Privacy Policy

At Bravus Games, we want users to clearly understand what happens to their personal data.

This Privacy Policy explains how personal information may be processed through:

• www.bravusgames.com;
• our communications;
• video games published under the Bravus Games brand;
• and services related to those games.

This information will be updated whenever the services or technologies actually used change.

• Controller: Higinio Suárez de Rada
• Trading name: Bravus Games / Bravus Games Studio
• Tax ID (NIF): 51104005Y
• Address: C/ Serrano, 145, 28002 Madrid, Spain
• Email: hello@bravusgames.com

This policy may apply to:

• website users;
• people who contact Bravus Games;
• players;
• people requesting support;
• users of future player accounts;
• and other individuals whose data may lawfully be processed in connection with our services.

The website currently does not provide user accounts or forms that store information directly in our own database.

If you contact:

hello@bravusgames.com

we may receive:

• your name;
• email address;
• the content of your message;
• attachments;
• technical information you choose to provide;
• any other information you voluntarily include in your communication.

Please do not send sensitive personal information that is not necessary for us to deal with your request.

As with most web services, certain infrastructure providers may process technical data required to deliver, protect and operate the website.

Depending on the infrastructure actually used, this information may include:

• IP address;
• access date and time;
• browser;
• operating system;
• basic device information;
• requested URL;
• technical logs;
• security events.

The actual processing will depend on the effective configuration of the services used.

This clause does not mean that tracking technologies are being used where they have not actually been implemented.

Depending on the context, personal data may be processed for the following purposes:

Communications

To respond to enquiries, messages and requests.

Support

To investigate bugs or issues reported by players.

Operation of future games

Where required by a particular title, data may be processed for features such as:

• accounts;
• progress;
• synchronisation;
• leaderboards;
• multiplayer;
• purchases;
• support;
• security.

Security and abuse prevention

To detect:

• fraud;
• unauthorised access;
• manipulation;
• abusive behaviour;
• technical incidents.

Product improvement

If analytics services are lawfully introduced, we may obtain aggregated or individual information, depending on the tool used, in order to understand performance and improve our games.

Legal compliance

To comply with legal obligations, authority requests or the exercise of legal rights.

The legal basis will depend on each particular processing activity.

It may include:

• performance of a contract or pre-contractual measures;
• the user's consent;
• compliance with a legal obligation;
• legitimate interests, where applicable and where the user's rights do not override those interests.

Each game may use different technologies and services.

Depending on the title, processing may involve:

• user identifiers;
• account or profile data;
• email address;
• device identifiers;
• advertising ID;
• game progress;
• gameplay statistics;
• purchases;
• advertising interactions;
• crashes;
• performance data;
• notifications;
• approximate country or region;
• support data;
• anti-fraud data;
• information required for online features.

The fact that a category is mentioned here does not mean that it is currently collected or that it will be collected by every Bravus Games title.

Before each app is released, this policy and the information provided through the relevant app store will be reviewed to reflect the app's actual behaviour.

Our games may in the future integrate specialised providers.

These may include providers of:

• hosting;
• databases;
• authentication;
• analytics;
• advertising;
• attribution;
• storage;
• crash reporting;
• communications;
• notifications;
• payments;
• cloud services;
• security.

Providers will only be identified as active providers in this policy when they are actually used.

Where appropriate, the services used by each released game and their purpose will be disclosed.

Some games may in the future be monetised through advertising.

Where advertising is used:

• the relevant platform will be documented;
• personalised or non-personalised advertising will be identified where applicable;
• use of advertising identifiers will be reviewed;
• consent will be obtained where legally required;
• Google Play and Apple declarations will be updated accordingly.

This section does not mean that advertising is currently being used.

Some games may use tools designed to:

• analyse sessions;
• detect errors;
• measure performance;
• obtain usage statistics;
• study retention;
• improve the user experience.

Where such tools are used, the relevant provider and actual processing will be identified.

Where games include in-app purchases, payments will normally be processed by the relevant platform, such as Google Play or Apple.

Bravus Games may receive transaction-related information necessary to manage:

• purchased content;
• restorations;
• support issues;
• fraud prevention.

We will not necessarily receive the user's complete financial information.

If a game allows users to create an account in the future, users will be informed about:

• required data;
• purposes;
• retention;
• authentication;
• account deletion;
• related processing.

Bravus Games may publish video games intended for a general audience.

Where a game may be used by children, its design, advertising, SDKs and data processing will be reviewed specifically before release.

Where consent is required and Spanish rules regarding children's consent apply, the necessary measures will be adopted.

We will not knowingly request unnecessary personal information from children.

Personal data will not be sold to third parties.

Data may only be disclosed or made available to third parties where there is a valid legal basis, for example:

• providers necessary to operate the service;
• distribution platforms;
• support providers;
• competent authorities;
• professional advisers where legally required.

Providers acting on behalf of Bravus Games will be subject to the relevant contractual obligations where required.

Some technology providers may operate outside the European Economic Area.

Where an international transfer of personal data takes place, an appropriate legal mechanism will be used, such as:

• an adequacy decision;
• Standard Contractual Clauses;
• other safeguards recognised by applicable law.

Personal data will be retained only for as long as necessary for the relevant purpose.

For example:

Enquiries

For the time necessary to respond to and manage the request and subsequently for as long as required to address potential legal liabilities.

Account data

For as long as the account remains active and afterwards for the applicable legal retention periods.

Technical data

For the retention periods defined by each provider and configuration, applying data minimisation principles.

Legal obligations

For the period required by applicable law.

Bravus Games will adopt reasonable technical and organisational measures, taking into account the level of risk, to reduce situations such as:

• unauthorised access;
• loss;
• alteration;
• disclosure;
• destruction.

Security measures will be reviewed as the complexity of our services increases.

Where applicable, you may exercise your rights to:

• access;
• rectification;
• erasure;
• objection;
• restriction;
• portability;
• withdrawal of consent.

Contact:

hello@bravusgames.com

Please include the information necessary to identify and handle your request.

We may request additional information only where necessary to verify your identity.

If you believe your data protection rights have been infringed, you may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD).

Bravus Games does not currently declare that it carries out automated decision-making producing significant legal effects on users.

If this changes, users will be informed in accordance with applicable law.

Bravus Games does not sell users' personal data.

We will update this policy whenever there are changes to:

• our games;
• the personal data processed;
• our providers;
• monetisation;
• features;
• applicable law;
• Google Play or Apple policies.

The latest update date will always be displayed at the beginning or end of the document.