Privacy Policy

How we keep you and your child safe.

Importance & Purposes

Bramble App Pte Ltd (“Bramble”, “us”, or “we”) respects your privacy and believes strongly in protecting your privacy. We understand how important privacy is to you, and we are committed to creating a safe and secure environment for users of all ages. This Privacy Policy ("Policy') applies to our website, letsbramble.com, our mobile application (“Bramble App”), which together constitute our online services (collectively, our “Services”). This Policy describes what information we collect, the purposes for which we collect it, the way in which we will use it, how we protect it, and the choices available to you regarding our use of your personal information and how you can access and update it. 

By visiting letsbramble.com or using the Bramble App or Services, you consent to our information handling practices as described in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents which you may have obtained previously provided to us. We may from time to time update this Privacy Policy to ensure that it is consistent with future developments, industry changes and/or any changes in legal or regulatory requirements.

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"). 

  1. For more information about the PDPA, please visit the Personal Data Protection Commissions website (https://www.pdpc.gov.sg); and 
  2. For more information about COPPA and general tips about protecting children's online privacy, please visit the US Federal Trade Commission’s website, OnGuard Online (http://www.onguardonline.gov/articles/0031-protecting-your-childs-privacy-online).

To summarize our data privacy commitment in plain English: 

Children’s Privacy Policy

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 privacy@letsbramble.com 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. 

In addition to the Child User’s birth date, pronoun, and nickname collected during registration as stated above, we also automatically collect usage and device information that cannot be used to personally identify the Child User, as described below. We use this information to provide the Services to the Child User, to fulfill our legal obligations, and for the purposes described in our Privacy Policy’s section “Purpose: Use of Information”. We use the Parent’s email address only to communicate with the Parent to obtain consent for the creation of the Child User’s account and the Parent’s account.  Once a Parent creates an account for the Child User, the information collection and usage policies in the rest of this Privacy Policy apply. 

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 privacy@letsbramble.com. To refuse future collection or use of your child’s Personal Information, please contact privacy@letsbramble.com.

Information Collection 

We may collect the following information about you: 

  1. Personal information including your name, email address, telephone number, age, pronoun, number of children, your child’s nickname, your child’s age, and your child’s pronoun.
  2. Audio, video, screen recordings, photographs, avatar images, or gameplay which may be linked to personal information, if you choose to submit these types of data;
  3. Unique or persistent IDs, and passwords for your account or device, which may be linked to personal information; 
  4. Information collected automatically about your usage of our Services and information collected by tracking technologies as further described below, including the frequency with which you use the features within our Services and the time spent on specific features within our Services;
  5. Approximate location information, collected automatically, not sufficient to identify which street or building you are in, but sufficient to identify your city, region or country, and time zone;
  6. Non-personal information collected automatically about your browser and/or device, including operating system version, device type, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, IP address, system performance and other diagnostic information;
  7. We may sometimes ask you for permission to access the microphone, photogallery, calendar, reminders, or other features on your mobile device;
  8. Non-personal information which may be linked to personal information, for example, nickname, number of children you have, your children’s ages and genders, whether your children have any special needs, game usage statistics, cookie information (further described below), interests, and time of day;
  9. If you participate in any of our offline activities, contact our support team, complete a user survey, or contact us in any other way, we may collect other information that you offer to us.

Information we do NOT collect

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. 

Information Retention Period

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, for our internal analysis, or for the period necessary to comply with our legal obligations, resolve disputes, prevent fraud or abuse, enforce our agreements, and conduct our normal business operations, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).  Once the retention period expires, personal information will be deleted or anonymised or aggregated, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.  Therefore, it may not be possible for us to grant access to or modify such information after the expiration of the retention period.

Withdrawal of Consent

You have the right to withdraw your consent to data collection at any time, simply by emailing privacy@letsbramble.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 privacy@letsbramble.com

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.

Purpose: Use of Information

Bramble uses the information collected with your consent or according to your instructions, in the following ways: 

