, “We”, “Us” or “Our”, refers to Brainiac Games
LTD, with its registered address at 2nd Floor 2 Woodberry Grove, North Finchley, London,
United Kingdom, N12 0DR.

This Privacy Policy is part of and incorporated by reference into the Terms of Service (the “Terms”)
governing the use of all “Brainiac Games” branded software applications (the “Application/s”, or “
App/s”), which may operate on any type of computing device (including without limitation, a mobile
device), and applies to your use of the Applications and/or www.chess-universe.net, and/or URL
which may replace it or which may be added to the list of websites published by us and linking to
this Privacy Policy (the “Website/s”).
We take the privacy of our users and data security very seriously and believe in the right of our
users to know which data is collected and for what purpose. We therefore strive to make our
actions transparent and allow our users to control the collected data and remove it if they so
wish, and we take all reasonable precautions to prevent unauthorized access to this data.

When accessing to our website and/or using any of our Apps you consent to the collection,
transfer, manipulation, storage, disclosure and other uses of your information as described in
this Privacy Policy. Irrespective of which country you are based in, you authorize Brainiac
Games to use your information in, and as a result to transfer it to and store it in Slovenia and
any other country where Brainiac Games, or any third party service providers acting on its
behalf, operates. Privacy and data protection laws in some of these countries may vary from
the laws in the country where you are based, but we will always take appropriate steps to
safeguard the privacy of your personal information.

By using our Apps you specifically consent to collection, transfer, manipulation, storage,
disclosure and other uses of your information (including personal information) as described in
this Privacy Policy.. We may receive and/or you may be asked to provide your information
(including personal information) any time you are in contact with us or use the Applications. As
described in greater detail below, we may share this information (including personal information)
with our affiliates and with third party partners (as defined below) and use it in ways consistent with
this Privacy Policy. We may also use your information (including personal information) together
with other information to provide and improve products, services, content, and
advertising. Irrespective of which country you are based in, you authorize Brainiac Games to
use your information in, and as a result to transfer it to and store it in Slovenia and any other
country where Brainiac Games, or any third party service providers acting on its behalf,
operates. Privacy and data protection laws in some of these countries may vary from the laws
in the country where you are based, but we will always take appropriate steps to safeguard
the privacy of your personal information.

For general information please feel free to contact us via info@chess-universe.net.

Please read this Privacy Policy in order to learn more about the data we collect, what do we
use it for and how we protect your privacy.

Interest-based ads
We promote our Apps and services in ours and other publisher’s apps and we also allow our
partners to promote and advertise their goods and services in our Apps. We may share
information we collect from you to our advertising partners and they can reuse such data for
targeted advertising. We or our advertising partners may display interest-based, or retargeted,
ads (''IBA''), but only for the device IDs that have not opted out of IBA. By using our Apps and not
choosing one of the opt-out options, you give us consent to transfer your data as stated below.
We may pass information we collect from you such as technical information, advertising and
application usage information (for example if a device has clicked on a sports ad within our Apps,
for more information please see Information And Data We Collect From You Section of this
Privacy Policy) as well as age or gender information to our advertising partners and they can
reuse such data for targeted advertising. We allow our partners to serve targeted third party
advertisements or other content. They may attach the information gathered from our App to info
gathered from other apps, websites, or via other services, and then build profiles and transfer the
info to another provider. For example we pass advertising IDs to Facebook and they match it
with your Facebook ID, aggregate it and delete the initial identifier. By doing so the other provider
may receive or gather information about you and use the information for displaying targeted ads.
Advertisers may choose their audience by location, demographics, likes, keywords, age &
gender, interests, behaviors, connections and any other information Facebook receives or infers
about users. We cooperate with several providers of IBA that are listed herein in subsection a)
and in Opt-Out Section of this Privacy Policy (''Third Parties'').
At all times You have an option to opt out from sharing your information and data for the
purposes of interest-based advertising When you opt out, you will not stop receiving ads, they
just won't be based on topics you like, your interest, behavior, demographics, etc. You can opt
out by choosing one of the following options (for more information please read the ''Opt Out''
Section of our Privacy Policy):
a) Via third party IBA provider:

- Google(AdMob) https://support.google.com/admob/answer/7665968; https://support.

google.com/dfp_premium/answer/9012903;
https://support.google.com/admob/answer/2753860#Interest_based
- Facebook Audience
Network https://www.facebook.com/about/privacy/update?ref=old_policy
- Facebook Ad
Campaigns https://www.facebook.com/about/privacy/update?ref=old_policy
- AdMost https://resources.admost.com/privacy-policy/
- Unity Ads https://unity3d.com/legal/privacy-policy
- Inmobi https://www.inmobi.com/privacy-policy/
- Add4Game https://ad4game.com/privacy/
- Google Adx https://policies.google.com/technologies/ads?hl=en-US
- Applovin https://www.applovin.com/privacy/
- ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-
privacy-policy/#step-2
- adtrue https://publishers.adtrue.com/terms-and-conditions
- Mintegral https://www.mintegral.com/ru/privacy/
- Adcolony https://www.adcolony.com/consumer-privacy/
- Vungle https://vungle.com/privacy/
- My.com https://legal.my.com/us/mytarget/privacy/

If you choose to opt out you should stop receiving interest-based and targeted ads via the
selected IBA provider, but you may continue to receive interest-based or targeted ads through
other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA
providers, please see opt out options b) and c) below.
b) Via “Do Not Track Settings” in mobile phone:
Turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your
Android device.
c) Via our Apps:
Choose “Opt Out of IBA” within the settings of our Apps (where available).
“Do Not Sell My Personal Information” Rights
If you are a California resident, California Consumer Privacy Act (CCPA) may permit you to “opt
out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in
the CCPA). CCPA recognizes certain exceptions to the definition of “sale,” such that not all
transfers of personal information are “sales.
You have an option to opt out of the sale of your personal information and data for the purposes
of interest-based advertising at all times.
If you would like to opt out of the sale of your personal information, choose “Opt out of IBA”
within the settings of our Apps (where available).

