1.General Information
This privacy policy explains the type, extent, and purpose of processing personal data within our app, along with the related features and content. We aim to make our privacy policy clear and easily understandable for all users. Therefore, we use the official terminology of the General Data Protection Regulation (GDPR) throughout our privacy policy.
This Data Privacy Statement applies for the offering and use of the "STG play and win real reward App" (hereinafter referred to as “The App“ or “our App”), which is provided to you by Brays (hereinafter referred to as “we” or “us”) for use on your mobile device.
1.1 Controller within the meaning of data protection law:
Brays is the “controller” in accordance with the applicable data protection law, in particular the EU General Data Protection Regulation (GDPR).
Should you have any questions or comments about data privacy when using "The App" , please feel free to contact us by email to brays.ex.info@gmail.com
Contact details:
Rasha ALI
MG 2 Q 552 H2
Giza 12511
1.2 Data Protection Officer
Rasha ALI
MG 2 Q 552 H2
Giza 12511
When contacting Data Protection Officer, Please refrain from enclosing sensitive information such as a copy of an identification document with your request.
2.Data collection regarding the use of our app
We place a high priority on safeguarding your personal data, treating it with strict confidentiality and in compliance with statutory data protection laws and this privacy policy.
When you download, register, log in, or use our app, specific personal data is processed.
Personal data includes information that can be used to personally identify you.
This privacy policy outlines the data we collect, how we use it, and the purpose behind its processing.
2.1 Accessing and Storing Information
When you use our app, it may involve accessing information (e.g., IP address) or storing information (e.g., cookies or similar technologies) on your device. This access or storage may also entail further processing of personal data under the GDPR.
If such access or storage is strictly necessary for the error-free technical operation of our services, it is carried out according to § 25 para. 1 s. 1, para. 2 no. 2 TTDSG.
If this processing serves additional purposes (e.g., tailoring our app to user needs), it will only proceed based on § 25 para. 1 TTDSG with your explicit consent in line with Art. 6 para. 1 lit. a GDPR. You may withdraw this consent at any time, effective for future actions.
For more detailed information on how your personal data is processed and the applicable legal basis, please see the sections below that address specific processing activities within our apps.
2.2 Information Collected When Downloading the Apps
When you download our apps, certain necessary information is transmitted to the app store you are using (e.g., Google Play Store, Apple App Store). This may include data such as IP address, unique device ID, location, date and time of the request, time zone difference from Greenwich Mean Time (GMT), request content (specific page), access status/HTTP status code, amount of data transmitted per request, app usage data, operating system, and interface language. We do not control this data collection and are not responsible for it. The contract is directly with the app store provider and is governed by their terms and privacy policy.
In relation to your use of the app stores, we only process reviews and related data you publish about our apps and receive anonymized statistics from the stores, such as download numbers, uninstall rates, and crash reports.
2.3 Data Processing When Using the Apps
When you use our apps, we collect certain data essential for their functionality and performance. This includes processing data such as the internal device ID, operating system version, access time, IP address, content accessed, and country of access. This data helps us provide services and features, as well as prevent and resolve issues or misuse.
If you use our app, we collect and share data related to your in-app progress and interactions with our partners’ offer walls, along with advertising data. This data is linked to you via identifiers (GAID, Google App Set ID, IDFA, IDFV, or App User ID). We use DigitalOcean LLC Corporation (101 6th Ave, New York, NY 10013, USA) as a service provider for hosting, as detailed in their privacy policy.
This data processing is justified under Art. 6 para. 1 lit. b GDPR as necessary for contract performance and is based on our legitimate interests under Art. 6 para. 1 lit. f GDPR to ensure app functionality and reliability.
Our app is hosted by DigitalOcean LLC, 101 6th Ave, New York, NY 10013, USA, which processes data on global servers. Personal data collected is stored on these servers, and a Data Processing Agreement under Art. 28 GDPR ensures data protection and prohibits third-party access.
To access additional app features, you may be asked to provide certain data, which will only be processed upon your submission.
For rewards payments, we may request your full name and email to pass to an external provider (e.g., PayPal, 2211 N 1st St, San Jose, CA, USA), as outlined in their privacy policy. Note that we do not handle payment or bank data directly, as these are managed by external providers.
For customer management, we process user data using DigitalOcean LLC services. This processing is justified by Art. 6 para. 1 lit. b and f GDPR.
You can request changes or deletion of your data by contacting us at brays.ex.info@gmail.com,except where legitimate interests apply as per GDPR’s “right to erasure.”
Where data processing for the app services qualifies as personal data processing, it is based on Art. 6 (1) b. or f. GDPR, aimed at service provision and improvement based on our legitimate interests.
2.4 Technical Functions of the App
To use additional features beyond the app’s basic functions, specific permissions may be requested:
Push Notifications:
Push notifications keep you updated on various aspects of the app, including:
Permissions for these notifications are explicitly requested, and you can choose to accept or deny them. For older operating systems, explicit permission requests might not appear, as push notifications may be enabled by default.
