Privacy Policy

1. Introduction

Brain Seal Ltd ("Brain Seal", "we", "us" or "our") is an independent video game developer and publisher registered in the United Kingdom.

We respect your privacy and believe that enjoying a video game should not require you to surrender your personal information.

This Privacy Policy explains how personal information may be processed when you play our games, visit our website or communicate with us.

It applies to all games developed or published by Brain Seal, including the Dark Quest series, Story of a Gladiator, Geometry Survivor, Monarchy, Blow it up and Dominus Gladiatus, as well as our official website at https://brainseal.com.

The information processed may vary depending on the game, platform, software version and services involved.

2. Privacy in Our Games

Brain Seal does not deliberately collect personal information from players for advertising, behavioural profiling or gameplay analytics.

Our games are designed to be enjoyed without requiring players to register a separate Brain Seal account or provide personal contact information directly to us.

Brain Seal does not operate its own systems to:

• Collect players' names or email addresses through ordinary gameplay.
• Track individual gameplay behaviour for advertising or marketing.
• Create behavioural or advertising profiles of players.
• Sell player information to advertisers or data brokers.
• Deliver personalised advertisements based on player activity.

Game progress, settings and saved games may be stored locally on your device or through storage services provided by the platform on which you play.

Certain technical information may nevertheless be processed by game engines, platform services or other software components, as explained below.

3. Game Engines and Technical Services

Some Brain Seal games are developed using third-party game engines, including Unity.

Depending on the engine version, project configuration, enabled services and gaming platform, these technologies may automatically process limited technical information.

Such information may include:

• Device and operating system information.
• Hardware and graphics configuration.
• Software version and technical settings.
• Crash reports and diagnostic information.
• IP addresses or technical identifiers where applicable.
• Information necessary for supported engine or platform functionality.

The processing performed by Unity depends on the specific products and features integrated into a game and their configuration.

Unity may process information as an independent data controller for certain activities or as a data processor acting on behalf of the game developer for others.

Where technical information is processed on behalf of Brain Seal, we remain responsible for meeting applicable data protection obligations, including identifying a lawful basis and providing appropriate transparency and safeguards.

Where applicable, we rely on legitimate interests in maintaining game functionality, investigating technical problems and ensuring software reliability, subject to the requirements of applicable law.

Players may consult Unity's Game Player and App User Privacy Policy for further information:
https://unity.com/legal/game-player-and-app-user-privacy-policy

Brain Seal does not use such technical information to create advertising profiles of its players.

Where a particular game or technology requires additional privacy disclosures or controls, these will be provided as appropriate.

4. Gaming Platforms and Third-Party Services

Our games are distributed through third-party digital storefronts and gaming networks, including:

• Steam, operated by Valve Corporation.
• PlayStation and PlayStation Network, operated by Sony Interactive Entertainment.
• Xbox and associated Microsoft services.
• Nintendo eShop and associated Nintendo services.

These platform providers may independently collect and process information relating to your account, purchases, achievements, cloud saves, device or use of their services.

Some games may also be distributed or supported by third-party publishing partners, who may independently process information in connection with their own services.

Brain Seal does not control processing activities independently determined by these third parties.

For further information, please consult the relevant provider's privacy policy:

• Steam: https://store.steampowered.com/privacy_agreement/
• PlayStation: https://www.playstation.com/legal/privacy-policy/
• Microsoft: https://privacy.microsoft.com/privacystatement
• Nintendo: https://www.nintendo.com/privacy-policy/

Where a third party processes personal information on behalf of Brain Seal rather than independently, we remain responsible for meeting our applicable data protection obligations.

5. Our Website

Our official website, https://brainseal.com, provides information about Brain Seal and its games.

We do not intentionally use our website to create advertising profiles or track visitors for behavioural advertising.

When you visit our website, hosting and infrastructure services may automatically process limited technical information necessary for website delivery, security and maintenance.

This may include:

• IP addresses.
• Browser and device information.
• Requested pages and connection timestamps.
• Technical error and security logs.

Where Brain Seal determines the purposes of this processing, our lawful basis is our legitimate interest in operating a secure, functional and reliable website.

Technical information is retained according to operational and security requirements, taking account of applicable provider retention settings and legal obligations.

Our website may contain links to external websites, digital storefronts, video-hosting platforms and community services.

Those third parties may process personal information independently according to their own privacy policies.

6. Cookies and Similar Technologies

Brain Seal does not intentionally use cookies or similar technologies for personalised advertising or behavioural profiling on its website.

Cookies, local storage or similar technologies may be used where necessary for website functionality, security or the delivery of requested services.

Third-party content, including embedded videos, may involve additional cookies or connections to external providers.

Where consent is required under applicable law for non-essential storage, access or tracking technologies, we will obtain it before those technologies are activated.

Where a lawful exemption applies but requires additional transparency or an opportunity to object, we will provide the appropriate information and controls.

We may update this section if the technologies used by our website change.

7. Contacting Brain Seal

If you contact Brain Seal by email or another communication channel, you voluntarily provide information that we may need to process in order to respond.

This may include:

• Your email address.
• Your name or display name, if provided.
• The contents of your message.
• Information about the relevant game or platform.
• Attachments, screenshots or technical information you choose to submit.

We process ordinary enquiries and customer support correspondence on the basis of our legitimate interests in responding to communications, maintaining our products and supporting players.

Where processing is necessary to perform a contract with you, we may rely on contractual necessity. Where record-keeping or disclosure is required by law, we rely on the relevant legal obligation.

We do not use support correspondence to create advertising profiles or send unsolicited marketing communications.

You are not required to contact Brain Seal in order to play our games. However, if you request a response by email, we need your email address and sufficient information to address your enquiry.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it is processed.