Information and data we collect from you

1. Technical Information And Data
We might collect technical data necessary for you to use our App and additional technical data
that enables us to maintain and analyze the functioning of the App, to personalize the content of
the App, and to display advertisements.
We may automatically obtain certain information about your computing device, including:

• IP address; Country code;

• IDFAs, IDFVs, Advertising IDs;
• Language;
• Time zone, session start/stop time,
• Network status (WiFi, etc.), browser plug-in types and versions;
• User agent string (UA), platform, SDK version, timestamp;
• Technical device information (e.g. device model and name, operating system name and
version, CPU information, storage size, screen size, firmware, software, mobile phone
carrier, Internet service provider, API key identifier for application, International Mobile
Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
• Push notifications token;
• Player identifier string (we collect player identifier string only upon your sign in to Google
Play Games Services or Apple's Game Center).

In addition, for users of Android devices we create a unique user ID and for users of iOS devices
we use IDFVs to track your use of our Apps.
Although some of this information may uniquely identify your device, this information does
not identify you personally. Some legislation may treat information that uniquely identifies
your device as personal information.

2. Advertising And Application Usage Information And Data

When you use our Apps, we may collect additional information by using device identifiers that
permit identification of your device. Such information is used for advertising and analytics
purposes.
The information collected includes:
 • Which advertisements are shown;
• Length of time an advertisement is visible and the size of the advertisement;
• Advertisement response (if any), including clicks on ads;
• Application usage information, (how often you use the app, for how long you use the app,
the events that occur within the app, in-app location, in-app purchases you make and
their value, aggregated usage, performance data, life time value of user etc.).

3. Classical Personal Information

We do not collect any personal information about you through our Apps, with the sole exception
of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers
are identifiers that do not identify you personally, but may uniquely identify your device. Some
legislation (such as US) may treat such information that uniquely identifies your device as
personal information.
We may ask you to submit and we may process other non-personally identifiable information that
may be personal to you such as your age range, year of birth and gender, provided that year of
birth and gender information is collected in our Apps. We will use such information for users who
have not opted out from behavioral advertising we may use such information to display targeted
ads. You can opt out from receiving targeted ads by choosing one of the options described in the
''Opt Out'' Section of our Privacy Policy.
When you voluntarily contact us directly, we may collect information about you that you provide
us (such as your name and surname, email address). We will use such contact information only
for the purpose for which you provided it to us. We will not share this information with third
parties.
If you wish to delete your contact information that we received from you when you contacted us,
please send an e-mail to info@chess-universe.net and your contact information will be deleted
from our database.
We also collect the information about the name you give to yourself in the Application and your
rating of the Application (if any). Please do not use your real name.

4. Creation of User Account and saved chess plays

We will save the plays You made in the App for the period of 14 days. Within that timeframe
You and Your opponent will be able to see Your and Your opponents’ moves made in the
chess games. The plays will be deleted after 14 days.

You are able to create User Account within the App. By creating an User account You will be
able to store Your item collection, rating and purchases and use Your profile on multiple
devices.

You can create User Account by providing Us with email address and password. User Account
is created once you click on the activation link in the email the We will send You. Only one
device can use one User account at the time. You can use an email address that does not
reveal your identity.

We will only use your email address for the purposes of the User Account, when given to Us
in the App.

How we use your information

1. In General
We use the information we collect about you/your device to deliver services to you and to
operate our business. Such use by us and by our Partners may include:

1.1. Delivering our services: developing, delivering and improving our products, services, and
content, tailoring our products and services, providing software updates and product support,
understanding and analyzing trends in connection with usage of the Apps and websites,
administering the Apps, and customer communications.
1.2. Displaying advertisements: displaying third party advertisements in our Apps. Please see
more in Advertising Section of this Privacy Policy.
1.3. Analytics and research: understanding and analyzing trends in connection with the usage of
the Apps, gathering demographic information about our user base, data about where the App
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 Apps and
services, or to test our new game features and content. We use the data we receive from
Third Party Social Network only for internal analytics. For opting out from analytics please
visit Opt-Out Section of this Privacy Policy.

2. Push Notifications
We use push notifications to remind you about your activities within the App. You will receive
push notifications only if you are subscribed to push notifications in the App. To unsubscribe,
please use the instructions provided below:
For iOS: You will be asked to accept or refuse push notifications after an Application is
downloaded. If you do not accept, you will not receive push notifications. Please note that if you
accept, some mobile phones will allow you to disable push notifications later on by using the
settings on your mobile phone. To manage push notifications on your mobile phone please follow
these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the
icon of App; Manage the “Notifications” option by sliding it OFF or ON.
For Android and Windows: After an App is downloaded, you will automatically receive push
notifications. You can manage push notifications on your mobile phone by entering the “info
screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications
can be disabled by unchecking the “Notification” option within the App.
We collect push notification tokens in order for us to be able to determine whether you are
subscribed to push notifications. When you decide to unsubscribe from push notifications, such
push notification tokens will be deleted from our database.
For the restriction on the usage of information please see ‘Children's Privacy’ Section of
this Privacy Policy.