  1. To create and manage user accounts;
  2. To provide, maintain and enhance our Services;
  3. To conduct research and develop marketing materials;
  4. To develop and improve new products or services;
  5. To understand, improve, and develop our Services based on usage trends, learning behaviours, and preferences of our users, to improve how our Services looks and works, and to create new features and functionality; 
  6. To ensure that content provided by the Services is presented in the most effective manner for you and for your computer or mobile device;
  7. To personalise your experience while using our Services, including for example, to remember your recent activity so we can recommend the most appropriate content for you on your next usage;
  8. To provide you with the benefits of enhancements based on feedback from our expert and professional advisors and staff, all of whom are required to adhere to this Privacy Policy.
  9. To detect, prevent, and address technical issues;
  10. To communicate with you, including for example, to respond to your inquiries or provide support, or remind you of deadlines or events, or provide news of the Services or your account;
  11. To send you promotional communications, including by email, to the extent that you have provided consent to receive such communications;
  12. To provide you with customer service communications, for example, usage satisfaction surveys in order for us to keep improving our Services;
  13. To notify you about changes to our Services;
  14. To monitor the usage of the Services;
  15. To enforce Terms & Conditions;
  16. For company operations, e.g. quality control or fraud detection;
  17. To carry out our obligations and enforce our rights arising from any contracts, including for billing and collection;
  18. To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as country, region, city, or town), in order to, for example, improve our Services or the marketing of our Services within a specific region;
  19. In the form of anonymous or aggregated data for the purpose of analysing, improving, or marketing Bramble Services;
  20. To communicate with you to ask you to complete surveys that we use for research purposes.
  21. To fulfill any other purpose for which you provide it;
  22. In any other way we may describe when we request or you provide the information; 
  23. Other purposes reasonably incidental to the above when dealing with parties to whom disclosures have been made.

Legal Bases of Personal Data Processing

The performance of the contract (the Bramble Terms of Use) between you and Bramble means that Bramble has the following legitimate interests in processing your personal data:

  1. Our business interest in providing you with the Services, including but not limited to the provision of personalised content based on the data that you have provided;
  2. Our business interest in processing and analysing your Bramble App conversations, as may be part of the personalised content that makes up the Services;
  3. Our business interest in offering you particularised or adapted content based on your usage of the Services; 
  4. Our business interest in collecting data regarding your general usage activities for the purpose of improving the Bramble user experience; 
  5. Our business interest in requesting that you partake in surveys about our Services, in order to better understand your needs and expectations, and to improve the Services;
  6. Our business interest in providing you with emails and push notifications about your Bramble account, your scheduled usage, your receipt of new content, and offers for any in-app purchases; 
  7. Our business interest in providing customer service communications, as is necessary to suit your needs and answer your questions in a clear and easy way; 
  8. Our business interest in collecting data related to unplanned downtime or errors in the Services; 
  9. Our business interest in complying with our legal obligations; and 
  10. Our financial interest in providing you with promotional offers and/or discounts with regards to the Services.

Third Party Disclosure

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:

  1. When you post content which is visible to or accessible by others on the Services; 
  2. When you consent or instruct us to share your personal information with third parties. Bramble makes use of a number of third-party gameplay analytic tools (such as but not limited to DeepAffects, Microsoft Azure, HuggingFace, WebSpellChecker, Google) to personalise your gameplay based on your personal information. More information about how your personal data is collected and processed using such third-party analytic tools can be found under “Tracking Technologies” below. You may also visit the following websites to learn more about the third-party analytic tools that we use, including their privacy policies:
  1. https://www.deepaffects.com/privacy-policy/ and https://www.deepaffects.com/terms-of-services/ 
  2. https://azure.microsoft.com/en-us/support/legal/
  3. https://huggingface.co/privacy
  4. https://webspellchecker.com/legal/privacy-policy/
  5. https://policies.google.com/technologies/partner-sites
  1. If Bramble’s service providers (such as gameplay analytics, hosting, backup, security, market analytics, and payment service providers) require this information to provide services to us. Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Bramble uses the tools provided by these service providers only after we satisfy ourselves that the service providers will maintain the confidentiality and security of your personal information, in accordance with the applicable law; 
  2. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
  3. In-app purchases are purchased from and billed by Apple or Google, and not us.  These purchases are subject to the terms and conditions and privacy policies of Apple or Google respectively.  All billing and refund inquiries must be directed to Apple or Google respectively.  We do not have access to Apple or Google accounts or transaction information.  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 or use. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. You can read their respective privacy policies at the following links:
  1. For Google:
  1. http://www.google.com/intl/it_it/policies/privacy/, or
  2. https://policies.google.com/privacy?hl=en&gl=us  or
  3. https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en; and 
  1. For Apple:
  1. http://www.apple.com/it/privacy/privacy-policy/ or
  2. https://www.apple.com/legal/privacy/en-ww/ or
  3. https://support.apple.com/en-us/HT203027
  1. When we are required by law to share your information;
  2. When we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved;
  3. If Bramble or substantially all of our assets are acquired by a third party, or in case of a merger with another company,  in which case personal information held by us about our customers may be one of the transferred assets;
  4. We may also disclose anonymous or aggregate information that does not identify you as an individual. For example, Bramble makes use of third-party analytic tools (such as but not limited to Firebase Analytics, Firebase Authentication, and Firebase Realtime Database, AWS, Squarespace, Google Drive, Jira) to better understand user data. More information about how your personal data is collected and processed using such third-party analytic tools can be found under “Tracking Technologies” below. You may also visit the following websites to learn more about the third-party analytic tools that we use, including their privacy policies:
  1. https://policies.google.com/technologies/partner-sites
  2. https://d1.awsstatic.com/whitepapers/compliance/Using_AWS_in_the_context_of_Singapore_Privacy_Considerations.pdf
  3. https://firebase.google.com/support/privacy
  4. https://support.squarespace.com/hc/en-us/articles/360000851908-GDPR-and-Squarespace
  5. https://cloud.google.com/security/compliance/gdpr/
  6. https://www.atlassian.com/trust/privacy/gdpr

Transfer of Personal Data outside Singapore

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.

