Privacy Policy

Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information. This Privacy Policy applies when you use any of the Apps of  Brewblack ltd. Publisher and should be read together with Terms of Use. By using our Apps, you are consenting to our processing of your information in ways set out in this Privacy Policy. If you do not agree with it, please do not use any of our Apps. In certain cases, for example, if geolocation data is processed by the relevant App, the App will prompt you to give additional consent. In such a case, you can choose not to give consent to us processing data related to your location but you can still use the Publisher’s App. From time to time, Publisher may modify this Privacy Policy so you should review it regularly.

Information we collect

Information you share with us or give us permission to obtain

When you use Apps, Publisher may collect data, including information which directly or indirectly identifies you. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. The information we collect about you includes:

Technical information

 When you use a website or mobile application like ours, certain internet and electronic network activity information gets created and logged automatically.  These are the types of technical information we collect:

  • We will collect information about you when you interact with us such as when you report a problem, contact or communicate with us.

  • Log data. Our servers passively keep an electronic record of your interactions with our services, which we call “log data”. For example, when you visit our website, sign into our services, or browse content, we collect data about these interactions that includes where you navigate within our website and apps, your IP address, browser type and settings, the date and time of your visit, search terms, which elements of our site and services you use the most, device data, and cookie data. We use log data to operate our services, maintain security, ensure reliable performance, and improve your experience.

  • Cookie data. We use “cookies”  and similar technologies to collect log data and operate our services.

  • Device data. We collect and combine data about the devices you use, and data about your device usage and activity. We may collect certain device information and electronic identifiers such as your mobile device identifier provided by your mobile device operating system, your mobile operating system details and the name of your mobile carrier, hardware and software information such as app version, app crashes, device type, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser. For example, if you use the iOS platform then Advertiser IDs (also known as “IDFAs”) may be collected. Other identifiers collected may include IP addresses, OpenUDID, Session ID, ODIn1, iOS Vendor IDs, MAC addresses, IMEI.

  • To use certain features in our services, you may allow us to access your camera or the microphone.

  • Information about how and when you use the Publisher’s App. This includes the amount of times you used the Publisher’s App, which parts of it you viewed and other technical data such as country settings and timestamps.

  • Geolocation data, which is any information which indicates the geographical position of your device and which may include the time the location was recorded. Before processing any precise GPS geolocation data, the Publisher’s App will require you to give your consent, which you can revoke by changing the privacy settings of your device.

  • Information on your wireless and mobile network connection, like your service provider and signal strength.

  • If you opt-in, some services may collect movement data from your device. In addition to the information you provide us directly, we receive information about you from other services, including: If you purchase a subscription in our apps, Apple provides us with any personal information of the subscription purchaser (like name, email or payment information). Only anonymized data gets passed to us.

 How we use the information we collect, and legal bases for use

We process your information:

  • To fulfill a contract, or take steps linked to a contract, including:

  • Receive, process, and confirm your subscription or registration, and communicate with you about your account

  • Allow you to sign in to your account.

  • Verify your identity.

  • As required to conduct our business and pursue our legitimate business interests, in particular:

    • Help you when you make customer service requests.

    • Prevent fraud, abuse, and other misconduct on our App

    • Help us diagnose technical and service problems and administer our website and apps.

    • Conduct research and development (e.g. by conducting user surveys) to improve our Apps and develop future products.

    • Understand how you use the service, to create a better experience for you and other users. This includes making inferences, like what content you may be interested in, based on how you use the service

  • When required, with your consent:

    • Market our services and deliver targeted advertising to you, unless you opt out, as controlled by your email and privacy preferences

    • Send cookies or similar technologies to your device, as described in “cookies and similar technologies” below.

  • For legal reasons:

    • Verify your identity to comply with law.

How and when we share your information

  • Service providers we use to process information on our behalf, for the purposes we describe in this Privacy Policy. For example, we may contract with businesses for web hosting and maintenance, security and spam detection, data storage, and analytics and advertising. We only engage businesses we believe are trustworthy and who have confirmed their privacy practices are consistent with ours, and we only provide the information necessary for them to perform these services on our behalf. Each service provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your information from unauthorized access, use, or disclosure. Service providers may only use your personal information in ways we specify.

  • Government and law enforcement bodies. We share information when we believe that disclosure is reasonably necessary or appropriate to comply with law, regulation, or legal request; or to detect, prevent, or stop any illegal, unethical, or legally actionable activity.

  • Our subsidiaries and affiliates. We share your personal data with our subsidiaries in order to provide our services to you. We require that our subsidiaries protect your personal information consistent with this privacy policy. If we were to engage in a merger, acquisition, bankruptcy, or other transaction that involves the transfer of the information described in this Privacy Policy, we may share your information with the parties involved in that transaction.