How we may share your information to

third parties
Other players and users
Social feature and interaction are core components of the App. Other players may, for
example, see your profile data, in-game activities and read the messages you have posted.

Partners working for us

We have partners who perform services on our behalf,such as data storage, technical or
customer support and data analytics. Processors are contractually required or bound by law
to protect your data and are only permitted to process such data in accordance with our
agreements with them.

We entered into a Data Processing agreement with Kings of Games, razvoj mobilnih iger,
d.o.o., Šmartinska cesta 152, 1000 Ljubljana, Slovenia as a data processor, in which we
agreed that Kings of Games process your information in accordance with this Privacy Policy
and applicable regulation.

Other companies and public authorities.

Based on your consent or if so required by law we may supply or disclose your data, including
personal information to third parties.

We cannot provide all services necessary for the successful operation of our products by
ourselves. We must therefore share collected information with third parties (collectively
referred to as “Partners”). We may share information that can be used to personally identify
your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for
the purposes of developing and delivering our services and conducting analysis and research
and for measuring our and our Partners’ advertising campaign performance. We may share such
information to:

- Our analytics providers: We use third party analytics for the purposes of delivering our
services, conducting analysis and research.
- Our cloud service providers: We may store information we collect from you on servers
provided by our third party cloud service providers.
- 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 Apps for free or at low cost. Please see more in Advertising Section
of this Privacy Policy.
- Advertising partner’s third party tracking provider: For some Apps we may 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. Please see more in Tracking Section of this
Privacy Policy.

We may contract with additional Partners or change existing Partners in the future to perform any
services in connection with the Apps. These changes shall be updated twice a year or promptly
in case of material changes in our data processing practices.
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, 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 info@chess-
universe.net.

How our partners may use your

information
We strive to adhere to the generally accepted industry practices regarding the collection and the
usage of information by our Partners and to limit their usage to the services they provide for us.
They adhere to this Privacy Policy, but in some cases we must use their privacy policies.
We strive to commit our Partners to using the information solely for the purposes as stated in this
Privacy Policy. Notwithstanding the above, we cannot guarantee that our Partners will adhere to
the contractual obligations or acceptable business practices. While we strive to protect the
information provided to our Partners, we have no direct control over their use of the collected
information and therefore you acknowledge that we are not liable for any third party privacy
breach and that our liability for our Partner breaches is limited to the amount we are able to
receive as indemnification from our Partners (legal costs exempted).

Advertising
When you use our Apps we may display contextual advertisements to you. In order to enable
advertising we allow our advertising partners to collect persistent identifiers (such as device ID,
IDFA, IDFV, advertising ID, IP address) that might be considered as personal information
under some legislations, but they should use it solely for the purposes of contextual advertising
(including frequency capping, fraud prevention and tracking for the attribution and billing
purposes),. For any other purposes they should use the information solely on anonymized and
aggregated basis.
For some territories, we may use and share with our advertising partners technical and
advertising and application usage information we collect from you (please see Information and
Data We Collect From You Section of this Privacy Policy) in order to enable our advertising
partner to deliver, target and optimize third party advertising in our Apps, so that the
advertisements you see are more relevant to you and are based on your app and device usage,
online behavior and interests (this is commonly referred to as online behavioral or interest based
advertising, i.e. IBA). In addition, we may use and share such information with our advertising
partners in order to target and optimize our advertising and promotions in our and other
publisher’s apps.
We will always follow applicable legislation and accepted market practices, thus we will not use
and share information for the purposes of behavioral advertising for users who did not pass the
age gate in our Apps and for those who opted-out of IBA. For more information on behavioral
advertising and our IBA providers please see Interest-Based Ads Section of this Privacy Policy.
For opting out from sharing your information and data for the purposes of behavioral advertising
please visit Opt-Out Section of this Privacy Policy.

Tracking
When you use the App, we or third parties operating the advertisement serving technology may
use information logged from your device using SDKs, cookies, web beacons and other
technologies to ensure that appropriate advertising is presented within the App and to calculate
the number of unique and repeat views of advertising.
For some of our Apps we use third party tracking and data collection tools from our service
providers for the purposes of tracking performance, ad visibility and privacy compliance of third
party SDKs in our Apps.
We use third party tracking and data collection tools from our service providers 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 tools may
use cookies, APIs, and SDKs in our Apps 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.
In addition, our Partners may use their own tracking technologies (including and without
limitation: SDKs, cookies, Web beacons, HTTP cache, local shared objects and other
technologies) in order to track impressions, clicks, installs or other advertising campaign
performance indicators for the purposes of measuring third party advertising campaign
performance.

