PRIVACY POLICY
(Last Updated: June 2026 with effective date 25th June 2026)
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy applies to Easybrain’s games, apps, websites and related services (together, the “Services” or “games”, “apps”, “websites” for individual categories). This Privacy Policy explains how we, and affiliated companies (collectively, "Easybrain" or "we", "us", "our") collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.
The data controller is Easybrain Ltd, with a registered address at 335, 28th October Avenue, Trilogy Limassol Seafront, West Tower, Floor 14th, 3106, Limassol, Cyprus.
1. INFORMATION WE COLLECT AND HOW
This Privacy Policy applies across our entire portfolio of apps and services. While using our Services, we may process certain personal data or personal information that can be used to identify you ("Personal Data", or "data" or "information" or "Personal Information"). For details specific to individual apps, including data collection and sharing practices, you may also refer to the privacy labels in the Apple App Store or the Data Safety section in Google Play.
The Personal Data we may process includes:
Basic Identifiers
such as mobile device ID’s, advertising ID (iOS Identifier for Advertiser, Android Advertiser ID), internal User ID’s and IP address.
Commercial Information
such as in-app purchase history and subscription details.
Device Information
type and model of the device, operating system and version, screen resolution, application version, preferred language settings, time zone, connection type, and estimated internet speed as calculated by your browser. We may also receive approximate demographic signals, such as age range, from app distribution platforms which are aggregated indicators and do not include a specific date of birth.
Usage Information
information about how you interact with our Services, such as date and time of usage, features used, interaction with advertisements, and data generated during service use (e.g., game progress, levels completed, tournament participation).
Diagnostics
information that is collected about how our apps perform, such as crash logs, app performance data such as launch time, energy use and other diagnostic data collected for the purposes of measuring technical diagnostics related to the app.
Location Information
When you download and use our Services, we automatically detect your general location, namely country and state through your IP address. We may collect, with your consent if applicable, other location information through your IP address, such as the city you are in.
Media and other files
If you choose to upload media or files, either when contacting support or when using optional features, the app will request access to those files. If you choose to use features involving photos, we will request access to your camera. These permissions are optional and do not limit access to the app’s main functionality. Any media used within these optional features stays on your device and is only shared with us if you deliberately submit it for support.
Contact Information
such as your name and email address when you provide it to us directly through an email or online form, the support feature embedded in our Services, or through another form of inquiry.
Reviews and Communications
We will also process personal data and metadata of public reviews in App Stores, comments or contents of communication you have with us.
User-Generated & Community Content
Content you post or upload on social networks, platforms such as the App Store and Google Play Store, or direct contact with our social media sites, which may include your name, social media username, image, likeness, voice, and other identifiable information available in such user generated content. Our legal basis for this processing is your consent, which we obtain directly via the medium (e.g., email, social networks, or social platforms) used to share the content.
Cookies and similar data collection technologies
We, along with our third-party advertising networks, analytics partners, and service providers, may use cookies and similar technologies—such as mobile “SDKs”, pixels, and web beacons—to enhance and personalize your experience with our Services. These technologies help us deliver targeted advertisements, analyze performance, improve functionality, ensure security, and prevent fraud.
Some of these technologies enable the synchronization of behaviors and preferences across different platforms, devices, and apps. This allows us to tailor content, features, and advertisements to your interests. In addition, we and certain advertising networks may access your inventory of installed apps to avoid advertising already installed apps. In addition, they play a critical role in identifying and preventing unauthorized access, fraudulent activities, and other security risks to protect both you and our Services.
If you'd like to opt-out from having advertisements personalized in this way on your mobile device, please see the ‘Opt-out of targeted advertising’ section below.
Please note that, while your browser settings may allow you to transmit a “Do Not Track” signal when you visit the Services, our Services (including apps and websites) are not configured to respond to “Do Not Track” signals received from browsers.
For more information on how third parties may use tracking technologies in our apps, go to APPENDIX A and APPENDIX B.
For more information on the use of cookies on our websites can be found HERE for Easybrain.com, HERE for Sudoku.com and HERE for Solitaire.net.
