PRIVACY POLICY

This Privacy Policy is effective as of 1 April 2019 and was published for the last time on 1 April 2019.

LSSIYCE LEGAL INFORMATION

In accordance with the obligations provided for in Law 34/2002, regarding services of the Information Society and Electronic Commerce (hereafter LSSIYCE), INDUSTRIAL BREINCO S.A. declares that the domain name www.breincosmartplay.com is owned by INDUSTRIAL BREINCO S.A., with tax identification code (CIF) A08946238 and address at Crta. Cardedeu a Dosrius, Km.6.5 08450 LLINARS DEL VALLÈS (Barcelona).

INDUSTRIAL BREINCO S.A. is duly registered in the Commercial Registry of Barcelona, in sheet 95 of volume 6,037 of the archive, book 5,330 of the 2^nd section, 1^st enrolment of page number 71,216, now page number B-73,993.

INDUSTRIAL BREINCO S.A. shall not assume any liability for the misuse, improper or unlawful use of the information on its web pages.

Within the limits set by the law, INDUSTRIAL BREINCO S.A. shall not assume any liability for the lack of veracity, integrity, updating and accuracy of the data and information contained on its web pages. The content and information on the web pages of INDUSTRIAL BREINCO S.A. are created by professionals who are suitably qualified for the exercise of their profession. However, the content and information do not bind the aforementioned company, and do not constitute opinions, tips or legal advice of any kind, as they are merely a service provided for informational and informative purposes only.

The web pages of INDUSTRIAL BREINCO S.A. may contain links to other third-party web pages. Therefore, INDUSTRIAL BREINCO S.A. cannot assume any liability for the contents that may appear on such third-party web pages. The texts, images, sounds, animations, software, and other contents included in this website are exclusively owned by INDUSTRIAL BREINCO S.A. or its licensees. Any act of transmission, distribution, transfer, reproduction, storage, or total or partial public communication, must have INDUSTRIAL BREINCO S.A.’s express consent.

URBANENJOY S.L. is duly registered in the Commercial Registry of Barcelona, in sheet 83 of volume 45,977 of the archive, page number 505,751, and enrolment: 1, date of enrolment: 19 June 2017.

The web pages of URBANENJOY S.L. may contain links to other third-party web pages. Therefore, INDUSTRIAL BREINCO S.A. cannot assume any liability for the contents that may appear on such third-party web pages. The texts, images, sounds, animations, software, and other contents included in this website are exclusively owned by URBANENJOY S.L. or its licensees. Any act of transmission, distribution, transfer, reproduction, storage, or total or partial public communication, must have URBANENJOY S.L.’s express consent.

The application and content of BREINCOSMARTPLAY (‘BSP’) are controlled by INDUSTRIAL BREINCO S.A. and URBANENJOY S.L. (‘DEVELOPERS’), as set out in our collaboration agreement.

Your privacy is very important to us; therefore, this document includes our Privacy Policy.

Herein we explain how we use, store and share the information we collect. Please read this document.

If you wish to access, modify, cancel, limit the processing of or reject the provided data, as well as transfer the data, you can address yourself to: Crta. Cardedeu a Dosrius, Km.6.5 08450 LLINARS DEL VALLÈS (Barcelona) or send an email to breincosmartplay@breinco.com.

If you do not wish the ‘DEVELOPERS’ to use, store or share the information collected in the manner described in this Privacy Policy, you may not be able to play our games.

The ‘DEVELOPERS’, including their subsidiary or affiliate companies, or our collaborators, only use geolocation device access data and game start QR code reading account, to create game statistics, improve our business model and promote and develop web services (collectively referred to as ‘SERVICES’) in accordance with this Privacy Policy, but under no circumstances do we access any device information linked to the user.

All our ‘SERVICES’, whether used on mobile devices, tablets or other platforms, are subject to this Privacy Policy.

When you use our ‘SERVICES’, you accept our Privacy Policy.

When you download the application(s) for the first time, you will be asked to accept our Privacy Policy.

If you do not agree with our Privacy Policy, you may reject it, but you will not be able to access the ‘BSP’ application(s).