If you grant permission, the processing of your data for these notifications is based on your consent, as outlined in Art. 6 para. 1 lit. a GDPR. You may revoke this consent at any time, effective for future use. To do so, permissions can generally be adjusted in your device’s settings, though this may vary by device and operating system. Please note that revoking permission does not affect the lawfulness of prior data processing.
Be aware that not granting certain permissions may limit the functionality of the app.
2.5 Contact via Support Tickets or Email
If you send us inquiries through our contact form or via email, the information you provide, including your contact details, will be stored to process your request and for any follow-up questions. This information will not be shared without your consent.
The legal basis for processing this data is our legitimate interest in responding to your inquiries as outlined in Art. 6 para. 1 lit. f GDPR, and where applicable, Art. 6 para. 1 lit. b GDPR if your request is contract-related. You may object to the processing of your personal data at any time under Art. 6 para. 1 lit. f GDPR.
Additionally, we may contact you via the app or email regarding app usage or similar services, based on Art. 6 para. 1 lit. b or f GDPR.
For these purposes, we use service providers such as Gmail (1600 Amphitheatre Parkway, Mountain View, California) and DigitalOcean LLC (101 6th Ave, New York, NY 10013, USA).
2.6 App Payout Functionality
Please note that Rasha ALI is the sole controller for the data processing described here.
You can download our app from the app store without needing to register. No personal data is collected by us during the download process, and no personal data is shared with us by the app store provider. However, if you wish to use the payout functions within the app, additional details are required to process the payment, handled by external payment service providers. User payment data is transmitted to these providers.
The data provided for payout purposes is processed to fulfill a contract with the user or to take pre-contractual steps (Art. 6 para. 1 lit. b GDPR). Any optional information provided by you is processed based on your explicit consent (Art. 6 para. 1 lit. a GDPR), which you may revoke at any time by sending an informal email to the controller’s contact details listed at the start of this privacy policy. Revoking consent does not affect the legality of any processing conducted prior to the revocation.
If you choose to register via Google (Google login), we will process your email address and name as shared from your Google user profile, following your consent. For more information on data processing by Google For further details on data processing on Google please refer to: https://policies.google.com/privacy
2.7 Declaration Of AAID Use:
Why is the Advertising ID Declaration Important? The Advertising ID (AAID) is a unique identifier that Google assigns to each Android device. It is used by advertisers to track users across different apps and devices and to serve more targeted ads.
Advertising Use: Our app and our partners will never connect your advertising identifier (AAID) to persistent device Identifiers.
Our app will connect your advertising identifier (AAID) to personally identifiable for fraud detection only after explicit consent of you .
Analytics Use: our app and our partners will never connect to personally identifiable information or associated with any persistent device identifier for any analytics purpose.
AAID Reset: for fraud detection purpose, if you reset your advertising identifier (AAID) our app will connect your new advertising identifier or data derived to your previous advertising identifier only after your explicit consent.
AAID Delete: if you delete your advertising identifier (AAID) our app and our partners will never connect or use your previous advertising identifier for any purpose.
Opting Out: If you opt out of interest-based advertising or personalized advertising, your advertising identifier (AAID) will no longer be used for any advertising purposes. Its use will be restricted to contextual advertising, Appear limitation, conversion tracking, reporting, and safety and fraud detection.
in the next dialog box, you can customize your preference settings and you can back to change it any time from the side menu in our app.
Your personal data will not be transferred to third parties unless:
We also use carefully selected external service providers for processing services. These providers are bound by our instructions, undergo regular monitoring, and have signed data processing agreements in line with Art. 28 GDPR. These agreements cover services such as app hosting, email distribution, and IT updates and maintenance.
When you use our apps, your data may be processed in countries outside the EU and EEA that do not have an adequate data protection level, such as the U.S., especially if you have consented to data transfer to our advertising partners.
To ensure data protection when transferring data to these third countries, we implement the European Commission’s standard contractual clauses under Art. 46 (2) lit. c GDPR, requiring recipients to handle data according to EU protection standards. You may request a copy of these clauses via our contact information.
If standard data protection clauses alone do not guarantee sufficient protection, additional technical, contractual, or organizational measures are implemented. We regularly review these measures to maintain adequate data protection levels, making adjustments as necessary.
The retention period for personal data is determined by statutory storage requirements (e.g., commercial and tax law). Data is routinely deleted once these periods expire. If data is needed to fulfill a contract or initiate one, or if we have a legitimate interest in continued storage, it will be deleted once it is no longer required for these purposes or if you exercise your right to withdraw consent or object.
Your profile and account data are deleted promptly after you delete such data in your app account or remove the entire account through the app’s delete function, in line with our standard deletion processes.
Our app utilize “cookies” and similar technologies with various functions. Some cookies are essential for technical reasons, enabling certain app functions that wouldn’t work otherwise, while others help analyze user behavior or display advertising.