Third party terms and conditions

Please note that your access to and ability to use and interact with the Apps may be subject to
certain third party terms and conditions and privacy policies, including but not limited to
application stores, mobile software platforms, online gaming platforms, social networking
services, statistics services providers and payment providers. You recognize and agree that We
are not liable for any such third party terms and conditions and their use of your personal
information.
Our Apps may contain links to third party websites, products, or services. For example, the Apps
may feature offers from third party advertisers or the ability to engage in transactions with such
entities. Please note that while using such third party offerings, you are using sites, products, and
services developed and administered by people or companies not affiliated with or controlled by
us. We are not responsible for the actions of those people or companies, the content of their
sites, products or services, the use of information you provide to them, or any products or
services they may offer. Our link to such third parties does not constitute our sponsorship of, or
affiliation with, those people or companies. Nor is such linking an endorsement of such third
party’s privacy or information security policies or practices or their compliance with laws.
Information collected by third parties, which may include such things as location information or
contact details, is governed by their privacy practices. These other websites or services may
place their own cookies or other files on your computing device, collect information or solicit
personal information from you. We encourage you to learn about the privacy practices of third
parties with which you interact.
We are not responsible or liable for your interaction with such third parties, the information
requests initiated by such third parties, or the subsequent use, treatment or dissemination of
information you voluntarily choose to provide to them.

Children’s privacy
We consider ourselves to be oriented towards general public. Our products and services are not
directed to, and we do not knowingly collect personal information from children under 13, with the
sole exception of persistent identifiers as described below. If we learn that we have collected
personal information other than persistent identifier of a child under the age of 13, we will take all
reasonable steps to delete the information as soon as possible. If you become aware that your
child has provided us with personal information without your consent, please contact us
at info@chess-universe.net.
The only personal information we collect from users for the purposes of offering our services are
persistent identifiers as described herein.
We will send push notifications only to users who allow us to do so in order to reengage them in
terms of using the App. You may unsubscribe at any time by following the instructions in section
Push Notifications of this Privacy Policy. Push notifications are local, contextual and sent in app
only and not from a server or in conjunction with other user information.

Opt-out
You are always free to opt out from the future collection of your personal information by Us in
accordance with this Privacy Policy by uninstalling all the Apps from each of your computing
devices.
If you are a California resident, You are, in accordance with California Consumer Privacy Act
(CCPA) always free to opt out of the sale of your personal information and data for the
purposes of interest-based advertising. You can opt out by choosing one the options
described below:

Opting Out of IBA:

1. Via third party IBA providers
For Google (AdMob) please visit https://www.google.com/ads/preferences/html/mobile-
about.html;
If you choose to opt out by following one of the third party IBA provider’s opt out mechanisms,
you should stop receiving ads based on your interest via the selected third party IBA provider,
but you may continue to receive interest-based or targeted ads via other IBA providers. For
opting out from receiving interest-based or targeted ads through all IBA providers, please see opt
out options 2. and 3. below.

2. Via “Do Not Track Settings” in mobile phone

If you choose to opt out via “Do Not Track Settings” in your mobile phone all providers of
advertising services are bound to comply with such “Do Not Track” setting, but we cannot
provide any guarantees on their behalf. By choosing “Do not track” setting, you opt out of the
sale of your personal information if you are California citizen. If you choose the opt-out option
available via our Apps, we will not share your advertising ID with advertisers for the purposes of
IBA. We provide no guarantees regarding the information provided prior to opting out. Some
providers may have additional opt-out mechanisms implemented.
If you turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your
Android device, you can restore interest-based ads by turning the settings off. When you opt out,
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 your interests. Our advertising partners may
continue to serve you ads based on other non-personal information, such as ads related to the
content of the application you are using.
Your iOS or Android mobile device may provide a “Limit Ad Tracking” or “Opt Out of Interest-
Based Advertising” setting. When you have opted out using this setting on a device, our partners
will not use information collected from that device to infer your interests, or to serve ads to that
device that are targeted based on your inferred interests.
You can find the setting for your mobile device by following the directions below, or contact your
device provider.
The reason for switching from device IDs to Advertising Identifier is that advertisers are able to
use this identifier only for advertising and for no other purpose, while users can choose to opt out
of tracking via the settings of mobile phone. Advertising Identifier is an anonymous identifier for
advertising purposes which enables users to reset their identifier or opt out of interest-based ads.
The parties participating in advertising are obligated to follow users’ choice for opting out of
tracking according to the app store guidelines.
IOS DEVICE
- iOS 7 or Higher
Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking”
setting
- iOS 6
Go to your Settings > Select General > Select About > Select Advertising > Enable the “Limit Ads
Tracking” setting
More information about the iOS setting can be found here: https://support.apple.com/en-
us/HT202074
ANDROID DEVICE
For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:
Open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”

3. Via our apps

We have created an opt-out option within some of our Apps. If you are You may choose it by
visiting ''Info Screen'', ''Settings'' and ticking the ''Disable Interest-Based Ads''. Choosing this
option will mean that you will still be served ads, but they will not be tailored to your preferences.
Should you decide to opt out of advertising altogether, you may make an in-app purchase to do
so, or you can delete the App.

In-app purchases
Our Apps 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. Any post-purchase processes are controlled by
the app store and are subject to specific terms of such app store.
For Terms of service more information on in-app purchases please see In-App Purchases
Section of the available at https://www.chess-universe.net/terms.

Protection of personal information

We have implemented: reasonable security 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.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and up to date. You can
access, check and ensure the integrity of your information as described below.

Access to personal information

We make good faith efforts to provide you with access to the personal information you provide to
us (information associated with your account). You can also request that we correct or delete
information, provided that we are not required to retain such information by law or for legitimate
business purposes.
We may decline to process requests that are unreasonably repetitive, require disproportionate
technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is
not otherwise required by local law. Access, correction or deletion requests regarding your
personal information may be submitted to info@chess-universe.net.