If you have any questions or comments with regard to our Privacy Policy and/or practices, check the CONTACT US section.

HOW WE COLLECT AND USE YOUR INFORMATION

The ‘DEVELOPERS’ collect the following information in the following manner:

• You access the application(s) and play with our games.

We only register the number of times the application is activated and the geographic location where it occurs.

We only use this information for statistics, to improve our games and the gaming experience.

The application download, activation and game are completely anonymous. We never request any type of personal identification, account, email address or personal data.

Access to the camera and audio system of your device is only requested to provide you with the possibility of taking photos and/or videos, as well as listening to audio related to the suggested games.

• You view the information sent by us related to the application’s functionality and content.

We will only know the number of communications viewed.

Viewing is completely anonymous. We never request any type of personal identification, account, email address or personal data.

• You make suggestions or questions through our social media channels, websites or by email.

We will only use this information to provide you support, communicate with you and respond to any request or question you send through our customer service.

Also, to detect and correct errors.

We will never collect any information sent outside of our ‘SERVICES’ functionality, even through email or text messages.

The ‘DEVELOPERS’ will only use and store your information during the period necessary to comply with all the purposes described in this Privacy Policy, in accordance with applicable laws. We want to inform you that a longer retention period may be required to resolve arguments or respond to regulatory or police requests. In these cases, the collected information will be used and stored until the request is closed.

We reserve the right to inform police agencies of activities that we consider illegal, in good faith. We will investigate or take steps to counter illegal activity, suspected abuse or unauthorised use of the ‘SERVICES’, or to protect the property or safety of others. We may also disclose your information if any law or court order in the entire world demands it, if the information is related to a real or threatened damaging conduct.In this case, we consider the applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.

HOW WE ENSURE THE SAFETY AND CONFIDENTIALITY OF YOUR PERSONAL INFORMATION

The only personal information we collect comes from the suggestions or questions you make through our social media channels, websites or by email.

We have implemented safety measures to protect and preserve data safety and use collected personal information correctly.We take and oblige third parties to take reasonable precautions to protect your personal information against loss, misuse, unauthorised disclosure, modification and destruction. Nevertheless, please remember that we cannot guarantee that data transfer through the Internet or any wireless network will be 100% secure. As a result, even though we make every effort to protect your information, we cannot guarantee the safety of your information and we do not assume responsibility for the unauthorised use or access to your information which is not under our control.

If there is a security breach related to your personal information, we will inform you immediately in accordance with local regulations related to the notification of information violations, and we will take commercially reasonable actions to correct said violation. We encourage parents to instruct their children regarding privacy and the way they use their information on the Internet. Children should never reveal their name, address or telephone number, or any personal information, without prior permission from their parents. People under 18 years of age are considered children. Under-age users must not send the ‘DEVELOPERS’ personal information through any channel. Parents must ensure their children’s right to privacy. If you are a parent of an under-age child and believe your child has provided us with information, get in touch with us and we will eliminate the information from our system. To preserve your information’s confidentiality, we must ensure that we identify it correctly. For this reason, send us a copy of an official document so that we can check your identity. This copy will be safely destroyed within two months after receipt and closure of your request. Our team will analyse your request and will respond within one month, unless your request requires additional research. You will be specifically informed if this is the case. We remind users that they have the right to present a complaint before the European Data Protection Supervisor. In the case that we perform substantial changes to our Privacy Policy, it will be published again on our websites and applications stating the date the modifications were made at the top of the page. Therefore, review this Privacy Policy every once in a while, to know when changes are performed. Continued use of our ‘SERVICES’ after said changes means you accept these changes. If you do not accept the changes, you may choose to not use our ‘SERVICES’. If you want more information on recent changes, send your request to breincosmartplay@breinco.com with the subject ‘Information on changes’. 

If our company or any business line is sold (including related assets) our information may be transferred to the buyer.

 Any dispute that may arise from the use of our ‘SERVICES’ will be submitted to the courts concerned. CONTACT US If you have any questions or comments with regard to our Privacy Policy and/or practices, get in touch with us by email at breincosmartplay@breinco.com.