2. SOURCES OF DATA
How we obtain information depends on how you use the Services. For example, we may collect information:
you provide directly to us, such as when you contact us through email or online form, through the support feature embedded in our Services, or through another form of inquiry;
automatically when you download and use our Services, purchase or redeem one of our products or services, including in-app purchases and subscriptions or participating in an activity of functionality of our Services where you provide your information;
from publicly available sources and third-party platforms, such as when you sync our Services with third-party accounts, post to our social media pages, or through publicly accessible comments, reviews, or posts on social media and other online forums;
automatically, including through cookies and similar tracking technologies;
from third parties, such as advertising and marketing networks or business partners.
Information received from app stores and distribution platforms, such as the Apple App Store and Google Play Store, including information and signals made available to us in connection with your access to, download, or use of our Services, in accordance with the applicable app store’s terms and privacy policies.
For more information on which third parties may provide us with your personal information in our Services, go to APPENDIX A and APPENDIX B.
3. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of the ways in which we use your Personal Data, the legal bases we rely upon to do so and to provide you with an option to opt-out of certain practices, where applicable. We may use your Personal Data:
Service Provision and Maintenance
We process your data to provide and maintain our services consistent with the terms of our End User License Agreement. This allows us to provide our apps and its functionalities, recognize returning users, maintain your preferences and settings, sync your game progress across various devices, provide technical and other support and conduct essential business functions.
Syncing and Backup via Third-Parties
With your explicit permission, we use your data to provide backup and sync functions via third-parties like Google Play Games and Apple Game Center. Please note that these third parties mentioned in this section are governed by their own privacy policies, terms and end-user agreements and we are not responsible for and have no control over the sharing practices or policies of the third parties that operate those sites. Further, when you disable the backup feature, certain information might remain on your device(s) or the third party servers. To delete these remaining data, please visit your device’s or third party settings.
Administering and Protecting Our Services
We process your data based on our legitimate interest of administering and protecting our services and business. This includes actions such as troubleshooting issues, data analysis, testing, fraud prevention, data hosting, and verifying eligibility to access our Services.
Communication and Continuous Improvement
We use your data to communicate with you, respond to your requests, and improve our services. These data are processed pursuant to performance of our End-User Licence Agreement, or based on our legitimate interests to keep our users updated about our Services and our new features in accordance with your preference.
To opt-out of communication with us for our Services, send us your request through the online contact us support feature.
Analytics
We analyze your data using our own as well as third-party analytical tools to better understand how our services are used. This helps us learn about user behavior within our games, including navigation habits, feature usage, actions taken, duration of play, and frequency of return. These insights allow us to enhance user experience by improving gameplay, revising less popular features, and fixing any bugs or issues. Processing personal data through our first-party analytics tools is based on our legitimate interests in improving our games, developing new services, conducting analyses to modify our software or content, and providing an overall better experience for our users. When it comes to third-party analytics, we rely on your explicit consent as the legal basis for processing in jurisdictions where necessary. For more information about our third-party partners, kindly visit “APPENDIX B - Analytics and other service providers”.
Depending on your local privacy laws, to opt-out or withdraw your consent from processing of your information for Analytic Purposes, see the “EXERCISE YOUR PRIVACY RIGHTS” section below.
Marketing
We use your data for marketing purposes based on our legitimate interests in advertising to existing users or, where required, your consent. This includes in-game promotions and, with your consent, push notifications (which you can disable in your device settings). We also advertise through third-party websites, apps, and interconnected devices using anonymised or aggregated data shared with marketing partners, who may combine it with their own data to improve ad effectiveness. Additionally, we may use third-party data provided by our marketing partners when they have obtained your consent or another legal basis to share this information with us.
As part of user acquisition, we share limited pseudonymous information (such as advertising identifiers and campaign metrics) with advertising networks and platforms to measure campaign performance and reach new players.
Our games may be available through third-party distribution channels (offerwalls within other apps or manufacturer and platform-provided app discovery, setup, or recommendation features). When you install via these channels, we receive limited technical information to confirm installation and, where applicable, provide any associated reward, subject to contractual safeguards.
To opt out of receiving advertisements for our services and products, send us a request through the in-app support feature by going to your app Settings (in certain apps, tap on the three dots (or “more”)), then select Help or Support, and choose Contact Us (or “+”) to send your request, or go to Settings → About → Privacy Preferences.