International transfer
We operate globally, thus we may for the purposes described in this Privacy Policy transfer your
information to our affiliated entities and/or to other third party service providers across boarder
and from your country or jurisdiction to other countries or jurisdictions around the world. Please
note, that these countries and jurisdictions may not have the same data protection laws as your
own jurisdiction, but wherever your personal information is transferred, stored or processed by
us, we will take reasonable steps to safeguard the privacy of your personal information.

Storing of information
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 them for providing our services, unless a longer retention
period is required or permitted by applicable legislation.
Storing might be different depending on the territory of collecting the information and the
applicable legislation, but we always strive to store the information only as long as it is needed
for the purposes of providing, improving or personalizing our services.
Deletion of information
When information is no longer needed, we shall delete it using reasonable measures to protect
the information from unauthorized access or use.

Special provisions for citizens of

California
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.
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 Apps 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 will delete your data as described above in “Your Rights”
Section.
Your rights
You have certain rights in connection with your personal information and how we handle it, i.e.
you have a right to access personal information we hold about you, to request the deletion of
your personal information, to opt-out of the sale of your personal information, and right to
portability of personal information. Some of these rights may be subject to some exceptions or
limitations. You can exercise these rights at any time by sending your requests regarding your
personal information to info@chess-universe.net
Your rights include:

- Right of access. You have a right to know what information we have collected about you
and in some cases to have the information communicated to you. If you wish to exercise
this right, please contact us by letting us know that you wish to exercise your right of
access and what information in particular you would like to receive. We reserve the right
to ask for reasonable evidence to verify your identity before we provide you with any
information. Please note that we may not be able to provide all the information you ask
for. Where we are not able to provide you with information that you have asked for, we
will explain to you why. We will try to respond to any request for a right of access as soon
as possible, but we will always do so within 45 days of receipt of your request and
verification of your identity. For Privacy enquiries you may contact us via info@chess-
universe.net.
- Right to deletion. You have a right to request deletion of the personal information that we
hold about you. Should you wish to do that, please contact us via info@chess-
universe.net. We reserve the right to ask to provide us additional information to verify
your identity before we can start processing your request. Once we receive all
information, we need in order to be able to identify you, we will delete your personal
information you requested us to delete as soon as possible, but we will always do so
within 45 days of receipt of your request and verification of your identity. Please note that
we may still retain some or all of that information, for example for complying with our
 legal obligations and protecting or enforcing legal rights. We may also retain your
information in an anonymized form.
- Right to opt-out of the sale of your personal information. In some cases, you may have
the right to request a restriction of the processing of your personal information. You are
always free to opt out from the future collection of your personal information by us and
our Partners by choosing one of the options, described in “Do Not Sell My Personal
Information” Rights section.
- Data Portability. In some circumstances, you have the right to request that we provide
you with the personal information which you have provided to us, so you can transfer this
information to another Business. Should you wish to do that, please contact us
via info@chess-universe.net

We may decline to process requests that are unreasonably repetitive, require disproportionate
technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is
not otherwise required by local law.
California’s “Shine the Light” law permits customers in California to request certain details about
how certain types of their information are shared with third parties and, in some cases, affiliates,
for those third parties’ and affiliates’ own direct marketing purposes. Under the law, we will
provide California customers certain information upon request (“Right to access”) or permit
California customers to opt out of, this type of sharing (“Right to opt-out of the sale of your
personal information”).
If you are a California resident and wish to obtain information about our compliance with this law,
please contact us via info@chess-universe.net. We may request information from you to verify
your identity. Please note that We are not required to respond to requests made by means other
than through the provided email address.

Changes to our privacy policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the
amended version will supersede this version of our Privacy Policy. Use of information we
collect is subject to the Privacy Policy in effect at the time such information is collected. We
will take reasonable steps to draw your attention to any changes in our Privacy Policy.
However, to be on the safe side, we suggest that you read this document each time you use
the website to ensure that it still meets with your approval. The most current version of the
Privacy Policy will govern our use of your information and will be available at https://www.chess-
universe.net/privacy.

Should you request so by informing us on info@chess-universe.net, we will send you all the
updates of this Privacy Policy or previous versions of this Privacy Policy to your e-mail. We will
also inform you about any material updates of our Privacy Policy with an in-app banner and a
link.

English language
By accepting this Privacy Policy you acknowledge that you are proficient in the English language,
or have consulted with an advisor who is sufficiently proficient in English, so as to allow you to
understand the terms of this Privacy Policy.

Privacy questions
If you have questions or concerns about Brainiac Games’ Privacy Policy or information
processing, please contact us through info@chess-universe.net.

Version 7.0.

Last revised in August 2021

Brainiac Games LTD

EEA Privacy Policy
As used in this Privacy Policy, “Brainiac Games”, “We”, “Us” or “Our”, refers to Brainiac Games
LTD, with its registered address at 2nd Floor 2 Woodberry Grove, North Finchley, London,
United Kingdom, N12 0DR.

This Privacy Policy is part of and incorporated by reference into the Terms of Service (the
“Terms”) governing the use of all “Brainiac Games” branded software applications (the
“Application/s”, or “ App/s”), which may operate on any type of computing device (including
without limitation, a mobile device), and applies to your use of the Applications
and/or www.chess-universe.net, and/or URL which may replace it or which may be added to
the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree
to the collection, use and disclosure of your information (including personal information) in
accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with
your information (including personal information) any time you are in contact with us or use the
Applications or the Websites.

