We take the privacy of all our users very seriously, but especially our users under the age of 13. Accordingly, this Policy aims to comply with requirements of the Singapore Personal Data Protection Act (“PDPA”) and the U.S. Children's Online Privacy Protection Act ("COPPA").
To summarize our data privacy commitment in plain English:
Protecting the privacy of children is especially important to Bramble. For that reason, we created certain features designed to help protect personal information relating to children who are less than 13 years of age (“Child Users”). Bramble does not knowingly permit Child Users to register directly for our Services without the consent of a Parent or legal guardian (“Parent”). If we learn that Personal Information of a Child User has been collected on our Services without a Parent’s consent, we will take appropriate steps to delete this information. If you are a Parent and discover that your child under the age of 13 has a registered account with our Services without your consent, please alert us at firstname.lastname@example.org and request that we delete that Child User’s personal information from our systems.
Child Users cannot sign up for a Bramble App account. When any user registers for our Services, we request their birth date. Should their age indicate they are below 13 years of age, we request the Child User’s Parent’s email address, so that we can email their parent to ask the Parent to create an account instead.
Bramble App is designed to be used by parents and children together. As such, we believe that it is more suitable for Bramble App to be installed on parents’ devices. Child Users are therefore only users through, and together with, their Parent.
Bramble App does not ask the potential user for any more information than is necessary to provide the Services. Until a Parent creates their account, a Child User will not be able to access our Services, except for pages which do not collect any of the Child User’s personal information.
Bramble does not display any targeted advertising on our Services. We do not disclose personal information of Child Users for direct marketing purposes or for targeted advertising purposes.
As a Parent, you have the ability to access information about your Child User by contacting email@example.com. To refuse future collection or use of your child’s Personal Information, please contact firstname.lastname@example.org.
We may collect the following information about you:
Bramble does not and will not collect or process credit or debit card (“Payment Card”) information. However, Apple and Google collect Payment Card information with respect to in-app purchases made through the Services. We do not receive or have access to any payment data, such as credit card number, billing name and address, CVV/CVC number, or password or PIN that Apple or Google respectively might collect. Such payment processors may provide us with some limited personal information about you, such as a “unique token” that enables you to make additional purchases using the information they have stored. In the event that this information is made available to Bramble, we will not store it. Such information will be discarded.
You have the right to withdraw your consent to data collection at any time, simply by emailing email@example.com. Once you have withdrawn your consent, Bramble will no longer process your personal data.
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing firstname.lastname@example.org.
Please note that if you withdraw your consent to the collection, use and/or disclosure of your personal data, depending on the nature of your request, we may not be able to continue providing our services or performing our contractual obligations to you. Such withdrawal may also result in the termination of any agreements or arrangements you may have with us. Our legal rights and remedies are expressly reserved in such an event.
Please note that it may take up to 4 weeks for any request for any withdrawal of consent to take effect.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable law.
Bramble uses the information collected with your consent or according to your instructions, in the following ways:
Bramble cares deeply about your privacy. We do not rent or sell to third parties personal information that we collect from any users.
To use the services of third parties, Bramble may disclose personal information to third parties as follows:
Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes obtaining consent from you to transfer your personal data overseas, and before you give consent, providing you with a reasonable written summary on the extent of the protection offered to the personal data to be transferred overseas, and/or taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the standard of protection under Singapore’s PDPA.
At Bramble, we use Personal Information only for the purposes for which it was collected or where you have consented to our use of your Personal Information. We take reasonable steps to ensure that the Personal Information we store and use is accurate, complete, and up-to-date. If you discover that Personal Information or other data pertaining to you is inaccurate, incomplete, or out-of-date, please update your account information or contact us at email@example.com. Your rights are as follows:
We greatly value your trust. Information that you share on our Services is kept strictly confidential and fully secure. Your personal information is protected using Secure Socket Layer (SSL) or Transport Layer Security (TLS) as it passes between your device and our servers. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and upon receiving it.
Where we have given you or where you have chosen a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and highly recommend that you change your password frequently.
We adopt physical as well as technical measures to protect your data - we only allow authorised personnel to access your personal data, and we maintain strong password policies for all electronic files containing your personal data.
No method of transmission of information via the Internet or method of electronic storage is 100% secure. We will make all reasonable efforts to protect your personal information at all times. However, we cannot guarantee the absolute security of your information.
In the event we become aware that the security of our website or Bramble has been compromised or users’ personal information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with appropriate law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on our website. We will notify the relevant Supervising Authorities of a personal data breach within 72 hours of learning of the breach.
If you sign up to receive promotional materials from us via email, we will use the information you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe" at the bottom of any such communication or by contacting us at firstname.lastname@example.org we will remove you from our mailing list. If you no longer wish to receive push notifications on your mobile device, you may turn them off using your mobile device settings.
If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Bramble App, you will receive such an SMS message. Standard text message rates will apply.
Bramble and the analytic tools we use make use of technologies, including cookies and tags, for example to enable a service to recognise your device so you do not have to provide the same information several times during one task, to recognise that you may have already given a password so you do not need to do it for every web page requested, and to measure how people are using the Services.
Like most websites, we use 'cookies' and similar tracking technologies (like web beacons or pixel tags), collectively “Cookies”. This Cookies Policy explains what Cookies are and how we use them. Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from Cookies. We do not store sensitive personal information, such as mailing addresses, account passwords, etc. in the Cookies we use.
For any other web browser, please visit your web browser's official web pages.
We make use of third-party gameplay analytics software to enhance your Bramble App experience. These softwares may receive and process your personal information, including but not limited to voice recording data, photographs of your face or your Child User’s face, and a transcript of your conversation using the Services.
We may link the information we store within the third-party gameplay analytics software to any personal information you may submit to us. For example, we may link analytics results from your conversation transcripts using Bramble App to users in order to further personalise interventions for your gameplay experience, and in order to better understand how our game is being played by different people, so as to improve our Services.
You may choose not to share your personal information with our third-party gameplay analytics software partners. Bramble App will prompt you for permission before we start collecting such personal information to be processed through our third-party gameplay analytics software partners. If you decline to provide such personal information, however, Bramble will be unable to provide you with certain features and functionalities of our Services.
We make use of mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Services, the events that occur within the Services, aggregated usage and performance data, and where the applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit to us. For example, we may link gameplay statistics to users in order to better understand how our game is being played by different people, so as to improve our Services.
We gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Your clicks on links are also saved. These and the open statistics are used in aggregate form to, among other things, give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
To learn more about how we collect and process user data from our Product using a third-party analytic partner, please visit https://policies.google.com/technologies/partner-sites. Users may request to have their personal data deleted and/or anonymised by contacting email@example.com.
Do Not Track (“DNT”) is a setting in a web browser that requests websites not to track your behavior. You can activate the DNT settings through most browsers.
We do not track users over time and across third party websites, so we do not respond to DNT signals.
Our Data Protection Officer is Mr. Chua Jiahao, contactable at firstname.lastname@example.org.
Effective Date: 12 May, 2021