Effective September 30, 2019. Last revised February 19, 2021.
We want you to understand how and why Brightful Innovations Company Limited. (“Brightful,” “we” or “us”) collects, uses, and shares information about you when you use our websites, mobile apps, and other online products and services (collectively, the "Services") or when you otherwise interact with us or receive communication from us. This Privacy Policy applies to all of our Services.
What We Collect
Information You Provide to Us
We collect information you provide to us directly when you use the Services. This includes:
Account information. To create an account, you must provide your first name, last name, email address, and password. We also store your user account preferences and settings.
Content you submit. We collect the content you submit to the Services. This includes content of your games, your messages with other users, and your reports and other communications with us. Your content may include text, links, images, gifs, audios, and videos.
Actions you take. We collect information about the actions you take when using the Services. This includes your interactions with games, like creating a game, inviting players, giving answers, and reporting. It also includes your interactions with other users, such as messaging, upvoting, and blocking. We collect your interactions with our Paid Services, like purchasing, upgrading and cancelling.
Other information. You may choose to provide other information directly to us. For example, we may collect information when you fill out a form, participate in Brightful-sponsored activities or promotions, apply for a job, request customer support or otherwise communicate with us.
Information We Collect Automatically
When you access or use our Services, we may also automatically collect information about you. This includes:
Log and usage data. We may log information when you access and use the Services. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, actions taken, links and buttons clicked, the requested URL, hardware settings, and search terms.
Information collected from cookies and similar technologies. We may receive information from cookies, which are pieces of data your browser stores and sends back to us when making requests, and similar technologies. We use this information to improve your experience, understand user activity, personalize content, and improve the quality of our Services. See our Cookie Notice for more information about how Brightful uses cookies. For more information on how you can disable cookies, please see “Your Choices” below.
Location information. We may receive and process information about your location. For example, with your consent, we may collect information about the specific location of your mobile device (for example, by using GPS or Bluetooth). We may also receive location information from you when you choose to share such information on our Services, including by associating your content with a location, or we may derive your approximate location from other information about you, including your IP address.
Information Collected from Other Sources
We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you.
Linked services. If you authorize or link other services (e.g., third-party apps or websites) to access your Brightful account, Brightful receives information about your use of that service when it uses that authorization. Linking services may also cause the other service to send us information about your account with that service. To learn how information is shared with linked services, see “How Information About You Is Shared” below.
How We Use Information About You
We use information about you to:
- Provide, maintain, and improve the Services;
- Research and develop new services;
- Help protect the safety of Brightful and our users, which includes blocking suspected spammers, addressing abuse, and enforcing the Brightful user agreement and our other policies;
- Send you technical notices, updates, security alerts, invoices and other support and administrative messages;
- Provide customer service;
- Communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you (for information about how to opt out of these communications, see “Your Choices” below); and
- Monitor and analyze trends, usage, and activities in connection with our Services
We will never rent or sell your information to anyone.
How Information About You Is Shared
When you use the Services, certain information may be shared with other users and the public. For example:
- When you invite players to join a game, your game’s state is shared with all those players. Keep in mind that additional players may join a game after you have already started.
- When you publish content (such as a customized game), all users will be able to see that content, the name associated with the content, and the date and time you originally submitted the content.
- When other users view your profile, they will be able to see your profile picture, your name, and your user id.
Please note that, even when you delete your account, the content and messages you submit through the Services may still be viewable or available on our servers. For more information, see “Your Choices” below.
Otherwise, we do not share, sell, or give away your personal information to third parties unless one of the following circumstances applies:
- With linked services. If you link your Brightful account with a third-party service, Brightful will share the information you authorize with that third-party service. You can control this sharing as described in "Your Choices" below.
- With our partners. We may share information with vendors, consultants, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out work for us. The partner’s use of personal data will be subject to appropriate confidentiality and security measures.
- To comply with the law. We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
- In an emergency. We may share information if we believe it's necessary to prevent imminent and serious bodily harm to a person.
- To enforce our policies and rights. We may share information if we believe your actions are inconsistent with our user agreements, rules, or other policies, or to protect the rights, property, and safety of ourselves and others.
- With your consent. We may share information about you with your consent or at your direction.
- Aggregated or de-identified information. We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may show the total number of times a document has been read without identifying who the readers were.
Analytics Partners
We may partner with third-party analytics providers to better understand your use of the Services. These third parties may collect information sent by your computer, browser, or mobile device in response to a request for content, such as unique identifiers, your IP address, or other information about your computer or device. For example:
We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our Services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Services.
Your Choices
As a Brightful user, you have choices about how to protect and limit the collection, use, and disclosure of information about you.
Accessing and Changing Your Information
You can access and change certain information through the Services.
Controlling Linked Services’ Access to Your Account
You can review the services you have linked to your account and revoke access to individual services.
Controlling the Use of Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information on controlling how cookies and similar technologies are used on Brightful, see our Cookie Notice.
Controlling Advertising and Analytics
Some analytics providers we partner with may provide specific opt-out mechanisms and we may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt-out. For example, you may manage the use and collection of certain information by Google Analytics here.
Do Not Track
Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.
Controlling Promotional Communications
You may opt out of receiving some or all categories of promotional communications from us by following the instructions in those communications or by updating your email options in your account preferences. If you opt out of promotional communications, we may still send you non-promotional communications, such as information about your account or your use of the Services.
Controlling Mobile Notifications
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Controlling Location Information
If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.
Other Information
Information Security
We take measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. For example, we use HTTPS while information is being transmitted. We also enforce technical and administrative access controls to limit which of our employees have access to non-public personal information.
Data Retention
We store the information we collect for as long as it is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
To request for your data to be deleted, please email support @ brightful.me.
International Data Transfers
Our technical infrastructure is in the United States and we process and store information on servers located in the United States. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.
Additional Information for EEA Users
Users in the European Economic Area have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing; and to withdraw consent for processing where they have previously provided consent. These rights can be exercised using the information provided under “Your Choices” above or using the contact information provided at the end of this document. EEA users also have the right to lodge a complaint with their local supervisory authority.
As required by applicable law, we collect and process information about individuals in the EEA only where we have legal bases for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:
- You have consented for us to do so for a specific purpose;
- We need to process the information to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, and marketing and promoting the Services;
- We need to process your information to comply with our legal obligations.
Children
Children under the age of 13 are not allowed to create an account or otherwise use the Services. Additionally, if you are in the EEA, you must be over the age required by the laws of your country to create an account or otherwise use the Services, or we need to have obtained verifiable consent from your parent or legal guardian.
Changes to This Policy
We may change this Privacy Policy from time to time. If we do, we will let you know by revising the date at the top of the policy. If we make a change to this policy that, in our sole discretion, is material, we will provide you with additional notice (such as sending you a notification or an email). We encourage you to review the Privacy Policy whenever you access or use our Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. By continuing to use our Services after Privacy Policy changes go into effect, you agree to be bound by the revised policy.
Contact Us
If you have any questions about this Privacy Policy, please contact us at legal@brightful.me or at:
Brightful Innovations Company Limited.
23rd Floor, 70 Connaught Road West
Hong Kong