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Last updated: October 2021

Sudbrook Dev Privacy Policy

Sudbrook Dev, including its affiliates (“Sudbrook Dev”), collects, stores, and uses your personal information as a data controller in connection with and in order to provide and develop Sudbrook Dev’s products, mobile applications, services and websites (together “Products & Services”) according to this privacy policy (“Privacy Policy”).

We are committed to protecting the privacy of all people who interface with our Products & Services. Sudbrook Dev seeks to comply with COPPA, the United State’s Children’s Online Privacy Protection Act, and CAN-SPAM, which covers the transmission of commercial email messages with the primary purpose of advertising or promoting a product. For European residents, we also seek to follow the E.U. Data Protection Directive (95/46/EC).

1. Your Acceptance

All Sudbrook Dev Products & Services are governed by this Privacy Policy and by using or accessing any one of our Products & Services you give your consent to your data being processed, used and disclosed. If you do not agree to this Privacy Policy, please do not install or use the Products & Services.

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Sudbrook Dev reserves the right to modify this Privacy Policy. Your continued use of our Products & Services will signify your acceptance of any changes to this Privacy Policy.

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2. How Sudbrook Dev Collects Your Data

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Expected situations when you make personal data available to Sudbrook Dev includes, but is not limited to: (A) by using Sudbrook Dev’ mobile apps or visiting our websites, (B) registration for our Products & Services or special events and/or contests; (C) accessing our Products & Services using a third-party identification (e.g. with social networking sites or gaming services); (D) purchasing a product or services through Sudbrook Dev’ or Apple Inc’s online stores or within the app (or "in-app purchase"); (E) asking for support for Products & Services; (G) using features in our Products & Services to share information with other people ; and (H) otherwise through use of Sudbrook Dev’ Products & Services where personal data is needed for the use and/or participation of the Products & Services.

Additionally, Sudbrook Dev may use data received from third parties related to demographic, advertisement, market and other analytics services or surveys. A list of third-party operators is below.

3. Advertising

Sudbrook Dev reserves the right to use and disclose the non-personal data collected for the function of advertising by Sudbrook Dev or Sudbrook Dev’ partners and contractors.

Sudbrook Dev may use third-party advertising serving technologies that use certain processes to collect information as a result of advertising that our Products & Services serve.

Sudbrook Dev or third parties serving the advertising may use demographic and geo-location information (see Section 4 for more information of use of location data) as well as information logged from your device or hardware (e.g. iPhone, iPod Touch, iPad or computer) to make sure that advertising shown within our Products & Services is relevant. For such purposes, Sudbrook Dev or third parties may collect and use data, including but not limited to, hardware/device type, Device ID, IP address, MAC address, installed software, application usage data, Operating System information, browser information, Internet and on-line usage information and in-game information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage.

The aforementioned data may be used and disclosed according to this Privacy Policy and the privacy policy of the company providing the advertising serving technology. The aforementioned data may be transferred, stored, and used in the United States and other countries where Sudbrook Dev or third-party advertising providers (and their service providers and customers) operate.

4. Location Data

To the extent you use Sudbrook Dev’ Products & Services that are location enabled, we may obtain, collect and use your location data to provide location related Products & Services and advertisements. E.g. some add-ons or offers may use such data so that it they are made available at specific locations.

Sudbrook Dev may use (A) rough, network-based geo-location data (based on WIFI network proximity/location and/or network tower proximity), (B) precise geo-location data (based GPS radio coordinated retrieved from your device/hardware), (C) your IP address to determine their location or (D) the regional settings that you have set on your device/hardware.

Your GPS-based geo-location will not be accessed without your consent. Notwithstanding Sudbrook Dev’s partners who are furnishing location related parts of any of the Products & Services, your GPS geo-location will not be shared with third parties without your consent. If your GPS geo-location is provided by Sudbrook Dev to third parties, it will be done so anonymously.

5. Information Analytics

Sudbrook Dev uses your information to both undertake its own analytics and to also allow analytics to be undertaken and provided by third parties. We then use this analytical information to support our business operations and intelligence, develop and improve products and services, individualize content, provide advertising, and make recommendations and/or suggestions. Sudbrook Dev may also use third-parties, such as a Google Analytics to develop, analyze and support our Services. For more information about Google Analytics and its services please see https://www.google.com/analytics

6. Social Networking Sites

Some Products & Services may be able to connect to social networking sites (for example, Facebook) to retrieve information about you. When this occurs, Sudbrook Dev may collect information from your social networking profile when you consent allow your social networking site to provide that information to Sudbrook Dev. This information includes, but is not limited to, your name, profile picture, list of friends (and their name and profile pictures). Sudbrook Dev may combine and use such information collected by us through such social networking sites.

7. Disclosure and Transfer of Personal Data to Third Parties

Sudbrook Dev may disclose and transfer personal data to third parties in accordance with this Privacy Policy and applicable legislation.

