Brain Jar Games, Inc. Privacy and Cookie Policy

Last Updated: July 31, 2025

Your privacy is important to Brain Jar Games and we take our responsibility of caring for it seriously. This policy (“Privacy and Cookie Policy”) describes how Brain Jar Games, Inc. ("BJG" or “we”) may use or process the personal information we collect when you play our games and/or use our applications and services (collectively, "Services"). We may update our policies from time to time so please check our website periodically for updates. Your use (or continued use) of the Services constitutes acceptance of both this Privacy and Cookie Policy as well as our Terms of Use which are incorporated herein by reference. 

BJG is a United States-based company and information that you provide to BJG, if any, will be transferred to, stored in, and/or accessed from the United States. BJG makes every effort to comply with all applicable laws for the protection of your privacy, including without limitation, the European Union General Data Protection Regulation (“GDPR”), the UK GDPR, and the California Consumer Privacy Act (“CCPA”).

This Privacy and Cookie Policy is intended to provide you with notice of the following:

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1. Information we collect.
2. How we collect your information.
3. How we use your information.
4. Who may receive your information.
5. Where we hold your information.
6. How we protect your information.
7. Our policies concerning children’s personally identifiable information.
8. Your choices and controls with respect to your information.
9. Third-party services..
10. California residents and California privacy rights.
11. Changes to this Privacy and Cookie Policy.
12. How you can ask questions or send us comments about this Privacy and Cookie Policy.
13. Right to contact a data protection authority.

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1.Information We Collect

The information we collect depends on what Services you use and how you use them.

A. Information You Give Us Directly

We collect information that you provide us, such as:

• Contact information you may voluntarily provide including your first and last name(s), email address, mailing address (including zip code), phone number(s);
• Information about your contacts if you choose to connect your address book or contacts with your Account; 
• Account information or login credentials for certain third party sites (such as Steam); 
• Location coordinates (if this feature is enabled);
• Device identifier (but not UDID), MAC address, Internet Protocol (IP) address, operating system, computer type, software, browser type, referring site; 
• Information you provide when providing feedback and/or seeking help from us, such as your name, telephone number, and records (including call recordings) of the issues you experience; and
• Billing information, such as your name, payment card number, payment account details, and shipping address. Note, however, that any such information is collected by and utilized by a third-party service provider on BJG’s behalf.  BJG does not collect, process, or store any such information directly.

You can enable or disable location services when you use our website(s) and/or game(s) at any time through your device settings. 

If you choose to provide BJG with a third party’s personal information (such as name, email, and/or phone number), you represent that you have that third party’s permission to do so. 

B. Information You Provide When Using Our Services

When you use our social features, any text, audio, visual, and/or other electronic communications information that you disclose may be read, copied, collected, or used by other users and BJG, and may become publicly available and/or may be processed by BJG for the purposes described in Section 2(C) Inappropriate Content and Fraud Prevention Technologies. Please make sure your privacy settings and choices in the features you use reflect your preferences.

When you use our game(s), your in-app profile information, usage, and statistics are collected and some may be visible in-app, as well as visible to users in your related project(s). 

C. Other Information We Collect When You Use Our Services

We may collect other information automatically when you use our Services, such as:

• Internet Protocol (IP) address;
• Information about your device, hardware, and software, such as your hardware identifiers, mobile device identifiers (like Apple Identifier for Advertising [IDFA], or Android Advertising ID [AAID]), platform type, settings and components, software and updates you have installed, and the presence of required plugins;
• Approximate geolocation data (derived from IP or device settings);
• Browser information, including your browser type and the language preference;
• Referring and exit pages, including pages viewed and other interactions with web content;
• Details about what Services you purchase or obtain, and your use of them;
• Device event information, including crash reports, request and referral URLs, and system activity details (e.g., whether you encountered an error using our app or lost Internet access); and
• Other information (such as your likeness) that you may provide as part of your participation in live events.

We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5), and application data caches.

D. Information Provided to Us by Third Parties

We may receive information about you contained in third-party user accounts when you use our Services on or through third-party platforms. This information is provided to BJG as part of establishing or linking an Account, which is necessary to access BJG’s game(s). We may also receive information from the third-party platforms that you use for the purpose of delivering or analyzing the performance of BJG marketing. Your use of our online Services through these third parties indicates your agreement for the transfer of this information. We never receive your credit card number or other financial information from these third parties as part of establishing or linking an Account.