We take the privacy of our users and data security very seriously and believe in the right of our
users to know which data is collected and for what purpose. We therefore strive to make our
actions transparent and allow our users to control the collected data and remove it if they so
wish, and we take all reasonable precautions to prevent unauthorized access to this data.

We value your privacy and will never sell your information to anyone without your knowledge
and consent.

When accessing to our website and/or using any of our Apps you consent to the collection,
transfer, manipulation, storage, disclosure and other uses of your information as described in
this Privacy Policy. Irrespective of which country you are based in, you authorize Brainiac Games
to use your information in, and as a result to transfer it to and store it in United Kingdom and any
other country where Brainiac Games, or any third party service providers acting on its behalf,
operates. Privacy and data protection laws in some of these countries may vary from the laws
in the country where you are based, but we will always take appropriate steps to safeguard the
privacy of your personal information.

Only when the transfer is based on one of the following safeguards, we will transfer your personal
information:

1. If a country outside of EEA ensures an adequate level of protection in accordance with

EEA data protection legislation.
2. If we have entered into standard contractual clauses with our contractual partner that are
adopted by Commission of European Union in accordance with EEA data protection
legislation and are deemed to offer sufficient safeguards with respect to the protection of
the privacy rights.

Please read this Privacy Policy in order to learn more about the data we collect, what do we use
it for and how we protect your privacy.

Collected information
We may collect any or all of the information that you give us together with data about your use
of the website and applications, but we will primarily use the collected data to provide you with
a satisfactory service and enhance your Brainiac Games experience. We use information for (i)
delivering and improving our services and products, providing updates, technical
troubleshooting, understanding and analyzing trends in connection with usage of the apps, and
administering the apps; (ii) analytics and research in a way that we use your information for
understanding and analyzing trends in connection with usage of the apps, gathering
demographic information about user base, data about where download of our app was
performed, and we might use created reports and analysis for the purpose of business
intelligence; (iii) security in a way to use your data for enhancing the safety and security of our
products and services; (iv)providing customer support to you and to respond to your inquiries;
and (v) our legal obligation when we are required to do so by law.

We use different SDKs from our business partners and they share collected information with us.
For detailed information, see Analytics section below.

Collection of device and technical information

We might collect the data necessary for you to use our app and for us to maintain and analyze
the functioning of the app and to personalize the content of the app.

We automatically obtain certain information about your computing device, including your
Location for providing you with relevant Ads. We also obtain information about your account and
game progress, such as (types of chess game played, name and/or types of opponents, chess
match score sheet, users chess moves and strategy, time played, level progression, including
level completed, level failed, level started other similar statistical or analytical data.; technical
device information (e.g. device model and name, operating system name and version, unique
device identifier (IMEI), advertising ID, MAC address). Although some of this information may
uniquely identify your device, this information does not identify you personally. Some legislation
may treat information that uniquely identifies your device as personal information.

Collection of classical personal information

We may also collect personally identifiable information about you (such as your name and
surname, email address, birth year, player name and password), as well as non-personally
identifiable information (such as age range and gender) that you provide us by contacting us
directly. We might also collect the messages You sent to Us (such as chat logs and player
support tickets).

We will only use the contact information you provide to us (for example, your name and email
address) for the purpose for which you provided it to us. We will not share this data with third
parties.

If you wish to delete your contact information that we received upon your specific email inquiry,
please send an e-mail to info@chess-universe.net. and your e-mail will be deleted from our
database.

Creation of User Account and saved chess plays

We will save the plays You made in the App for the period of 14 days. Within that timeframe You
and Your opponent will be able to see Your and Your opponents’ moves made in the chess
games. The plays will be deleted after 14 days.

You are able to create User Account within the App. By creating an User account You will be
able to store Your item collection, rating and purchases and use Your profile on multiple devices.

You can create User Account by providing Us with email address and password. User Account
is created once you click on the activation link in the email the We will send You. Only one device
can use one User account at the time. You can use an email address that does not reveal your
identity.

We will only use your email address for the purposes of the User Account, when given to Us in
the App.

What is collected data used for

Our use of information collected from you
We use the information collected from you for delivering and promoting our services, for
advertising, internal analysis and research to improve the services. You hereby allow us to
collect, process and store the data as stated in this Privacy Policy. We use the information we
collect about you/your computing device to deliver services to you and to operate our business.
Such use by us and by our Partners may include:

1. Delivering our services: developing, delivering and improving our products, services, and
content, tailoring our products and services, providing software updates and product
support, understanding and analyzing trends in connection with usage of the Applications
and the Websites, administering the Applications and the Websites, and customer
communications, develop and improve the App and player experience, manage our
relationship with you, provide social features as part of the App, customize your App
experience, respond to your comments and questions and provide player support,
provide you our offers in the App as well as in other websites and services, and by email,
send you related information, such as updates, security alerts, and support messages,
enable you to communicate with other players, create accounts and allow you to play our
games and use the App, to operate, maintain and provide all the features and services
found on the App now and in the future, verify and confirm payments, send you App-
related communications, to provide support and to help you solve any technical
difficulties.

2. Analytics and research: Understanding and analyzing trends in connection with the
usage of the Applications and the Website, auditing, learning about user behavior within
the Applications and the Websites (how often you use the Application/Website, the
events that occur within the Application/Website, aggregated usage, performance data
etc.), gathering demographic information about our user base, data about where the
Application was downloaded from. For information that can be treated as personal
information in some legislation, we use only device identifiers. We use the data we
receive from Third Party Social Network for internal analytics.