The processing of data via strictly necessary cookies or similar technologies is based on § 25 para. 1 s. 1, para. 2 no. 2 TTDSG and our legitimate interest, as per Art. 6 para. 1 lit. f GDPR, in providing our services without technical errors.
Processing personal data through other cookies or similar technologies is based on user consent, as per § 25 para. 1 TTDSG and Art. 6 para. 1 lit. a GDPR. You may revoke your consent at any time, effective for the future.
More details on processing purposes and our advertising partners are provided in the sections below.
Purposes:
You can change your privacy settings or withdraw your consent at any time by opening the menu point Privacy Settings.
Below is an outline of your rights as a data subject, granted to you under current data protection law with respect to the processing of your personal data:
If you would like to exercise any of these rights or require further assistance, please reach out to us at the contact details provided.
If we process your personal data based on legitimate interests as outlined in Art. 6 para. 1 lit. f GDPR, you have the right, under Art. 21 GDPR, to object to the processing of your personal data at any time for reasons related to your particular situation. If your objection concerns the processing of personal data for direct marketing purposes, you have a general right to object without needing to provide a specific reason.
To exercise your right to withdraw, object, or any other rights, please send an email to brays.ex.info@gmail.com
Providing personal data for purposes such as deciding on the conclusion of a contract, fulfilling a contract, or implementing pre-contractual measures is voluntary. However, we can only proceed with contractual actions if you provide the personal data necessary for concluding or fulfilling the contract or for carrying out pre-contractual measures.
For fraud detection and prevention purposes, certain criteria—such as IP addresses and gaming behavior—are automatically assessed. If multiple indicators of fraudulent activity are detected, users may be partially or fully restricted from using the app. This data processing is necessary to properly fulfill the contract with the user, as per Art. 6 para. 1 lit. b GDPR and Art. 22 para. 2 lit. a GDPR. The data is deleted following the evaluation.
Organizations typically process data for market research and advertising purposes. Website providers use cookies that load onto your browser to recognize when you return to the same site. The collected data is used to create user profiles, which may be employed to display targeted advertisements on or off the platform. Additionally, these profiles may include data gathered from memberships on other platforms.
We collect data when you contact us, for instance, via a contact form or messaging services such as Support Tickets. The data collected depends on the information you provide, and the contact details specified. This data is stored to process your inquiry and for any follow-up questions. We will not share this data with third parties without your consent.
The legal basis for this data processing is our legitimate interest in responding to your inquiry, in accordance with Art. 6 para. 1 lit. f GDPR, and, if applicable, Art. 6 para. 1 lit. b GDPR if your inquiry pertains to concluding a contract. Unless there are compelling reasons to retain it, your data will be deleted after final processing, which we consider complete once the related matters are resolved.
If your request via email, social media, or other platforms is related to concluding a contract for the delivery of goods or provision of services, we process your data to fulfill the contract and requested services or for pre-contractual measures. In such cases, the legal basis for processing your data is Art. 6 para. 1 lit. b GDPR.
Your data will be deleted when it is no longer needed for contract fulfillment, or if it becomes clear that pre-contractual measures will not result in a contract. Please note that we may need to retain personal data of our contractual partners to meet contractual or legal obligations, even after the contract is concluded.
If the respective platform providers request you to consent to the processing for a particular purpose, the legal basis for the processing is Art. 6 para. 1 lit. a, Art. 7 GDPR. You have the right to withdraw such consent with effect for the future at any time.
These provisions apply to California residents and outline rights granted under the California Consumer Privacy Act of 2018 (CCPA), including the right to know, delete, and opt-out, as well as requirements for businesses handling personal information.
Categories of Information Collected
Right to Know and Right to Delete
California residents may request to know what personal information we have collected, used, disclosed, and sold, and may also request deletion of their personal information.
To exercise these rights:
Send an email to brays.ex.info@gmail.comwith the subject line “California Rights Request.” We will verify your identity using information we maintain. In some cases, we may decline requests if identity verification is unsuccessful.
Upon verifying your request, we will delete your information (and direct service providers to do the same), except where retention is necessary to complete transactions, detect fraud, resolve errors, exercise legal rights, or fulfill other lawful uses.
Right to Opt-Out of Sale
The CCPA allows California residents to opt out of the “sale” of their personal information. While we do not “sell” information as typically understood, we allow certain third-party networks to collect data through cookies and tracking technologies for purposes like advertising and analytics.
Non-Discrimination
You have the right not to be discriminated against for exercising any of the rights provided by the CCPA.
If you are a California resident and wish to exercise your CCPA rights, please email brays.ex.info@gmail.com.
Authorized agents may submit requests on behalf of a consumer with appropriate evidence and verification of identity.
We strive to respond to requests within 45 days. If more time is needed, we will notify you of the reason and the extension period.
We reserve the right to modify or update this privacy policy as needed to comply with applicable data protection regulations. This allows us to align it with current legal requirements and account for changes to our services, such as the introduction of new offerings.
Have a Questions?
If you have any inquiries or additional questions regarding the processing of personal data, please contact us at brays.ex.info@gmail.com.