Steam.  If you access, play or purchase our game(s) on or through a personal computer, this may be done through Steam.  Steam is a third-party website offered by Valve Corporation that operates a store where, among other things, games are made available to end users (such as our Game and you) in accordance to Steam’s various terms and conditions, including, without limitation, the Steam Subscriber Agreement presently available at https://store.steampowered.com/subscriber_agreement/ and Steam’s Privacy Policy presently available at https://store.steampowered.com/privacy_agreement/.  It is those terms and conditions, not BFG’s, that control with respect to your access and use of Steam and any personal information collected by Steam. We may, however, receive information about you from Steam consistent with Steam’s Privacy Policy. This information may include your username or device ID and the fact that you made a purchase, as applicable, but does not include any financial information. Steam may also send information to us that you authorize them to provide.

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Other Third Parties

We may receive information from other third parties when you use these services with our Services. 

E. Legal Basis for Processing

Our legal basis for processing your personal information varies depending on the type of information we collect, the context in which we collect it, as well as on your country of residence, as indicated when you set up your Account or, when not signed into an Account, your location as determined by your IP address and/or your device registration country.

If you are a resident of the European Economic Area (EEA) or of a jurisdiction where similar legal requirements may apply such as Brazil, Switzerland, and the United Kingdom, we rely on a number of legal basis’ to process information about you. We will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and/or where we have a legal obligation to process your information. For example, we typically rely on:

• consent when placing cookies on your device or on the web (through our cookie consent manager), to send you email marketing, or to deliver third-party targeted advertising to you on our Services;
• our legitimate interests to process your information when providing you with customer service support, to serve targeted  marketing of our Services, or for fraud prevention and security purposes; and
• on contractual necessity to process information when you create an Account or otherwise use our Services to enable us to provide you with our Services.

If you are a resident in a territory where our legitimate interests mentioned above are not recognized as a lawful basis under applicable law, we will identify and use other appropriate lawful bases to process your personal information such as contractual necessity or your consent.

2. How We Collect Your Information

We and third parties use technologies described below to collect information to deliver our Services.

A. Cookies and Similar Technologies

Cookies are small text files stored on your Internet browser. We and our third-party partners use cookies and similar tracking technologies to enhance your experience of our Services. Most web browsers are initially set up to accept cookies. You can change or reset the cookie settings of your web browser (for example, to erase existing cookies from your hard drive, to block or refuse the use of cookies, and/or to be notified when cookies are sent or encountered). If you choose to disable your cookie settings or refuse to accept a cookie, some parts of our Services may not function properly or may be considerably slower. Please refer to Section 8: Your Choices and Controls on how to manage your cookie preferences.

We may use tracking pixels or clear GIFs to collect information about your use of our Services and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud, and enforce our End User License Agreement (“User Agreement”).

We also use Analytics and Anti-Fraud technologies in our Services. These technologies may utilize the same cookies or similar mechanisms as further described below.

BJG may use the following types of cookies when using the Services, including our website and game(s):

- Session cookies: temporary cookies that remain in the cookie file of your web browser until you leave the site. Session cookies are used to validate your session and carry information across pages of the Services so you don’t have to re-enter information in order to access different files your Account has permission to view. 

- Persistent cookies: cookies that remain in the cookie file of your web browser for a longer period of time (depending on the life of the specific cookie). Persistent cookies are used to help us recognize you as a unique user when you return to our Services. We may also use persistent cookies to compile anonymous, aggregated statistics to allow us to understand how our Services are used and to help us improve our Services. 

- Third Party Cookies: we may allow third party service providers to set or use cookies on our website and certain other aspects of the Services, but we do not control the use or content of such third-party cookies. 

B. Analytics Technologies

We use internal and third-party analytics technologies to collect information about how you use our Services, your computer or device and the health of our Services.

