May, 24, 2021
1. General Terms
These terms apply to the use of games and other products developed by BRAMBLINGTECH, LLC (‘BRAMBLINGTECH’ / ‘we’ / ‘us’). Our registered office is at: off. 402, 33A, Admiralskyi Ave, Odesa, Ukraine, 65059. We are a company registered in Ukraine, with company number 44356203.
BRAMBLINGTECH, LLC understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, bramblingtech.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- What Does This Policy Cover
- What is Personal Data
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- Your Rights
Under the GDPR, you have the following rights, which we will always work to uphold:
c) The right to access the personal data we hold about you.
d) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details to find out more.
e) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details to find out more.
f) The right to restrict (i.e. prevent) the processing of your personal data.
g) The right to object to us using your personal data for a particular purpose or purposes.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
j) Rights relating to automated decision-making and profiling.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using our details.
- Data We Collect
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data.
Name, Email address, Business name, Job title, Profession, Information about your preferences and interests, IP address, Web browser type and version, Operating system, A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
- How We Use Your Personal Data
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, or because it is in Our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring Our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by informing us by emil, phone or post or clicking on unsubscribe in any of our emails).
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on Our services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using our details.
- How Long We Keep Yuor Personal Data
we will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): 2 Years from the date you last engaged with us;
- How and Where Do You Store or Transfer My Personal Data?
we may store or transfer some or all of your personal data. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would under the GDPR.
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, Our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
- Share of Personal Data
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- Personal Data Control
1.1 In addition to your rights under the GDPR, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails, at the point of providing your details and by managing your Account).
- Withhold Information
You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
- Access Personal Data
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown below.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
we will respond to your subject access request in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for us to improve our services for you and future visitors. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. we have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google Analytics, Heap Analytics & AutopilotHQ. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
- Contact us
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Telephone number: +37 281 993 282.
Postal Address: off. 402, 33A, Admiralskyi Ave, Odesa, Ukraine, 65059.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.