Personalised Advertisements
We and third party advertising networks will use information to be able to technically deliver ads to your device, and to enhance your experience, specifically through the personalization of advertisements, ensuring that the ads you encounter are of higher value, ultimately creating a more engaging and satisfying user experience.
For users who are located in the European Economic Area, the United Kingdom (the "UK"), Norway, Switzerland or Brazil we use a Consent Management Platform to gather your consent and preferences and to communicate them to our third-party advertising networks. Easybrain participates in, and complies with the policies and technical specifications of, the IAB Europe Transparency and Consent Framework (IAB TCF). Easybrain’s identification number within the framework is #350 (TCF v2.3 CMP Private).
For our websiteswebsite Sudoku.com and for Solitaire.net, and in particular if you are based in the European Economic Area and the UK, OneTrust operates the consent management platform with the identification number 28.
To opt-out or withdraw your consent from receiving personalized advertisements, see the “Opt-out of targeted advertising” section below
Where local laws allow, this processing will be based on our legitimate interests to deliver content that is more aligned with your preferences and interests, continue providing our services for free, sustaining our business operations, helping us to grow, innovate, and continuously improve the services we offer.
Community Engagement
We process user-generated or community content provided directly by you through email, social networks, or social platforms. This content may include Personal Data, and we may use it for specific purposes, such as showcasing your contributions to our community (e.g., reposting on our social media channels or platforms) and promoting our services or engaging with our audience through marketing initiatives.
You may withdraw your consent by providing us with written notice by email at [email protected].
Legal Requirements
We may process your data to respond to legal proceedings and other obligations or requirements under applicable law.
4. RETENTION OF PERSONAL DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, provide our Services and enforce our legal agreements and policies.
We will also retain Personal Data and Usage Information for internal analysis purposes and legitimate business interest to the extent necessary to improve the functionality of our Services, for business purposes or when we are legally obligated to retain this data for longer time periods.
Your Personal Data collected through our Services will be retained for as long as permitted by applicable law or necessary depending on the respective purpose of collection and shall be deleted when they no longer serve one of the above-mentioned purposes or shall be anonymized and therefore will no longer constitute Personal Data. It is clarified that in no case the retention period should exceed the 5 years from the date of collection. Once we have deleted or anonymized your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
5. PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA
We may share the above categories of Personal Data for certain business purposes, including:
Sharing with Service Providers and Partners
Purpose: We use third party service providers, contractors and partners to assist in operating and improving our services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. These include personal data storage, hosting and maintenance, ongoing development, analytics, customer support, and marketing.
Third Party Advertising
Purpose: Information may be shared with advertising partners who distribute advertising within the services. Details about these advertising networks can be found in ‘APPENDIX A - Advertising networks and their partners’. If you'd like to withdraw consent, or opt-out from having advertisements personalized in this way, please see the ‘Opt-out of targeted advertising’ section.
For certain USA residents, we may also “sell” or “share” your Personal Information, as defined under their respective State’s privacy laws, for this purpose. For more information about your rights as a US resident, please visit the “SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS” section below.
For Corporate Transactions
Purpose: To transfer information in events like mergers, sales, acquisitions, restructuring, bankruptcy, or other changes of ownership or control.
When Required by Law
Purpose: To comply with legal obligations, protect the rights, property, or safety of the business, customers, or others.
Enforce Legal Rights
Purpose: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With Your Consent or at Your Request
Purpose: Personal Data may be shared with third parties if you give consent or request such sharing. The reasons for sharing will be clearly communicated to you.
Social Sharing Features
Purpose: Services may offer social sharing features allowing you to share actions you take within the services with other media. These features require you to be over the minimum age limit prescribed by the legislation in your jurisdiction. The use of such features enables sharing of information with friends or the public, based on your settings with the entity providing the social sharing feature. Providers of these social features include Facebook and Instagram, among others. In all instances, we aim to ensure that Personal Data is shared responsibly, in accordance with user preferences, legal obligations, and industry standards for data protection.
6. CROSS-BORDER DATA TRANSFERS
Sometimes involves transferring data across borders, including outside of the EEA. Transfers are made to countries that provide an adequate level of data protection, or to entities that will provide sufficient guarantees that personal data will be processed in line with this privacy policy and applicable law, under standard contractual clauses approved by the European Commission.