For instance, we may collect and store data from your computer or device when you use our Services. This information includes technical and related information about your computer, device, and operating and/or network systems (such as IP Address and device identifiers); information about your engagement with certain features and services; usage statistics; as well as system interactions and peripheral hardware. We may also collect and store data from your device to create probabilistic identifiers for the purposes of analyzing the services accessed by our users across devices. If you use our game(s) offline without connecting to the Internet, this data will be stored on your device and transmitted to us when your device connects to the Internet. If you participate in online Services, we may also collect, use, store, transmit and publicly display your personal and/or statistical data regarding your use, or identify content that is created and shared by you with other users.

Third-party analytics technologies integrated into our Services may (including API [Application Program Interface] integrations) combine the information they collect in connection with your use of BJG's Services with information they have independently collected over time and/or across different platforms. Many of these companies collect and use information pursuant to their own privacy policies.

C. Inappropriate Content and Fraud Prevention Technologies

We strive to provide a safe and fair environment for all users. When you use our Services, we or third parties may use cookies and similar technologies, collect data about or from your machine or device, which may include a machine "fingerprint" or "hash" of your machine components, and gather other evidence about your use, machine state, or participation in our Services for fraud prevention, security, and authentication purposes. We may also monitor publicly-available information, third-party sites, and/or automated anti-fraud and abuse algorithms in our Services. If you believe your access to our Services was blocked by this technology in error, please contact us at support@brainjar.games. 

We may also monitor, record, review, and retain voice or text communications, and other content uploaded or transmitted by users (“User Content”) in our Services for purposes of moderating inappropriate User Content that violate our policies (any Code of Conduct or similar policy as BJG may establish). Moderation includes detecting, investigating and removing inappropriate User Content, as well as potentially sanctioning those users whose activities we find as violating our policies.

3. How We Use Your Information

We use your personal information, both individually and combined together, in the following ways.

To operate our business and to enhance and personalize your experience, including to:

• Operate, analyze, improve, and develop our Services;
• Undertake research and analysis to develop, update and demonstrate our game(s) and/or technology, and to better understand our users;
• Facilitate sharing on social networks;
• Measure the health of our Services;
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
• Facilitate your use of our game(s) on multiple devices and/or platforms, as applicable;
• Identify, fix, and troubleshoot bugs or functionality errors;
• Provide software updates;
• Perform audits, transactions, and other compliance activities;
• Adhere to your preferences and to deliver user content;
• Help keep our Services safe and fair, including for such purposes as described in Section 2(C) above to further our content moderation policies;
• Resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and enforce our agreements and policies; and
• Other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide personal information.

To provide you support, including to:

• Help identify and troubleshoot problems with your Account or Services;
• Communicate with you and respond to your specific requests or questions; and
• Manage and send you confirmations and important information about your Account, Services, purchases, and warranties.

To personalize our communications with you, including to:

• Provide you with relevant content, recommendations, information or offers; and
• Provide you with Service updates.

Retention. We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

Where possible, we may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

4. Who May Receive Your Information

Service providers. Vendors and other third-party service providers that help us operate our business and provide you with Services may receive your personal information. We require that any service provider processing your personal information only do so on our behalf and for purposes consistent with this Privacy and Cookie Policy, such as the purposes described in Section 3: How We Use Your Information. 

Business partners. We may provide personal information to business partners with whom we jointly offer Services. These partners include the companies that provide the platform on which you utilize our game(s) (such as Steam), or others.

Please refer to Section 8: Your Choices and Controls regarding your relevant choices and controls.

Disclosures to protect us or others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. 

Disclosure in the event of merger, sale, or other asset transfer. In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.

Third-party plugins. If or when third-party technologies or social tools are integrated into our Services, those third parties may collect information about your use of our Services. An example is the Facebook "Like" button.

In certain instances (such as on our websites), our Services incorporate YouTube videos and use YouTube API Services. This integration is subject to the YouTube Terms of Service, and may result in the collection of your personal information by Google according to the Google Privacy Policy. If you have authorized us to receive your YouTube or other Google information, such as through logging in to our Services through your Google Account, you may manage your authorization (including revocation) through the Google Security Settings. You may also have other rights with respect to your personal information that we have collected, as described in Section 8: Your Choices and Controls. 

With your consent. We may disclose your information to other recipients with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions, or if you tell us that you want to link your Account with another company’s services. These recipients will process the information you agree to share according to their respective privacy notices.