Support correspondence is retained according to the nature of the enquiry, whether follow-up assistance is reasonably anticipated, applicable legal obligations and the need to establish, exercise or defend legal claims.

Website technical logs are retained according to operational and security requirements and the applicable configuration of our infrastructure providers.

Where engine-related diagnostic information is processed on our behalf, its retention depends on the relevant service configuration, applicable contractual arrangements and the purpose of the processing.

Information independently processed by gaming platforms is subject to their own retention arrangements.

When personal information is no longer required, we take appropriate steps to delete or anonymise it, subject to applicable legal requirements and any justified backup retention periods.

9. Sharing of Personal Information

Brain Seal does not sell personal information.

Where reasonably necessary, personal information may be disclosed to:

• Hosting, email and other technical service providers acting on our behalf.
• Game engine or software service providers involved in the operation of relevant technical features.
• Professional advisers where necessary for legitimate business or legal purposes.
• Competent authorities where disclosure is required or otherwise permitted by law.
• Other parties where reasonably necessary to establish, exercise or defend legal rights.

Where third parties process information on our behalf, we seek to ensure appropriate contractual, confidentiality and security safeguards are in place.

We do not disclose personal information to third parties for their independent behavioural advertising purposes.

10. International Data Processing

Brain Seal is registered in the United Kingdom and its games are distributed internationally.

Personal information processed through website infrastructure, correspondence or applicable technical services may be transferred to or accessed from countries outside the United Kingdom.

Where a transfer is subject to UK GDPR or EU GDPR requirements, appropriate safeguards must be applied.

Depending on the transfer, these may include an applicable adequacy decision, approved Standard Contractual Clauses, the UK International Data Transfer Agreement, the UK Addendum or another permitted legal mechanism.

Where required, we assess transfer risks and implement appropriate additional protections.

You may contact us to request further information about the safeguards applicable to transfers of your personal information.

Third-party gaming platforms may operate their own international processing arrangements, described in their respective privacy policies.

11. Data Security

We take appropriate technical and organisational measures to protect personal information processed in connection with our website, correspondence and relevant services.

These measures may include access restrictions, appropriate confidentiality arrangements, software maintenance and other protections proportionate to the risks involved.

Only authorised individuals and service providers should have access to personal information where reasonably necessary for their responsibilities.

Although we take reasonable precautions, no method of electronic transmission or storage can be guaranteed to be entirely secure.

We will assess and fulfil any applicable legal obligations arising from a personal data breach.

12. Children's Privacy

Brain Seal does not deliberately collect children's personal information for advertising, behavioural profiling or gameplay analytics.

We do not intentionally use children's personal information for targeted advertising.

Some games and gaming platforms may be accessible to children, depending on age ratings, parental controls and other applicable restrictions.

Where children's personal information is processed through services for which Brain Seal is responsible, we will apply appropriate safeguards in accordance with applicable law.

Parents or guardians who believe that a child has provided personal information to Brain Seal inappropriately may contact us at support@brainseal.com.

Requests concerning information independently held by gaming platform providers should also be directed to the relevant provider.

13. Your Data Protection Rights

Where Brain Seal processes your personal information, you may have rights under the UK General Data Protection Regulation, EU General Data Protection Regulation or other applicable privacy legislation.

Depending on the circumstances, these may include:

• Access: Request information about the personal data we hold concerning you.
• Rectification: Request correction of inaccurate or incomplete information.
• Erasure: Request deletion of information where the applicable legal conditions are met.
• Restriction: Request that certain processing be restricted.
• Data portability: Obtain certain information in a structured, commonly used and machine-readable format where applicable.
• Withdrawal of consent: Withdraw consent where processing relies on consent.
• Automated decision-making protections: Exercise applicable rights concerning solely automated decisions that produce legal or similarly significant effects.

These rights are subject to relevant legal conditions and exceptions.

Because Brain Seal does not operate its own player-account registration system, we may not hold information identifying you in connection with ordinary gameplay.

Requests concerning information independently controlled by Steam, PlayStation, Microsoft, Nintendo or Unity should be directed to the relevant provider.

To exercise your rights concerning information processed by Brain Seal, contact support@brainseal.com.

We will respond within applicable statutory time limits. We may request information reasonably necessary to verify your identity before fulfilling a request.

Your Right to Object

Where Brain Seal processes your personal information on the basis of legitimate interests, you have the right to object to that processing in circumstances provided by law.

You may exercise this right at any time by contacting support@brainseal.com.

We will assess your objection and stop the relevant processing unless there are compelling legitimate grounds for continuing it that override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

You also have the right to object at any time to the processing of your personal information for direct marketing purposes, should such processing occur.

14. Data Protection Complaints

If you believe Brain Seal has processed your personal information in breach of applicable data protection law, you may submit a complaint to:
support@brainseal.com

Please include "Privacy Complaint" in the subject line where possible.

We maintain a process for handling data protection complaints in accordance with applicable UK law.

When we receive a complaint, we will:

• Acknowledge receipt within 30 days.
• Take appropriate steps to investigate the concerns raised.
• Keep you informed of progress without undue delay.
• Communicate the outcome of our investigation without undue delay.

You may also lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent data protection regulator:
https://ico.org.uk

Individuals in the European Economic Area may also have the right to complain to an appropriate national data protection supervisory authority.

Nothing in this Policy limits your statutory rights or available legal remedies.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our games, website, technology, service providers, business operations or applicable legislation.

The current version will be published at:
https://brainseal.com/privacy-policy/

The date at the beginning of this Policy indicates its latest revision.

Where required by law, we will provide additional notice of material changes.

16. Company and Contact Information

For privacy-related enquiries, please use the subject line "Privacy Request".

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