7. AGE LIMITS
Our Services are intended for a general audience and are not designed for users under 16. Where applicable, we rely on age-assurance signals provided by app stores (such as Google Play or the Apple App Store) to help determine a user's age. These signals do not include a specific birthdate.
Despite this, we recognise that some younger users may access our Services. Where we receive a signal indicating a user may be below the applicable age threshold, we apply protective measures, including making our Services unavailable or serving contextual advertising only (no personalised or targeted ads) and limiting data collection.
In certain jurisdictions, local law imposes a higher age threshold before personalised or targeted advertising is permitted. In these cases, we extend our protective measures accordingly.
If you believe that we may have collected personal information from a user who should not be using our Services, please contact us using the in-app Privacy Settings (Settings > Privacy Preferences) to request deletion.
8. LINKS TO OTHER SITES
Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.
9. YOUR RIGHTS AND OPTIONS
Under the General Data Protection Regulation (GDPR), you have certain rights regarding your personal data. These rights include:
In addition to the above rights, you also have the option to withdraw consent if we are processing your personal data based on your consent, at any time.
To exercise any of these rights, please follow the instructions under the “EXERCISE YOUR PRIVACY RIGHTS” section found below, and follow the necessary steps. Please note that exercising some of these rights may impact our ability to provide our services to you. We will inform you of any such impact when you make a request to exercise your rights.
10. SUPPLEMENTAL PRIVACY NOTICE AND RIGHTS FOR USA RESIDENTS
We are committed to protecting your privacy and ensuring that your personal information is handled in accordance with applicable privacy laws in the United States. Certain U.S. states including California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia give residents rights including the right to know what categories of personal information are collected about them and how it will be used, disclosed, and sold or shared.
The purpose of this section of the Notice is to provide residents of these states with a description of our practices regarding the collection, use, disclosure of personal information, available rights, and how to exercise their rights in relation to their personal information.
Depending on your state of residence, you may exercise the following rights:
Right to Know & Access: You have the right to request that we disclose what personal information we collect, use, and disclose. This includes the right to confirm whether we process your data and to know whether your personal data is sold or shared with third parties and, if so, the categories of third parties to whom the data was sold or shared. You may also request a copy of the specific pieces of information we have collected about you over the past 12 months, including the categories of sources and the business or commercial purposes for such collection and disclosure. For more information about data practices over the past 12 months, please visit “Information We Collect and How”, “PURPOSES FOR WHICH WE WILL USE YOUR DATA” and “PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA” sections of this Notice.
Right to Delete: You may request that we delete your personal information, subject to certain legal exceptions (including but not limited to security, legal compliance, or fulfilling a transaction).
Right to Correct: You have the right to request that we fix inaccurate personal information.
Right to Opt-Out (Sale, Sharing, & Targeted Advertising): You have the right to direct us not to "sell" your personal information or "share" it for targeted advertising (also known as cross-context behavioral advertising). As we use third-party advertising networks to provide measurement and personalization services, these activities may be considered a "sale" or "sharing" under certain U.S. laws. To exercise these rights, see the “EXERCISE YOUR PRIVACY RIGHTS” subsection below.
Right to Data Portability: You may request to receive your data in a portable and readily usable format.
Right to a List of Specific Third Parties: If you reside in Oregon, Delaware, or Minnesota, you have the right to request a list of the specific third parties to whom we have disclosed personal data. You may find a comprehensive list of these parties in our APPENDIX A - Advertising networks and their partners
Right to Appeal: If we decline your request, residents of all states listed above (except California) have the right to appeal our decision.
Mandatory Disclosures
Notice at Collection: We collect the categories of personal information and use them for the business purposes detailed in the “Information We Collect and How”, “PURPOSES FOR WHICH WE WILL USE YOUR DATA” and “PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA” sections of this Notice.
No Sensitive Data: We do not collect or process "Sensitive Personal Information" as defined by U.S. state laws (such as precise geolocation, health data, or biometric identifiers).
Retention: We retain each category of personal information for only as long as necessary to fulfill the purposes outlined in this Notice, or as required for legal and compliance reasons.
Non-Discrimination: We will not discriminate against you for exercising your privacy rights
To exercise any other rights conferred under US Privacy Laws, please follow the instruction under the ‘EXERCISE YOUR PRIVACY RIGHTS” section found below, and follow the necessary steps.
