Your privacy is very important to us, so we will always use your personal data only for the purposes described in this Privacy Policy. This Privacy Policy applies to all of our games, applications, websites and related services, collectively referred to as our "Service. It covers the practices we employ in collecting, using, disclosing, transmitting and storing information obtained about users and/or information obtained about users' computing device as a result of their use of the Service. We receive and/or you may be asked to provide your information (including personal information) at any time while interacting with us or using our Service. As described in more detail below, we share your information (including personal information) with our affiliates and use it in accordance with the terms of this Privacy Policy. We may also use your information (including personal information) along with other information to provide and improve our products. Please read the following information to learn more about how we use your personal information. By using our Service, you acknowledge that: You have read, understand and agree to this Privacy Policy; You are over the age of 16 (or your parent or guardian has read and agreed to this Privacy Policy on your behalf); You are a parent, legal guardian, or authorized school employee under applicable law if you are using our services on behalf of a child. If you do not or cannot give this consent, you may not use our Service. In that case, if you use our application, you must: Delete your account or your child's account using the feature described in the "Settings" section of the App, or contact us and request that we delete your or your child's data; Cancel all subscriptions using the features provided by Apple (if you use iOS) or Google (if you use Android), Tinkoff (for all OS, cancellation rules: Follow the link in the email notifications about the debit Enter the first 6 digits and the last 4 digits of the card, the expiration date of the card and the amount that is listed on the receipt. After entering the data, you will be redirected to a page where you can manage your existing subscriptions or change your means of payment (card); And remove the application from your devices.
For the purposes of the General Data Protection Regulation 2016/679 and any implementing legislation ("GDPR"), BUBULEARN CO (hereinafter referred to as Bubulearn, "we", "us", "company" or "our") will be the data controller responsible for the processing of personal data by our company. If you have any questions or concerns about the use of the BUBULEARN CO Privacy Policy, including questions regarding the exercise of any of your rights, please contact us through the Game Support so that we can respond as soon as possible. Or contact us in one of the following ways: For questions about privacy and the exercise of your rights - at our privacy-related email: info@bubulearn.com; For general information, please contact our customer support team by email: info@bubulearn.com.
2.WHAT PERSONAL INFORMATION WE COLLECT AND WHY We may receive, use and otherwise process your personal data in various ways. In all cases, we are committed to protecting your personal data. In each of the sections below, we describe how we receive your personal data and how we process it. 2.1. USERS OF OUR APPLICATIONS We collect personal data relating to users of our App.
SOURCES OF PERSONAL DATA We may receive your personal data from the following sources: Directly from you (through the game, website or online forms); and/or From third parties, service providers who assist us in providing the relevant application (e.g. Google, Apple, Firebase). PERSONAL INFORMATION WE COLLECT AND PROCESS In general, the information we collect about you relates to the type of device you use, information that helps us identify your device, how you use our applications, and may also include information you provide to us when you voluntarily contact us. We may also collect information from app store platforms, partners, and other third parties, such as information about your interests and purchases through the relevant app (provided that we never receive your payment or credit card information). Technical Information We collect technical information about your device that you need to use our apps, as well as additional technical information that allows us to maintain and analyze the performance of the app and to personalize the content of the app you use. This information includes, but is not limited to, the type of device(s) you use to play our apps, persistent identifiers such as IP address, Device IDs, Ad IDs, unique user ID specific to our apps, and the country or region in which you play. Persistent identifiers (such as Device ID and IP address) are identifiers that do not personally identify you, but can uniquely identify your device. Such online identifiers provided by end-user devices, applications, tools and protocols are considered personal data under data protection laws. Please see "Your Rights" for the rights you have under data protection laws.
We automatically collect certain information about your computing device, including:
  • IP address; country, city or region data;
  • Language;
  • location data (the specific location where the language is spoken);
  • Time zone, session start/stop time,
  • Network status (Wi-Fi, etc.), types and versions of browser plug-ins;
  • User agent (UA), platform, SDK version, timestamp;
  • UDID (device identifier)
  • Technical information about the device (e.g. device model and name, operating system name and version, processor information, screen size, firmware, software, mobile operator, Internet service provider, API key identifier for the application, Android ID, Android serial number);
  • A push notification token (so that we can determine if you are subscribed to push notifications).
In addition, we create a unique user ID for you to track your use of our apps.
Information about using the Service.
When you use our apps, we collect additional information from you through persistent identifiers that allow us to identify your device. We collect information about your preferred settings when you play using our apps. Such information is used to effectively provide and improve our app, cross-promotion and analytics for related purposes.