3. Advertising: We offer our Apps 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 that assist
us in delivering advertisements to you. When you use our apps we rely on our legitimate
interest to show contextual advertisements to you. Before sharing any information with
our advertising partners for the purposes of interest-based advertising, we will always
ask for your consent. When you use our Apps we show contextual advertisements to
you. In order to enable advertising we allow our advertising partners to collect advertising
identifiers that are considered as personal information under some data protection
legislations, but they should use it solely for the purposes of contextual advertising. For
any other purposes they should use the information solely on anonymized and
aggregated basis, this means in a way that cannot be tracked back to your device.

You have an option to withdraw or manage 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 App settings and clicking the “personalized ads” button and
manage your preferences. 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. Push Notifications: We use push notifications to remind you about your activities within
the App. You will receive push notifications only if you are subscribed to push notifications
in the App. You can always unsubscribe from push notifications, please use the
instructions provided below.
For iOS: You will be asked to accept or refuse push notifications after an Application is
downloaded. If you do not accept, you will not receive push notifications. Please note
that if you accept, some mobile phones will allow you to disable push notifications later
on by using the settings on your mobile phone. To manage push notifications on your
mobile phone please follow these instructions: Open your Settings menu and tap
 “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option
by sliding it OFF or ON.
For Android: After an App is downloaded, you will automatically receive push
notifications. You can manage push notifications on your mobile phone by entering the
“info screen” on the homepage of the App and choosing the “Settings” option. Here, push
notifications can be disabled by unchecking the “Notification” option within the App.

When you decide to unsubscribe from push notifications, such push notification tokens
will be deleted from our database.

5. In-App Purchases: Our Apps 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.
Any post-purchase processes are controlled by the app store and are subject to specific
terms of such app store. Please review privacy policy and terms of service of your app
store. For more information on in-app purchases in Our Apps please see In-App
Purchases Section of our Terms of Service.

WHO CAN SHOW PERSONALISED ADS TO ME?

Please see the following list of advertising providers that are allowed to show interest-based
advertising and review their data processing practices, including the technologies they use for
the purposes of interest-based advertising:

- Google(AdMob) https://support.google.com/admob/answer/7665968; https://support.go

ogle.com/dfp_premium/answer/9012903;
https://support.google.com/admob/answer/2753860#Interest_based
- Facebook Audience
Network https://www.facebook.com/about/privacy/update?ref=old_policy
- Facebook Ad
Campaigns https://www.facebook.com/about/privacy/update?ref=old_policy
- AdMost https://resources.admost.com/privacy-policy/
- Unity Ads https://unity3d.com/legal/privacy-policy
- Inmobi https://www.inmobi.com/privacy-policy/
- Add4Game https://ad4game.com/privacy/
- Google Adx https://policies.google.com/technologies/ads?hl=en-US
- Applovin https://www.applovin.com/privacy/
- ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-
privacy-policy/#step-2
- adtrue https://publishers.adtrue.com/terms-and-conditions
- Mintegral https://www.mintegral.com/ru/privacy/
- Adcolony https://www.adcolony.com/consumer-privacy/
- Vungle https://vungle.com/privacy/
- My.com https://legal.my.com/us/mytarget/privacy/

You can withdraw your consent to sharing your personal information for the purposes of
interest-based advertising at all times by going to the app settings and clicking the interest-
based ads button where you can manage your preferences.
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.

Storing of information
We store your information for as long as needed to provide you with our services and for as long
as we are legally obliged to do so. 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 them for
providing our services and in any event no later than five (5) years after your interaction with our
products has ceased.

We store personal information as long as it is needed for the provision of our services. Traffic
information is erased or made anonymous when it is no longer needed for the purpose of the
transmission or, in the case of payable services, up to the end of the period during which the bill
may lawfully be challenged or payment pursued. Location information is stored to the extent and
for the duration necessary for the provision of a value-added service. Direct marketing and
provision of value-added services information (including traffic information used for these
purposes) is stored as long as the same is necessary for the provision of these activities, or up
to the time when a user opts out from such use in accordance with this Privacy Policy. Other
information is stored for as long as we consider it to be necessary for the provision of our
services. This section shall not prevent any technical storage or access to information for the
sole purpose of carrying out the transmission of a communication or as strictly necessary in
order for us to provide the service you requested.

Deletion of information
When information is no longer needed, we shall delete it using reasonable measures to protect
the information from unauthorized access or use.

Protection of personal information

We have implemented: reasonable security 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.

Sharing your personal information

Other players and users
Social feature and interaction are core components of the App. Other players may, for example,
see your profile data, in-game activities and read the messages you have posted.

Partners working for us

We have partners who perform services on our behalf,such as data storage, technical or
customer support and data analytics. Processors are contractually required or bound by law to
protect your data and are only permitted to process such data in accordance with our
agreements with them.

We entered into a Data Processing agreement with Kings of Games, razvoj mobilnih iger, d.o.o.,
Šmartinska cesta 152, 1000 Ljubljana, Slovenia as a data processor, in which we agreed that
Kings of Games process your information in accordance with this Privacy Policy and applicable
regulation.

Other companies and public authorities.

Based on your consent or if so required by law we may supply or disclose your data, including
personal information to third parties.