We aim to respond to your request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing. If we cannot satisfy your request, we will respond to you with our justification for declining to take action. If you wish to appeal this decision, you can contact us through the method provided in “Contact Us” below.
11. EXERCISE YOUR PRIVACY RIGHTS
Any requests to exercise your rights should be made through the Privacy Setting tab in any of our apps located by going to your home page and tapping the Gear Icon, three dots (or More), or the "Me" button, depending on the app > Privacy Rights and select which rights you want to exercise. You can also contact us through our support feature located in our apps by going to your home page and tapping the Gear Icon, three dots (or More), or the "Me" button, depending on your app -> click help (or support) -> and then click on the Start Conversation button, and place your request. You can also send us an email at [email protected], however, we may still redirect you to make the same request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
You may also contact your local data protection authority within the European Economic Area or the UK or a relevant national authority for unresolved complaints.
Opt-out of targeted advertising
To show you personalized advertisements in our apps we use third-party advertising networks and their partners, as listed in 'APPENDIX A - Advertising networks and their partners’, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers i.e. the Android advertising ID and/or Apple's ID for advertising (IDFA), device data and/or other tracking technologies to enable and optimize this advertising procedure.
Depending on your local privacy laws, you may have the right to withdraw your consent for personalized advertising, or opt-out from the selling or sharing of your data at any time.
You can exercise these privacy rights at any time by checking the Privacy Setting tab in any of our apps or under the privacy settings of your iOS or Android device.
- Open app Settings
- Select Privacy Preferences (or “Do Not Sell or Share my Personal Information”)
- Click on “Withdraw Consent to All", and then click Confirm Choices (Android) or Save & Exit (iOS)
When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests.
Otherwise, you can limit access to your advertising identifiers i.e. the Android advertising ID and/or Apple's ID for advertising (IDFA), through the privacy settings on your iOS or Android device. This means that third parties won’t be able to link your data across different apps and websites. To do so, please follow these steps:
For iOS:
- Open the Settings on your iOS device
- Navigate down and select Privacy (& Security).
- Select Tracking Advertising (depending on your device's operating system).
- If you selected Tracking, enable or disable "Allow Apps to Request to Track" and/or this particular app from the list of apps.
- If you selected Advertising, enable or disable “Limit Ad Tracking” accordingly
For Android:
- Open the Settings on your Android device
- Navigate down and select either Privacy or Google (depending on your device operating system)
- If you selected Privacy, now choose Ads.
- If you selected Google, select Ads under the All Services section.
- Tap on Reset Advertising ID / Delete Advertising ID accordingly.
Note: Irrespective of your choice and/or your device settings, you will continue to see non-customized advertising (e.g. “contextual” advertising) and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites. For more information go to 'APPENDIX A - Advertising networks and their partners’.
Opt-out of analytics (depending on your local privacy laws)
To perform analytics in our apps we use first and third party analytic tools in order to gain insights into how our users interact with our products and services. To do so, we use personal and non-personal information such as device identifiers, device data and/or other tracking technologies to enable and optimize this procedure.
For third-party analytics, in countries where the applicable laws and regulations require us to do so, your consent is the legal basis for processing. For more information about our third party partners, please visit “APPENDIX B - Analytics and other service providers”.
On the other hand, we collect user data for our own internal analytics tools, which is based on our legitimate interest to create better games and provide a more enjoyable experience for our users. The data collected is solely used for the purpose of our own analytics tool and is not shared with any third parties.
You can withdraw your consent or object to the processing based on legitimate interests for analytics purposes, at any time by checking the Privacy Setting tab in any of our apps.
Method (depending on your local privacy laws) - App Settings:
- Open app Settings
- Select Privacy Preferences
- Select “View Partners” and scroll until you reach the analytics section where you can change your preferences
12. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.
In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.
13. CONTACT US
If you have any questions about this Privacy Policy, please contact us using the in-app support feature in our Services, which is the preferred method to be able to quickly respond your requests or contact our data protection officer at the address provided below:
Easybrain Ltd
335, 28th October Avenue
Trilogy Limassol Seafront
West Tower, Floor 14th
3106, Limassol, Cyprus
[email protected]