STANDARD PERSONAL INFORMATION. We do not collect standard personal information through our applications (such as your name, address, or telephone number). You may, however, use our applications without providing us with your standard personal information. We will only collect your standard personal information (such as your name, residential address, e-mail address or telephone number) when you contact us directly, and we will only use such information to respond to your request. When we use your email to send you promotional information, we will ask for your prior consent if required by law. If you have passed an age verification and given us consent to receive promotional emails, we will use your personal information to analyze your promotional preferences and provide you with promotional emails about our products and services. You can unsubscribe from receiving promotional emails at any time by clicking on the "unsubscribe" button at the end of all our marketing and promotional emails sent to you, or by sending us an email at info@bubulearn.com. We may ask you to provide, as well as process, other non-personally identifiable information that may be personal to you, such as your child's age category and gender, provided that age category and gender information is collected only for users who have passed parental controls when using our apps. When you use a particular category of our apps, we collect information about the online alias you choose for your child's account and your rating information for the corresponding app (if any). Please do not use your real name or your child's name.
Push notifications We use push notifications to remind you of your in-app activities. You will only receive push notifications if you have signed up for them in the app. You can always unsubscribe from push notifications. Please use the instructions below. For iOS: You will be prompted to accept or decline push notifications after downloading the app. You will not receive push notifications if you decline receiving them. Note that if you opt-in to receive push notifications, some cell phones will allow you to disable push notifications later by using your cell phone settings. To manage push notifications on your cell phone, please follow these instructions: Open the settings menu and tap "Notifications"; find the App you're interested in; tap the App icon; control the "Notifications" option by moving the slider to enable or disable. For Android: Once you download the app, you'll automatically receive push notifications. You can manage push notifications on your cell phone. To do this, go to the "Information screen" on the main page of the App and select the "Settings" option. Here you can disable push notifications by unchecking the "Notification" button in the App. If you choose to unsubscribe from push notifications, the associated push notification tokens will be removed from our database. For information about restricting the use of information, please refer to the Children's Data Privacy section of this Privacy Policy.
SURVEY We conduct surveys to improve our services. It is up to you to decide whether you want to take the survey or not. We will always ask for your consent before conducting a survey. We may periodically conduct surveys in our applications as well as collect demographic and usage information for internal analysis, marketing and brand development purposes. Participation in the survey is completely voluntary. We will use this information to make our services more attractive to users. The information collected must be anonymized and aggregated. We may collect the following information: age and gender of the app user, data about the use of the app by others, age and gender of people who regularly use the app, popularity rating of the main character, which characters the user knows, which app is most often used, whether children under 13 use the app alone or with adult supervision, gender of users who play a particular game, different ways of using the app, evaluation of the features of the app, time period of use We may use third-party vendors to conduct in-app surveys, and they may place their tags in the app to collect non-identifiable data from a device ("Tag Data") solely for survey purposes, such as collecting information about different devices to ensure that audiences of different devices are deduplicated. These providers may use the anonymized and aggregated data collected from the survey and the Tag Data together with data from other partners ("Unified Data") to publish syndicated reports on audience and online trends. If you want to opt out of the in-app survey, do not click the survey button or refuse to answer the survey questions.
IN-APP PURCHASES THROUGH OUR APP You can download the app for free. However, some features of the Service are offered on a subscription basis for a fee. Any specific payment terms for any paid services will be explained to you before you agree to pay, and the applicable payment terms will be incorporated into these terms by reference. Payment transactions for in-app purchases are made through the app store (Google Play or App Store) from your account. Any post-purchase processes are controlled by the app store and are subject to certain terms and conditions of such app store. Please read the privacy policy and terms of service of your app store. For more information about in-app purchases through our apps, please refer to the Terms of Use, available at: https://bubulearn.com/terms-of--use
We do not process payments for in-app purchases and do not have access to your credit card information. We may change the price and nature of services at our discretion, but if you pay for services, we will always notify you if we change the price or substantially change the nature of the services you use. We are not responsible for any loss you may incur if you do not change or cancel your subscription after we have informed you of any change in price or nature of services. You may pay for certain services (through one of our websites, from the app, or through the app store) with an auto-renewable subscription. By signing up for certain subscriptions, you agree that your subscription may be automatically renewed. If you do not cancel your subscription, you authorize the App Stores and other payment acceptance systems to charge you a renewal fee. The auto-renewal period will be the same as your original subscription period, unless you are provided different information about the Service. Renewal fees will not exceed the cost of your subscription for the period immediately preceding the renewal, except for any specifically set prices and discounts, unless we notify you of the change in price prior to your auto-renewal. You must cancel your subscription in accordance with the cancellation procedure specified to you for that particular subscription. We do not refund any fees that may have accrued to your account and we do not prorate fees for cancelled subscriptions. Automatic subscriptions can be changed or canceled by changing the settings in the applicable app store or, if you purchased services directly from us, as part of the service purchased (for example, in the app) or by contacting us at info@bubulearn.com or in the app itself under Profile. For subscriptions paid in-app through other payment acceptance systems, we may provide a refund upon application within one calendar day from the date of debit. To do this, please contact Logopotam application support from within the application or by e-mail to info@bubulearn.com. In your appeal you will need to specify the reason for the refund and the email address to which the receipt was sent when payment for the subscription was made.
