1. DEFINITIONS, GENERAL INFORMATION AND TERMS OF USE.
Bratty! Studios has always been concerned about the privacy of its Users and, therefore, has created this Privacy Policy, which forms an integral and inseparable part of the User Agreement, available on the official website https://bratty.gg, to demonstrate its commitment to the protection of personal data and the privacy of its users, pursuant to the General Data Protection Law (Law No. 13.709/2018 - LGPD) and related rules. These terms also describe how User privacy is protected by Bratty! Studios when collecting, processing and storing players' personal information.
By accepting the website's Terms of Use, the User also accepts this Privacy Policy. By completing the registration information required to create an account, the User also expresses their explicit and unequivocal consent to the use of their data in accordance with this policy.
Bratty! Studios follows its own Code of Conduct ("Code of Conduct"), whose pillars are respect, cooperation and good faith toward its users.
1.1 DEFINITIONS OF THE PRIVACY POLICY
User: refers to all persons who use, will use or will visit the official website, its subdomains and/or the Bratty! Studios application;
Personal Data: any information provided and/or collected by Bratty! Studios, by any means, that: (I) identifies an individual, or that, when used in combination with other information processed by Bratty! Studios, identifies an individual; (II) is provided by the user themselves upon registration; (III) is collected when the user visits the company's virtual environment, whether its websites, mobile application or games (software); (IV) allows the identification or contact information of a natural person to be derived. Personal Data may be in any medium or format, including electronic or computerized records, as well as paper-based files.
Purpose: the objective that Bratty! Studios wishes to achieve through each act of processing personal information, particularly to use, store and process personal information to (i) understand, provide, improve and develop the platform; (ii) create and maintain a safe and trustworthy environment so as to ensure compliance with the Privacy Policy; and (iii) provide, personalize, evaluate and improve our advertising and marketing.
Consent: the explicit and unequivocal authorization given by the User who is the personal data subject for Bratty! Studios to process their personal data for a purpose previously described in this policy or in the terms of use, where the legal basis required for the act calls for the data subject's explicit authorization.
Necessity: the justification for why collecting personal data is strictly necessary to achieve the purpose, avoiding excessive collection.
Legal bases: refers to the legal grounds that make the processing of personal data by Bratty! Studios lawful for a specific previously defined purpose.
This privacy policy generally applies to all USERS and potential USERS of Bratty! Studios services, and also specifies how the company may collect, produce, classify, receive, access, use, store, reproduce, transmit, transfer, distribute, process, archive, delete, evaluate or control information, modify, communicate, disseminate or extract the collected data, including personally identifiable information, in accordance with the applicable legal bases and all privacy and data protection laws in force.
By accessing the Bratty! Studios website or application, the User declares that they have read, understood and accepted the Terms of Use, and also declares that they have observed the recommended age rating, for all legal purposes and effects. Children's and adolescents' data will be processed in their best interests.
If the User does not fit the description above or does not agree, even in part, with the terms and conditions contained in this Privacy Policy, they must not access or use the services offered by Bratty! Studios, or the websites and services operated by it or by the game's developer.
2. COLLECTION AND USES OF INFORMATION
The User is aware that they provide information knowingly and voluntarily upon registration or through browsing data on the websites, mobile application or games (software) operated by Bratty! Studios.
When the User registers or completes forms to access content on the Bratty! Studios website, including websites operated by it or by the developer, certain requested Personal Data will be kept confidential and will be used only for the purpose established by this privacy policy.
The data and information collected may include the following identification and access data:
a) User registration information, such as name, corporate name, general identity registration, individual taxpayer registration, CNPJ, telephone number, email, among others.
b) Software device information, such as: the Device's internet protocol ("IP") address, machine name, media access control address (MAC address), logged-in user, network domain, date and time records associated with transactions, and other interactions with the Service.
c) Authentication Data: username, password, personal identification number, password hints and similar data to authenticate users in connection with the use of the Services or access to information related to the Services.