Third parties may be used to collect and process personal data on behalf of Sudbrook Dev and in accordance to Sudbrook Dev’ instructions. Your information may be transferred, stored, and used in the United States and other countries where Sudbrook Dev or third-party advertising providers (and their service providers and customers) operate. Sudbrook Dev is not liable for any acts and breaches of these third parties (except as provided by mandatory law).

Sudbrook Dev may also disclose and transfer your personal data to third parties if and when Sudbrook Dev has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Sudbrook Dev’ property, users, rights, operations or any others who may suffer loss or damage or may be harmed, or Sudbrook Dev believes that such disclosure is necessary to protect Sudbrook Dev’ rights, fight fraud, or to comply with a judicial proceeding, court order, or legal process served on Sudbrook Dev. To the extent permitted by applicable law, Sudbrook Dev will make reasonable efforts to notify you of such disclosure through Sudbrook Dev’ website or in another reasonable manner.

8. Data Retention 

Sudbrook Dev retains collected data for as long as is necessary to fulfill the purposes set out in this Privacy Policy unless a longer retention period is permitted or required by law. Thereafter Sudbrook Dev deletes all aforementioned data in its possession within a reasonable timeframe. 

Correctness of any personal data is not verified by Sudbrook Dev.

Some data may be retained longer if it is needed to resolve disputes, enforce Sudbrook Dev user agreements, and/or abide by legal and technical requirements and constraints that are related to the security, integrity and operation of the Products & Services.

9. Cookies

A cookie is a small text file that Sudbrook Dev or third parties (such as advertisers, analytics companies or social networks) may transfer to your computer/device, to identify the computer/device you are using and to “remember” things about your visit, such as your preferences or a username and password. Information enclosed in a cookie may be linked to your personal data for such purposes as improving the quality of our Products & Services, personalizing recommendations to your interests, and making our Products & Services easier to use. You can disable cookies at any time, although by doing so, you may not be able to access or use all of the features of the Products & Services.

Sudbrook Dev’ Products & Services may feature advertisements served by third parties that deliver cookies to your computer/device so that the content you access and advertisements you see can be tracked. As the third-party companies may associate your computer/device with a number, they may be able to identify and recognize your computer/device whenever they send you an advertisement or collect information for analytics. These third parties may use information about your use of Sudbrook Dev’ Products & Services and third-party sites and applications so that they can measure advertisement performance and to provide advertisements of interest to you as well as conduct other analytics. This Privacy Policy does not apply to, and we are not responsible for the data collection practices of these third parties, and we encourage you to check their privacy policies to learn more about their use of cookies and other tracking technology.

Emails and other electronic communications sent to you by Sudbrook Dev may contain technology (such as tags) that enable Sudbrook Dev to track your usage of the communication, including but not limited to if the communication was opened and which links were clicked.

10. Third-party Terms and Conditions

Note that your access to and use of Sudbrook Dev’ Products and Services may be subject to third-party terms and conditions and Sudbrook Dev is not liable for the use of your personal data by any such third-party.

Some Product & Services may offer services, such as social networking and multiplayer gaming, that may use third-party services to provide authentication for the Product & Services using social networking ID or gaming network account. In association with such use, personal information and/or membership data may be automatically transferred to Sudbrook Dev.

Your personal data may be disclosed by Sudbrook Dev to third parties in connection with any corporate merger, consolidation, restructuring, the sale of substantially all of Sudbrook Dev’ stock and/or assets or other corporate change and with any during any due diligence process provided. This Privacy Policy shall continue to cover such personal data during such an event.

11. Information security

Sudbrook Dev values the security, integrity and confidentiality of your information. We have implemented measures that are designed to protect user information from unauthorized access, disclosure or use. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

12. Other

You may decide to disclose information / data about yourself while contributing user generated content to Sudbrook Dev’ Products & Services There is no expectation of privacy or confidentiality with respect to any information / data that you choose to disclose in any of our websites, blogs, forums, chats or similar will become public information.

Sudbrook Dev may store and/or transfer your personal data to its affiliates and partners in and outside of the United States and EU/EEA member states in accordance with this Privacy Policy and mandatory legislation.

13. Special Note about Children’s Privacy

Sudbrook Dev does not knowingly collect personal information from children under 13 years old. If Sudbrook Dev discovers that it has unintentionally collected personal data from children under 13 years old, reasonable measures will be taken by Sudbrook Dev to erase such personal data its records.

For questions about Sudbrook Dev’ privacy practices related to children under 13 years old please contact us at sudbrookdev [at] gmail.com

14. Third-party Operators

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Sudbrook Dev does not use third-party operators as of October 3, 2021.

15. Contacting Us

For enquiries regarding this Privacy Policy and personal information, please contact: sudbrookdev [at] gmail.com