5. Where We Hold Your Information

When you access our Services, including when available on third-party platforms, your personal information is generally collected by BJG directly and processed in the United States. Personal information we collect may be subsequently stored and processed for the purposes set out in this Privacy and Cookie Policy in the United States or any other country in which BJG, its subsidiaries, or third-party agents operate. 

By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

Under certain conditions, more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

6. How We Protect Your Information

Security of your information is a priority at BJG and we take a range of technical and organizational measures to help protect your information, including encryption of sensitive information. Even so, please be aware that no security measure is perfect. Thus, we cannot guarantee the security of your information at all times. You should always be diligent when it comes to the protection of your personal information.

7. Children

We do not knowingly collect personally identifiable information from someone we know to be a child under thirteen (13) years of age (or the minimum age of your country of residence) without prior, parental (or guardian) consent. If you are younger than thirteen (13) (or the minimum age in your country), please do not use our Services, including our website(s) or game(s), and do not submit any personal information through the Services or to BJG.

If you are between the relevant minimum age and eighteen (18) (or the age of majority where you live), you and your parent or guardian must review this Privacy and Cookie Policy together, as parents and guardians are responsible for the acts of children under eighteen (18) years of age when using the Services. 

8. Your Choices and Controls

We give you meaningful choices when it comes to our collection and use of your information. For example, if you no longer want to receive marketing emails from BJG, you may click the unsubscribe link included in the footer of any marketing email we send.

We offer the options below as provided by applicable law in the countries and jurisdictions in which we offer our Services. These laws include state privacy laws enacted in the United States and the General Data Protection Regulation (GDPR) in the European Union. While we provide additional details where necessary to comply with jurisdiction-specific legal requirements, such as in our section on Information for California Residents (below), these details are illustrative and not intended to limit similar rights that may be available elsewhere.

Verification of account ownership. To protect your account security and personal information, you may be asked to verify your account ownership prior to us processing your request to exercise your data privacy rights. Verification methods include being logged into your account, confirming ownership and access to the email address associated with your account, and/or confirming other unique account details.

Authorized agents. You can use an authorized agent to make a request to exercise your data privacy rights. Please contact us at support@brainjar.games to initiate that request. If you use an authorized agent to exercise your right to deletion, access, or correction, we will require that you verify your Account ownership directly with us, unless you have provided your agent with a valid power of attorney consistent with California law that includes a comparable proof of Account ownership.

If you use an authorized agent to submit a request to opt-out of the sale or sharing of your personal information for targeted marketing purposes, we will require your signed permission demonstrating that you have authorized the agent to act on your behalf.

Your right to deletion. You may delete your personal information held by BJG by contacting us at support@brainjar.games (with the subject “Delete My Information”) or at our address in Section 12 below. We will process such requests in accordance with applicable law. If you do so, you will no longer have access to BJG’s games(s) or Services . Note that we may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you with, create, and improve our Services, and to comply with the law.

Your right to access (or "know"). You can access the personal information we hold about you, including the categories of personal information collected, where we collect it from, why and how we use it, and who may receive this information (including to whom it may be sold or shared, as those terms are defined under applicable law). The generally applicable details about our processing are provided in this Privacy and Cookie Policy. To receive further details, please contact us at support@brainjar.games. 

Your right to correction. You can request correction of your personal information where it is inaccurate. 

Your right to opt-out or object to certain processing. You may opt-out of targeted advertising, or object to processing of your data based on our legitimate interests, where applicable law provides for such rights. This right is also referred to as the ability to opt-out of the sale or sharing of your personal information, as specifically provided by applicable US state privacy laws. 

To exercise these rights, please contact us by sending an email to us at support@brainjar.games or write to us at the address below. We will process such requests in accordance with applicable law.

You may appeal our decision regarding your privacy rights. To do so, please send us a “Notice of Appeal” at support@brainjar.games.

Cookie Controls. If you are in a location whose laws may require additional choices, you can control cookies and similar technologies used on most BJG sites for certain optional functional and advertising analytics and targeted advertising purposes via the banner that appears at the bottom of the webpage during your first visit. You can also disable some cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you would like help managing your cookie preferences.

The effect of your choice will depend on the context in which you exercise it:

• If you opt-out of having your information shared for purposes of targeted advertising on your personal computer (PC), your choice may take effect for any PC that you have logged into with your Account.
• If you opt-out of having your information shared for purposes of web targeted advertising through our cookies controls, your choice will take effect when visiting our websites through the browser and device on which you made that choice.