3. SHARING AND PROCESSING OF PERSONAL INFORMATION
BRATTY STUDIOS DESENVOLVIMENTO E PUBLICACAO DE JOGOS LTDA may share your data if you request it, upon proof of identity. The user declares that they are aware and consents that personal data may also be shared with the game's Licensor (or developer), within or outside the national territory, with third-party partners and with authorities and regulatory bodies for different purposes, when necessary. Whenever data is shared, it will be done within the limits and purposes of our business and in accordance with what the applicable legislation authorizes.
The User consents that Bratty! Studios may disclose the Personal Data collected to third parties in the following situations and within the limits of the legal relationship and those required and authorized by Law:
I. With its clients and partners when necessary or appropriate for the provision of related services;
II. With companies and individuals hired to perform certain activities and services on behalf of Bratty! Studios;
III. With group companies;
IV. With the game's developer;
V. With suppliers and partners for the provision of services contracted with Bratty! Studios (such as information technology, accounting, payment methods, among others);
VI. For administrative purposes such as research, planning, service development, security and risk management, among others.
VII. By virtue of a legal obligation, an order from a competent authority, or a court decision.
When Personal Data is shared with third parties, all parties mentioned in items I through VII must use the shared Personal Data consistently and in accordance with the purposes for which it was collected (or to which the User previously consented) and in accordance with what has been established by this Privacy Policy, other website or country privacy statements, and all applicable privacy and data protection laws.
Data may be shared for the following purposes:
(cid:127) Check violations and intrusions into game accounts; (cid:127) Check secondary accounts that commit violations with main accounts; (cid:127) Check simultaneous access and sharing in the game; (cid:127) Analyze Banning; (cid:127) Analyze toxic or illegal behavior; (cid:127) Provide services and offer the products contracted by the client; (cid:127) Implement and offer new services and products;
(cid:127) Marketing, prospecting, market and opinion research, and promotion of our products and services; (cid:127) Credit protection; (cid:127) Prevention and resolution of technical or security problems; (cid:127) Measures to prevent and combat unlawful acts and fraud, and ensure clients' security; (cid:127) Regular exercise of Bratty! Studios' rights; (cid:127) Compliance with a legal or regulatory obligation; (cid:127) Compliance with an order from a court, competent authority or supervisory body; (cid:127) Improvement of our services, software, website and application, and implementation of new products or services; (cid:127) Assistance in providing the services we deliver to you, for example, technical support and updated versions of the games; (cid:127) Contact by telephone, email, SMS, WhatsApp, push notification or other means of communication; (cid:127) Assistance in developing and offering our products and services; (cid:127) Debt collection. (cid:127) Continued provision of game services by the developer following any termination of the contract with Bratty! Studios;
3.1. SHARING AND INTERNATIONAL TRANSFER OF DATA
THE USER CONSENTS AND AGREES THAT PERSONAL DATA HELD BY Bratty! Studios MAY BE TRANSFERRED TO AND STORED IN COUNTRIES OTHER THAN BRAZIL, ESPECIALLY THOSE IN WHICH THE PROGRAM'S (GAME'S) DEVELOPER IS BASED, SHOULD IT DIRECTLY OPERATE THE SOFTWARE. THESE COUNTRIES MAY NOT HAVE THE SAME DATA PROTECTION LAWS IN FORCE IN BRAZIL. WHEN WE TRANSFER YOUR PERSONAL INFORMATION TO OTHER COUNTRIES, WE PROTECT THAT INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY, AS PROVIDED BY LAW OR IN ACCORDANCE WITH WHAT IS COMMUNICATED WHEN SUCH DATA IS PROVIDED (FOR EXAMPLE, THROUGH A SPECIFIC PRIVACY NOTICE). Bratty! Studios OBSERVES ALL REQUIREMENTS ESTABLISHED BY THE LEGISLATION IN FORCE AND ADOPTS THE BEST SECURITY AND PRIVACY PRACTICES TO ENSURE THE INTEGRITY AND CONFIDENTIALITY OF YOUR PERSONAL DATA.
