Privacy Policy 1. Introduction Brownapps (“Brownapps”, “we”, “our” or “us”) are committed to respecting your privacy and processing personal data in accordance with relevant laws. The Privacy Policy set out in this document relates to all websites and mobile applications owned or controlled by Brownapps at any given time. Certain parts of our Privacy Policy may relate only to some websites, apps, or categories of apps. The Privacy Policy should be read carefully to discover how we obtain, process, store and disclose your personal data. The policy also sets out your rights as a data subject. 2. Personal data (e.g. nickname, email, photo and subscription status) 1) Processing Operation and Purpose o To create an account, allowing you to use Q&A or back up content. o To provide access to Premium features if a subscription is purchased. o To notify you about material changes to the Terms of Service and Privacy Policy. 2) Lawful Basis o Necessary for the performance of a contract we have with you. o Necessary to comply with legal obligations. Some of the Mobile Apps or websites may not process every category of personal data listed above. 3. Automatic Collection, Retention and Sharing 1) Device and Usage information automatically collected In conjunction with our partners we automatically collect and log certain information stored on your terminal device ("Device Data") including device type, operating system specification, network settings, unique device identifier and IP address. “Usage Data” is collected and logged to discover how the Apps are used and which features are popular, it includes data relating to the time you are active, purchases and the features, buttons or screens you interact with. This helps to inform and improve our direction and development. We rely on our legitimate interest of measuring and analysing app usage to further inform development and improve the overall user experience. Our Analytics providers may by default use IP addresses to determine your general non-specific location. Among other things, this allows geographic sorting and protects us and our apps against misuse and nefarious activity. 2) Retention of Personal Data We are committed to the principle of storage limitation and will retain your personal data for no longer than is necessary to fulfil our processing purposes. Following account deletion, revocation of consent or a written deletion request, your personal data will be retained for no longer than 30 days, save for certain instances where legal obligations require longer retention periods. We will also anonymise some personal data so it will no longer be associated with you. In this event we are entitled to retain and use the information freely. 3) Sharing with Third Parties In order to provide you with our services, carry out our activities and to comply with legal obligations, we share your personal data with certain third parties such as: • cloud storage providers, to help us securely store and back-up your data. To be able to provide these services, the providers receive your Account Information; Photo (if provided). The providers we currently use are located in South Korea. • subscription infrastructure platforms, who facilitate the offering of in-app subscriptions. In doing so they receive your Account Information. The platform we are currently using is located in the US. • law enforcement authorities, government authorities, government bodies and the courts where they request it and disclosure is lawful. (e.g. prevention and detection of crime) 4. Security We have implemented appropriate technical and organisational security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to. These measures include encryption and pseudonymisation. Access to your personal data is granted strictly on a need to know basis. 5. Your Rights You have several rights in relation to your personal data, these include the right to: • Access a copy of the personal data we hold about you; • Correction or completion of any inaccurate or incomplete personal data; • Erasure (save for personal data necessary to comply with legal obligations or for the establishment, exercise or defence of legal claims); • Obtain a copy of your personal data in a portable format; • Restrict the processing of your personal data, in the following instances:- i. You are contesting the accuracy of your personal data and we need time to verify it. ii. Processing has been found unlawful, but you oppose erasure. iii. You require the personal data for the establishment, exercise or defence of legal claims, but we no longer need it for our processing purposes. iv. You have objected to processing based on our legitimate interests and a final decision is pending. • Withdraw consent or explicit consent for specific processing; • Object to the processing of personal data based on our legitimate interests on the grounds that they are overridden by your interests or fundamental rights and freedoms; • Object to the processing of personal data for direct marketing purposes. If you wish to exercise any of these rights, please email to brownapps@gmail.com. We may request proof of identification to verify your request. 6. Age Requirements You must be at least 13 years of age to use any of the Apps. 7. Cookies We use cookies and other such tracking technologies ("Cookies") to remember certain details when a "User" visits some of the websites owned or otherwise controlled by Brownapps. Cookies are small data files that transfer to the User's computer, phone, or other such device ("Terminal Device") upon visiting some of the websites. Information is then obtained on the return visit. Cookies are stored locally on a Terminal Device for different periods, determined by their expiry date. Session Cookies are deleted once the browser is closed, while Persistent Cookies may remain on the Terminal Device until a given date. Cookies can be categorised in two further ways: by the party that placed them ("Source"); and what they are used for ("Function"). 1) Source a. 1st Party Cookies (placed by Brownapps) b. 3rd Party Cookies (placed by Third Party Vendors) 2) Function a. Necessary Cookies b. Preference Cookies c. Statistics Cookies d. Marketing Cookies We require your consent to place Preference, Statistics and Marketing Cookies. When you visit some of our websites you will be asked for your cookie preferences by a Cookie Banner. These preferences can be changed at any time through the Cookie Settings window, accessed by clicking the black circular button at the bottom left corner of your display. For further information on the specific cookies used on a website please see the relevant Cookie Banner or Cookie Settings window. - Necessary Cookies Necessary Cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. There is no option to use the site without Necessary Cookies and unlike the latter three categories, we do not need User consent. The Cookie Banner and Cookie Settings window will by default permanently enable these cookies. - Preference Cookies Preference Cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. - Statistic Cookies Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. - Marketing Cookies Marketing cookies are used to track visitors across websites. The intention is to display advertisements that are relevant and engaging for the individual User and thereby more valuable for publishers and third party advertisers. - Disabling and Deleting Cookies The current versions of Safari and Mozilla Firefox, by default, block third-party Cookies. For more information please refer to the following blog posts regarding Safari and Mozilla Firefox. If other Browsers, such as Google Chrome or Microsoft Edge are used, third-party Cookies can be blocked manually through the Browser settings. The option may also exist in the Browser settings to block all Cookies, including strictly necessary ones. However, the websites may not work as intended, or at all. Most Browsers will allow the User to delete all Cookies or to delete them on an individual basis. The User should be aware that by doing so, their preferences for the websites may be lost. For instructions specific to a particular Browser, please refer to the online support pages provided by the Browser. 8. Contact If you wish to get in contact with us please email brownapps@gmail.com. Questions, comments and requests in relation to this privacy policy or the processing of your personal data should be addressed to our Data Protection Officer ("DPO"). DPO email: brownapps@gmail.com 9. Changes to this Privacy Policy We are constantly reviewing our Privacy Policy to ensure compliance with data protection legislation. Our apps are also constantly evolving and new features and services may change how we process your personal data. Any substantive or material change to this Privacy Policy will be brought to your attention. Last updated on May 20, 2024