Cookies and similar technologies

 We use cookies (a small text file placed on your computer or mobile device to identify your computer and web browser) and may use anonymous identifiers (random strings of characters that are used for the same purposes as cookies). Some cookies are “session cookies” that last until you close your browser, and others are “persistent cookies” that last until you or your browser deletes them.

We use cookies and similar technologies to analyze use of and improve our website and services, to see which areas and features of the website are most popular, to count the number of devices accessing, to personalize your experience, and to remember your preferences as described in “Interest-based advertising”.  For example, we use cookies to store your language preferences.

Most web browsers are initially set up to accept cookies. You can set your web browser to refuse all cookies or to indicate when a cookie is being sent; however, certain features of the website or services may not work if you delete or disable cookies.  Some of our service providers may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.


Analytics services

 We use third-party analytics service providers such as Google Analytics, Google’s Crashlytics and Firebase services, and Facebook. We may disclose your site use information to these analytics providers to help us learn more about how you and others use our services:

Your options

On your iOS device you can open the Settings app to change the camera, photos, and other permissions you grant our Apps, ad tracking, and other settings.

You can opt out of receiving marketing emails by using the “unsubscribe” link or other means specified in marketing emails you receive from us. However, you cannot opt out of receiving all emails from us, such as service announcements and emails about the status of your account.

Our policy on children’s information

 Some of the publisher’s Apps are not directed to children under the age of 13. We do not knowingly collect (or knowingly allow any third party to collect) information from persons under the age of 13. If we become aware that information has been collected from a person under the age of 13, we will delete this information and terminate the person’s account as quickly as possible. If you believe that we may have information from or about a child under the age of 13, please contact us and we will promptly delete that information.

 International transfer

We operate worldwide, and we may move, process, and store your data in other countries where we operate, which may be outside the country where you live. Not all data protection laws are the same. Some countries where we transfer personal data may allow government authorities greater access than your country does.

See the section for EU and UK residents below to learn more about data transfers to and from that region.


European Union and UK residents

If you reside in the UK or another member state of the European Union, you have certain rights under EU data protection legislation. You can ask us to:

Confirm we process your personal data, and ask what personal data we have about you.

Change or fix your data.

Delete your data.

Stop using some or all of your data if we have no legal right to keep using it.

Give you a copy of personal data you provided to us, in machine readable format.

If you wish to exercise any of these rights, please email us. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If you think we haven’t complied with data protection laws, you also have a right to file a complaint with your local data protection authority.

To verify your identity when you make a request, you must provide us with your email address and respond to an email verification request. We will match that information to the information we have in our systems.

Because our Apps are a worldwide service, we may transfer the personal data of EU residents to a country outside of the EU and the UK. When we do, we do so under the EU’s model contracts for the transfer of personal data to third countries (known as “standard contractual clauses”).


California residents

If you are a California resident, you have the following rights under the California Consumer Privacy Act and California Privacy Rights Act:

You have the right to know what personal information we have collected about you in the preceding 12 months, including sources, purpose of collection, and third parties we have shared it with.

You can ask us to delete your personal information.

You can ask us not to share or sell your information with any third party.

You can email us to submit your request. You must use “California Request to Know Information”, “California Right to Know Categories,” “California Right to Delete,” or “California Right on Opt out of Sale” in the subject line of your email, as appropriate. You must provide us with your first name, last name, phone number, and the email address. Each request must be sent separately. 

To fulfill your requests, we must be able to verify your identity in our systems against the identity you provide. You’ll need to provide us with your email address and respond to an email verification request, so we can match that information to the information we have in our systems.

We will process your request in an efficient manner, but we may not be able to delete your personal information (i) if we have to complete an ongoing transaction with you, (ii) if we detect or need to address a data security incident, (iii) in order to correct or repair an error, (iv) in order to protect against fraudulent or illegal activity, (iv) in order to comply with a legal requirement, or (v) if we use it internally in a lawful manner to improve our services. We will also maintain a record of your requests. If we delete your personal information, many of our services will not work the same for you. We do not knowingly sell the personal information of minors under the age of 16.


How we make changes to this policy

We may change this Privacy Policy from time to time to reflect our current practices and ensure compliance with applicable laws, so please check back frequently for changes. If we make material changes, we may notify you through other methods as required by law, such as in our mobile applications, by sending email to the email address associated with your account, or by push notifications to your device if you’ve enabled them. If you continue to use our Apps after those changes are in effect, you agree to the new policy.

Last updated: September 13, 2022