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You have a right not to receive discriminatory treatment for the exercise of these privacy rights.

9. Third-Party Services

Our websites and Services may contain advertising or links to third-party services (such as the Facebook "Like" button or links to third-party websites). If you click on those links, including an advertisement, you will leave our Services and go to the third-party service or site that you selected. If you visit a third-party website or use a third-party service, you should consult that service's or site's privacy policy as your use of third-party sites or services is governed by their privacy policies.

10. Information for California Residents

A. Notice at Collection

Depending on your use of our Services, the following categories of personal information may have been collected and disclosed in the preceding twelve (12) months, as these categories are defined under the California Consumer Privacy Act ("CCPA"):

• Identifiers; such as a real name, user name, account name, email, online identifiers, device identifiers, IP address, or mobile device identifiers;
• Account login data; we collect and process the credentials necessary for you to access your Account; for any third-party connected accounts, following your authorization, we collect an access token that allows us to receive information from that third-party specific to your account with them;
• Purchase information; such as payment card number, payment account details, billing address, and other payment information;
• Characteristics of Protected Classifications under state or federal law; such as age or gender;
• Commercial Information; such as products or services interaction and purchase history;
• Internet or Electronic Network Activity information; such as, browsing history, search history, and information regarding interactions with our websites, game(s), and/or advertisements;
• Approximate (coarse) geolocation data; such as location data derived from IP address or device settings;
• Audio or Electronic information; such as when you use our communication features, or participate in multi-user projects;
• Contents of users’ in-app messaging;
• Inferences; such as consumer preferences drawn from the above.

We may collect and disclose other categories of personal information to the extent that you provide them through our game(s)’ communication features.

Collection, use, and disclosure of this information is made for one or more of the business or commercial purposes listed in Section 3: How We Use Your Information. 

We do not "sell" or "share," as those terms are defined under the CCPA, personal information of consumers for direct marketing purposes; accordingly, we do not maintain a list of third parties to whom we have disclosed personally identifiable information. We also only use or disclose “sensitive personal information,” as defined under the CCPA, for the purposes specified in Section 7027(m) of the California Consumer Privacy Act Regulations.

California permits its residents under the age of eighteen (18) who are registered users of our Services to request and obtain the removal of content or information they have posted publicly through our communications features. Other states and jurisdictions may have similar laws. To make such a request, please contact us at support@brainjar.games (or our address listed in Section 12 below) with the term ‘State Privacy’ in the subject line and include a detailed description of the posted content or information that you would like removed. 

Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third-party registered user of the Services (including content or information that you posted that was stored, republished, or reposted by the third party). 

We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

B. Supplemental California Privacy Notice

Please see below for more details about how we process your personal information, incorporating the notice immediately above.

For each of the categories of personal information referenced above:

• The categories of sources from which the personal information may have been collected are listed in Section 1: Information We Collect. 
• The categories of third-party recipients to which the personal information may be disclosed are listed in Section 4: Who May Receive Your Information. 

C. Your Rights

Please see Section 8: Your Choices and Controls for a summary of your California privacy rights and how to exercise them. This includes the right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes (also known as targeted advertising), as further described in the subsection regarding Your right to opt-out or object to certain processing.

11. Changes to Our Privacy and Cookie Policy

We may occasionally update this Privacy and Cookie Policy. When we do, we will revise the “last updated” date at the top of the policy. If there are material changes to this Privacy and Cookie Policy, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification.

12. Contact Us

BJG welcomes your comments regarding this Privacy and Cookie Policy. If you have questions about this Privacy and Cookie Policy or have technical or general support questions, please contact us at support@brainjar.games . 

You may also write to us at: Brain Jar Games, Attn: Privacy, 145 Lisbon Street, San Francisco, California, 94112. 

13. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us at support@brainjar.games. You also have the right to contact your local Data Protection Authority if you prefer, such as:

• Data Protection Authorities in the EEA;
• Swiss authorities;
• UK authority.

Where appropriate, your local data protection authority may also forward the matter to the United States Department of Commerce or Federal Trade Commission (FTC) for consideration.