Payment by other payment methods means processing of transactions on the side of the processing center/bank. BUBULEARN CO and LOGOMIR LLC do not store card data and other payment details of users. The processing center/bank may store a shortened version of the stored credentials (e.g. the last four digits of a credit card) for future transactions (subscription renewals). Subscriptions purchased from the App Store are subject to that App Store's refund policy. As such, we cannot provide refunds, and if you believe you qualify for a refund, you will need to contact the App Store customer support team for that particular App Store.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? We will only process your personal data for as long as necessary for the purposes for which it was collected in connection with the provision of services to you, unless we have a legitimate interest or obligation to retain such data for a longer period or where the data is necessary to substantiate, exercise or defend a legal claim. Some of the personal data we collect is stored on your device (for example: temporary age category hash; temporary interest type hash; temporary gender category hash; sound setting for a parent account; debug mask status). We do not process or have access to such personal data. They are stored until you remove our app or service from your device.
3. TO WHOM DO WE TRANSFER YOUR PERSONAL DATA? We do not sell your personal information to third parties, our partner organizations or service providers. We cannot provide all of the services required for our Services to work successfully on our own. Therefore, we must share the information we collect with third parties, including analytics providers, tracking and fraud prevention providers, and other third party service providers that develop and support our Services. We do not share information that can be used to personally identify your device (such as persistent identifiers such as IDFA, IDFV, ad recipient ID and IP address). We also reserve the right to disclose your information (including personal information) when required by law and to disclose your information in an anonymous and aggregated manner. This means that you cannot be personally identified from it.
We may disclose information about you to organizations that provide services to us, ensuring that we meet our contractual obligations to keep your personal information confidential, comply with the terms of the General Data Protection Regulation and other relevant data protection laws. We may share your information with the following types of service providers: Technical support service providers who provide support for our website and IT infrastructure, Third-party software providers, including software-as-a-service solution providers, when the provider posts relevant personal information on our behalf; Professional consultants, such as attorneys, accountants, tax advisors, auditors and insurance brokers; Suppliers who help us create and collate reviews of our products and services; Our advertising agencies and consultants and those organizations or online platforms that have been selected by us to conduct marketing campaigns on our behalf and promote their own products or services that may be of interest to you; and/or Service providers who assist us in providing our services. Law enforcement or government agencies. We may disclose your personal information as required by law to investigate, prevent or take action regarding illegal activities, suspected fraud, violations of our intellectual property rights, situations involving potential threats to the physical safety of any person, violations of our Terms of Use or other agreements, and as required by law. For any further questions about the collection of information by third parties, please contact us at info@bubulearn.com;
4. CONFIDENTIALITY OF CHILDREN'S INFORMATION BUBULEARN CO adheres to strict requirements for the collection, use and disclosure of information. BUBULEARN CO has established privacy policies that comply with the requirements of the Children's Online Privacy Protection Act. If you have questions or concerns about our privacy policy, please contact us at info@bubulearn.com. We consider ourselves a family-oriented marketplace company. However, we have chosen to voluntarily implement higher standards of child privacy protection, although our products and services do not affect the privacy of such information. In doing so, we do not knowingly collect, store or use information from children under the age of digital consent under EEA data protection laws without the permission of their parents/legal guardians, except for permanent identifiers and the age category described below. If we become aware that our company has collected personal data that is not a permanent identifier or does not match the age category of a child under the age of digital consent under EEA data protection legislation, we will take all reasonable steps to delete such personal data 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@bubulearn.com.