Rights of Users

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 info@letsbramble.com. Your rights are as follows:

  1. You may choose not to provide Bramble with Personal Information. Registration is not required to access some of our online resources. If you decline to register, however, Bramble will be unable to provide you with certain features and functionalities of our Services. 
  2. You may modify or delete your account. Parents may modify or delete their Child User accounts. 
  3. Although we do not ordinarily collect Child User contact information, if that information is provided to us, Parents may request that it be deleted or that their Child User not be contacted.  
  4. You may unsubscribe from email communications at any time, by contacting privacy@letsbramble.com and informing us of your email address. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the Service, or technical or security notices.
  5. You may access your personal information to modify or update it at any time via your online account, in the Bramble App or by contacting privacy@letsbramble.com. Bramble will strive to respond to each request for access or correction as soon as possible or as soon as practicable, and as accurately and completely as necessary. However, please note that we may refuse your request under certain circumstances as laid out under the PDPA. We may also charge you a reasonable administrative fee for the handling and processing of your request to access your personal data. We will provide you with a written estimate of the fee we will be charging. 
  6. You may request information on what personal data Bramble has of you, or under its control. Bramble is only obliged to provide personal data that has been used or disclosed within the one year of you making this request.
  7. You may request information on the purpose of utilisation of personal data that Bramble has of you by contacting privacy@letsbramble.com. Bramble will provide this information unless doing so is likely to harm the rights or interests of a third party, or impedes laws and regulations.
  8. You may receive the personal data that Bramble has of you, or under its control, in a structured, commonly used and machine-readable format. You may transmit this data to another party or controller, without Bramble’s interference. However, this right only applies when the processing of your personal data is based on your consent, or on a contract, and such processing is carried out by automated means.
  9. To request the deletion of your personal data that we have on file please contact us at privacy@letsbramble.com. We may not be able to delete data in all instances, such as information retained in technical support logs and other business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual. Upon request, Bramble will permanently and irrevocably anonymise your data such that it can never be reconstructed to identify you as an individual. 
  10. To request that Bramble stops providing your personal data to third parties please contact us at privacy@letsbramble.com. We may not be able to delete data in all instances, such as information retained in technical support logs and other business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual. Upon request, Bramble will permanently and irrevocably anonymise your data such that it can never be reconstructed to identify you as an individual.
  11. You may lodge a complaint about Bramble’s personal data protection practices with any relevant supervisory authority. 
  12. You may give Bramble instructions concerning the use of your data after your death. Please email privacy@letsbramble.com to exercise this right. 
  13. Our response time to your request is within 30 days from receipt of your request. Such account shall be in respect of how your personal data has been or may have been generally used or disclosed within the year before the date of your request. If more than 30 working days are required, we will inform you within the first 30 days of the time when we would be able to respond to your request. 

Data Security

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. 

Data Breach

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. 

Newsletters or Other Electronic Communications 

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 info@letsbramble.com 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.

Tracking Technologies and Cookie Policy

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.

Cookies can be "Session" or, "Persistent" Cookies. Session cookies are essential to provide you with services available through the Services and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.  Persistent cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. We can also use them to compile statistical reports on website and Bramble activity. Persistent, Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Website. If you prefer to avoid the use of Cookies on the Website, first you must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.  If you do not accept Our Cookies, you may experience some inconvenience in your use of the Website and some features may not function properly.  If you would like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser. 

For any other web browser, please visit your web browser's official web pages.

Integration and Use of Third-Party Software

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. 

Mobile Analytics

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. 

Log Files

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 info@letsbramble.com.

How We Respond to Do Not Track Signals

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.

Notification of Changes

Bramble values your privacy, which is why we keep our Privacy Policy under regular review. We may update this Privacy Policy to reflect changes to our information practices. If any material changes are made, users will be notified by in-Services message, email (sent to the email address registered to your account), or by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. This privacy notice was last updated on 12 May, 2021.

Data Protection Officer 

Our Data Protection Officer is Mr. Chua Jiahao, contactable at jiahao.chua@letsbramble.com

Inquiries

We value what you have to say. Have any questions about our Privacy Policy? Get in touch with Bramble at info@letsbramble.com. Together we can effectively protect your privacy and personal information.

Effective Date: 12 May, 2021