We cannot provide all services necessary for the successful operation of our products by
ourselves. We must therefore share collected information with third parties (collectively referred
to as “Partners”). The only personal information we collect from users for the purposes of offering
our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, IP
address). Such persistent identifiers are used and shared with third parties only to place
contextual advertisement (including frequency capping, fraud prevention and tracking for the
attribution and billing purposes), to authenticate users of or personalize the content on Apps, to
maintain or analyze the functioning of the Apps, personalize the content of the App (such as
sending push notifications), to perform network communications to protect the security or
integrity of the user or the App, to ensure legal or regulatory compliance.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and up to date. You can
access, check and ensure the integrity of your information as described below.

Information collection relating to children

We consider ourselves to be oriented towards general public and even though our products and
services are not directed to, and we do not knowingly collect personal information from, children
under the age of digital consent according to EEA data protection legislation, with the sole
exception persistent identifiers as described herein. If we learn that we have collected personal
information of a child under the age of digital consent according to EEA data protection
legislation, we will take all reasonable steps to delete the information as soon as possible. If you
become aware that your child has provided us with personal information without your consent,
please contact us at info@chess-universe.net.

Opt-out
You are always free to opt out from the future collection of your personal information by Brainiac
Games in accordance with this Privacy Policy by uninstalling all the Applications from each of
your computing devices and discontinuing use of the Websites.

Third Parties terms of service

We may provide links and/or connections to third-party websites or services from our website
and our mobile applications. We are not responsible for the practices employed by websites or
services linked to or from Brainiac Games website or applications, including the information or
content contained therein.

Please remember that when you use a link to go from the Brainiac Games website www.chess-
universe.net or applications to another website or service, our Privacy Policy does not apply to
third-party websites or services. Your browsing and interaction on any third-party website or
service, including those linked on our website or in our applications, are subject to that third
party’s own rules and policies. We are not responsible for the privacy practices or content of
these third-party sites.

Legal basis for processing personal

information
Our legal basis for collecting and using the personal information will depend on the
personal information concerned and the specific context in which we collect it. However,
we will normally collect personal information from you only where: (i) we have your consent
to do so, (ii) where we need the personal information to perform a contract with you (e.g.
to deliver a service you have requested), or (iii) where the processing is in our legitimate
interests (and not overridden by your data protection interests or fundamental rights and
freedoms). In some cases, we may also have a legal obligation to collect personal
information from you, or may otherwise need the personal information to protect your vital
interests or those of another person.

Support
If you have further questions or any concerns regarding privacy with Brainiac Games and have
already signed up in Brainiac Games, the best way to get the answers is to contact our DPO,
Duško Pavasović by sending an email to: info@chess-universe.net (subject 'DPO''). Should you
have any concerns or complaints our DPO is not able to solve, you have the right to lodge a
complaint with a supervisory authority, Information Commissioner's Office, by telephone on 0303
123 1113 or contact us via live chat at https://ico.org.uk/global/contact-us/ .

If you submit a support request, we may receive your email address and other information you
provide related to your support request (“Support Information”). We use Support Information only
to provide support to you. We don’t rent, sell or share your email address unless we have your
express consent and in the following circumstances:

1. We may share your Support Information with our support providers, but only for the
purpose of providing support to you.
2. We may share your email address and Support Information to enforce compliance with
our mobile application license agreements and user agreements, to respond to legal
requirements, when legally required to do so, and at the request of governmental
authorities.
3. We may share your email address and Support Information with a successor entity or in
connection with a corporate merger, consolidation, sale of assets or other corporate
reorganization provided that use of your email address is otherwise in compliance with
this Privacy Policy.

Your data protection rights

You have the following data protection rights:

1. To access, correct, update or request deletion of your personal information. You may do
so by contacting us at info@chess-universe.net

2. To object to the processing of your personal information ask us to restrict processing of

your personal information or request portability of your personal information. You may do so
by contacting us at info@chess-universe.net

3. If we are processing your personal information with your consent, you can withdraw your
consent at any time. Withdrawing your consent will not affect the lawfulness of any processing
we conducted prior to your withdrawal, nor will it affect the processing of your personal
information conducted pursuant to lawful processing grounds other than consent. You may do
so by contacting us using the details at info@chess-universe.net.

4. You have the right to file a complaint with a data protection authority about our collection
and use of your personal information. For more information, please contact your local data
protection authority.

You can control and limit the type of personal information we collect and process about you in a
number of ways. For example, you can disconnect your social media account(s) from our games
or control your social media privacy settings to limit the information shared with us. You can also
reset your mobile advertising identifier or limit ad tracking altogether using the settings on your
phone. You can also limit or disable the use of cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to exercise their data
protection rights in accordance with applicable data protection laws.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the
amended version will supersede this version of our Privacy Policy. Use of information we collect
is subject to the Privacy Policy in effect at the time such information is collected. We will take
reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be
on the safe side, we suggest that you read this document each time you use the website to
ensure that it still meets with your approval.

If we make changes in the way we use your email address, we will notify you in advance of
posting by email. Such modifications will become effective on the date set forth in the email.

English language
By accepting this Privacy Policy you acknowledge that you are proficient in the English language,
or have consulted with an advisor who is sufficiently proficient in English, so as to allow you to
understand the terms of this Privacy Policy.

Privacy questions
For general information please feel free to contact us via contacts provided on www.chess-
universe.net and for privacy question via info@chess-universe.net

Version 7.0.

Last revised in August 2021

Brainiac Games LTD