About this Privacy Policy

This Ben Family privacy policy (the “Privacy Policy”) applies to the personal data that we collect from you when you use our website http://updatesvision.com (the “Website”) and our mobile applications named Ben Family  Learning Academy and Kids Puzzle Games by Ben Family (the “Apps”) (collectively, “Ben Family”). Our Privacy Policy tells you what personal data and non-personal data we collect from you, how we collect them, how we protect them, how we share them, how you can access and change them, and how you can limit our sharing of them. The Privacy Policy also explains certain legal rights that you have with respect to your personal data.

Definitions
          • ‘NON-PERSONAL DATA’ is information that is in no way personally identifiable.
          • ‘PERSONAL DATA’ means any information relating to an identified or identifiable natural person (‘data subject’), such as the data subject’s name, identification number, location data, or an online identifier. Personal data is in many ways the same as Personally Identifiable Information (PII). However, personal data is broader in scope and covers more data than PII.
         • ‘GDPR’ means the EU General Data Protection Regulation (2016/679).
         • CCPA’ means the California Consumer Privacy Act of 2018. 


Information we collect and how we collect it

When you use Ben Family, we may ask you to provide your personal data to us. For transparency purposes, we explain in detail what personal data we collect and have access to, the purposes for which we use them, and legal bases on which we rely when processing your personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of Ben Family use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not re-purpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.


Personal data collected through the Apps

When you use the Apps, we collect your email address, name, and age. We use such data for the following purposes:
         • To validate your age;
         • To store your game progress;
         • To register and maintain your user account;
         • To allow you to play from multiple devices;
         • To send promotional emails (if you consent to them); and
         • To reply to your support emails, if you send us any. We keep the data listed above until you stop using the Apps (e.g., uninstall the Apps).

In addition, we automatically collect certain information that is later used for re-engagement and re-attribution purposes. Please note that, although certain information (like your device ID) may be considered by certain laws personal data, such technical data does not allow us to identify you as an individual by any means and we do not intend to do so. The types of the technical information that we automatically collect through the Apps are mentioned below:

         • Timestamps telling us when you install or first launch the App;
         • Information about how you use the App;
         • Your device ID;
         • The URLs that you click on before accessing the App or later;
         • Information sent by self-reporting networks like Facebook, Snapchat, and Google Ads;
         • The ads that you click on or view; and
         • Your other online behaviour data. We use the technical information listed above to analyse your use of the Apps, find out how you find the Apps, examine the reasons that encourage you to install or delete the Apps, and track your online behaviour. We keep such data as long as it is necessary for its purposes, but no longer than 1 year.

The legal bases that we rely on when collecting and using your personal data are “performing a contract with you,” “your consent” (for promotional emails, marketing and advertising), and “pursuing our legitimate business interests” (i.e., to ensure the security of the Apps and our compliance with the applicable laws, as well as to analyse and grow the Apps). 

Analytics data

When you use the Apps downloaded from Google Play Store, we use our third-party analytics service provider Firebase (https://firebase.google.com) offered by Google, which automatically collects the following technical personal and non-personal data from you:

         • IP address;
         • Number of sessions;
         • Session duration;
         • Retention;
         • Events;
         • Install source; and
         • IDFA.
We use such data to:

        • Analyse the technical aspects of your use of the Apps;
        • Optimise the Apps for your needs;
        • Prevent fraud and abuse of the Apps;
        • Ensure the security of the Apps; and
        • Serve you relevant ads.

We keep such data as long as it is necessary for its purposes, but no longer than 1 year. The legal bases that we rely on when processing the above-mentioned data are “pursuing our legitimate business interests” (i.e., to analyse, grow, and protect KLA) and “your consent”. 

Contact with us

When you contact us by email or by using the contact form available on the Website, we collect yourname, email address, and any information that you decide to provide us in your message. We use your personal data to respond to your enquiries and provide you with the requested information. The legal bases that we rely on when processing such personal data are “pursuing our legitimate business interests” (i.e., to grow and promote Ben Family) and “your consent” (for optional personal data that you decide, at your sole discretion, to provide us). We keep such data until you stop communicating with us.  


Our Security Policy

We have built Ben Family using industry-standard security measures and authentication tools to protect the security of your personal data. We and the third parties who provide services to us also maintain technical and physical safeguards to protect your personal data. Our security measures include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymisation of personal data (when possible).

Unfortunately, we cannot guarantee prevention of loss or misuse of your personal data or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for Ben Family and not share it with anyone.

Transferring Personal Data from the EEA

The personal data that we collect from you may be stored, processed, and transferred among any countries in which we or our data processors operate. The European Union has not found the United States and some other countries to have an adequate level of protection of personal data under Article 45 of the GDPR. We rely on derogations for specific situations as defined in Article 49 of the GDPR. In case it is necessary to make a transfer of personal data outside the European Economic Area (EEA), we will make sure that the country in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).

Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. We will post changes on the Website and the Apps so that you are always aware of what personal data we collect, use, and disclose. If we have your email address, we will send you a notice about the changes implemented by us. Contact Us If you have questions about our Privacy Policy, please contact us: Address: Updates Vision - Ben Family  Av. Paulista, 1374 São Paulo, 01310-100, BR Email address: privacy@updatesvision.com