The only category of personal data that we collect from users who have identified themselves as under the age of digital consent under EEA data protection legislation for the purpose of providing our services are permanent identifiers (such as user ID, device ID or IP address) and the age category of the child. We do not transfer such persistent identifiers to third parties. They are used solely to authenticate app users, maintain or analyze app functionality, personalize app content (or send push notifications), perform network transmission of information to protect the security or integrity of the user or app, and to enforce legal or regulatory requirements. A child's age category is used to build a proper educational plan (in accordance with our Contractual Obligations) and is treated as anonymous information (e.g., "Category A" or "Category B"), so in this case the date of birth cannot be determined. When using permanent identifiers, we will not contact users who are under the age of digital consent in accordance with EEA data protection legislation, nor will we monitor or analyze the profile of our users. See Section 3 of this Privacy Policy for more information about disclosures to third parties. For any further information about disclosure of personal data to third parties, please contact us at info@bubulearn.com
5. YOUR RIGHTS You have certain rights in connection with our processing of your personal data, for example, you have the right to be informed whether we are storing the personal data you have given us, to access your personal data, to correct, update, amend or delete your personal data and to contact the relevant supervisory authority. Some of these rights may be subject to certain exceptions or limitations. You may exercise these rights at any time by sending an appropriate request regarding your personal data to info@bubulearn.com. You have the following rights: Right to object. You have the right to object to the processing of your personal data that is processed on the basis of legitimate interests (see "Legal Basis" below). You can always object to further collection of your personal data by our Company and our Partners by removing all Services from each of your computing devices. Right of Access. You have the right to know what information we hold about you, and in some cases to have relevant information provided by you to our company. If you wish to exercise this right, please contact us, letting us know that you wish to exercise your right of access to such information and specifying what information in particular you would like to receive. We reserve the right to request reasonable evidence to verify your identity before providing you with any information.
Please note that we may not be able to provide all of the information you requested, for example, in cases where the information includes personal information about another person. If we are unable to provide you with the information you requested, we will give you the reason for our refusal. We will endeavour to respond to any request for a right of access as soon as possible and within 1 month of receiving your request and verifying your identity. Right to delete personal information. We endeavor to keep your information held in our databases accurate and up-to-date. If you believe that any information we hold about you is incorrect, please contact us at info@bubulearn.com and we will correct such information as soon as possible. Data Deletion. You have the right to request the deletion of your personal information from our database. If you wish to have your personal information deleted, please contact us at info@bubulearn.com. We reserve the right to ask for additional information to confirm your identity before we can process your request. Once we have all the information we need to be able to identify you, we will delete your personal data in accordance with your request as soon as possible within 1 month of receiving your request and verifying your identity. Please note that we have the right to retain all or part of such information, for example to comply with our legal obligations and protect or enforce our legal rights. We may also retain your information in an anonymous form. In some cases, your personal information that appears in games, such as your username, avatar, your scorecard, and any chat messages, may be stored on other players' devices. In this case, we may not be able to delete or update such data from these devices, for example, if such device is not connected to a Wi-Fi network.
Data Portability. In some cases, you have the right to request that we provide you with the personal data you have provided so that you can transfer the relevant information to another data controller. In this case, please contact us by e-mail at info@bubulearn.com Restrictions on Data Processing. In some cases, you may have the right to request a restriction on the processing of your personal data. Right to file a complaint. You have the right to file a complaint against us. To do so, contact the relevant supervisory authority in your country of residence. If you wish to exercise any of the above rights, please contact us using the contact information provided in Section 1 above.
LEGAL BASIS Whenever we process your information, we do so legally in accordance with one of the legal bases set out in the EEA Data Protection Act. The legal bases on which we rely are as follows: Contractual obligations. These legal bases relate to the information we process to provide the services you request, which we have agreed to provide to you, such as to provide and improve our services, provide customer support, provide special features in our apps (e.g., in-app chat feature, multi-user feature, leaderboards and other third-party social media features), and deliver content you purchase through the in-app in-app purchases feature. Legal Rights. This legal framework relates to information that we process for purposes that may be reasonably expected in the context of your use of our services, to ensure our legal rights, to provide you with the best experience when using our Apps, to guarantee the security of your information and to provide our Apps for free or at a reduced cost. We pay special attention to your data protection rights and ensure that your data protection rights are not infringed upon by our legal rights and interests. We rely on our legal rights and interests when processing data for analytics, tracking and fraud prevention, push notifications, cross-promotion and contextual advertising.
Consent. When we ask for your consent to use your data for a specific purpose, we make this clear at the time of data collection and also explain how you can withdraw your consent. We ask for your consent before providing any information to our advertising partners for the purpose of sending personalized advertising and before conducting any surveys. Legal Obligation. This legal basis refers to information that we process pursuant to a legal obligation, such as for record keeping for tax purposes.
SECURITY We have taken appropriate technical and organizational measures to protect the confidentiality, security and integrity of the information we collect, and to prevent unauthorized access and use of information contrary to the terms of this Privacy Policy. Although we make commercially reasonable efforts to ensure the security of the information you provide, please be aware that no security measures are perfect.