3.2. PROCESSING OF CHILDREN'S AND ADOLESCENTS' DATA
CHILDREN OR ADOLESCENTS REGISTERED OR WHO WILL REGISTER WITH Bratty! Studios MUST HAVE AUTHORIZATION FROM THEIR PARENTS OR GUARDIANS, WHO ARE ALSO SUBJECT TO THIS POLICY AND WHOSE ACCEPTANCE AND CONSENT MUST BE EXPLICIT. UPON REGISTRATION, THE USER MUST PROVIDE THE GUARDIAN'S EMAIL ADDRESS FOR CONTACT OR POSSIBLE CONFIRMATION OF REGISTRATION. THE LACK OF ACCEPTANCE OR CONSENT FROM PARENTS OR GUARDIANS MAY RESULT IN THE IMMEDIATE BLOCKING OF THE ACCOUNT AND DELETION OF DATA. THE MINOR USER'S DATA WILL ALWAYS BE PROCESSED IN THEIR BEST INTERESTS IN ACCORDANCE WITH THE LAW.
4. LEGAL AND CONTRACTUAL REASONS FOR DISCLOSING DATA
In certain legal or contractual circumstances (Terms of Use), Bratty! Studios may disclose Personal Data, to the extent necessary or appropriate, to government bodies, consultants and other third parties in order to comply with applicable legislation, the Terms of Use or a court order or summons, or if Bratty! Studios believes, in good faith, that such action is necessary for, but not limited to:
I. Complying with legislation that requires such disclosure;
II. Investigating, preventing or taking action related to suspected or actual illegal activities, or cooperating with public bodies, or protecting national security;
III. Performance of its contracts;
IV. Investigating and defending against any claims or allegations made by the User themselves or third parties;
V. Protecting the security or integrity of the services (for example, sharing with companies experiencing similar threats);
VI. Exercising or protecting the rights, property and security of Bratty! Studios and its affiliated companies;
VII. Protecting the rights and personal safety of its employees, users or the public;
VIII. In the event of the sale, purchase, merger, reorganization, liquidation or dissolution of Bratty! Studios.
The User's request for deletion, disclosure, editing or any form of access to data must be accompanied by confirmation of their identity. Bratty! Studios may, at its sole discretion, request other identity documents or other evidence it considers necessary and sufficient to confirm ownership of the account and registration data.
5. SECURITY OF PERSONAL INFORMATION
The User's Personal Data and information will be stored in the Bratty! Studios database or in databases maintained "in the cloud" by service providers contracted by Bratty! Studios, which duly comply with the data legislation in force in Brazil or in their respective country.
Bratty! Studios and its suppliers use a wide variety of security procedures, with appropriate technology, to protect the confidentiality, security and integrity of their Users' Personal Data, preventing the occurrence of any damage arising from the processing of such data.
Although Bratty! Studios adopts the necessary security precautions and monitors its system for vulnerabilities and attacks to protect information and Personal Data against unauthorized disclosure, misuse or alteration, the User understands and agrees that there are no completely secure guarantees, even with advanced technology, that ensure that information cannot be accessed, disclosed, altered or destroyed through a breach of any physical, technical or administrative safeguards.
6. DATA RETENTION
Bratty! Studios retains all data provided, including Personal Data, while the User's registration is active or inactive, and as necessary for the provision of its services.
Bratty! Studios will retain your Personal Data and keep your data stored for as long as necessary. Any request for deletion will be fulfilled in accordance with the law and will result in the closure of the User account, in accordance with the terms of use.
Bratty! Studios may retain your Personal Data after receiving your request for deletion if necessary to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse, and ensure compliance with contracts.
7. LEGAL BASES FOR PROCESSING
Bratty! Studios processes Personal Data only in situations in which it is legally authorized or with the User's explicit and unequivocal consent, as is the case with this policy and the user terms.
As provided in this Privacy Policy, Bratty! Studios has legal bases to collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate or control information, modify, communicate, transfer, disseminate or extract data about the User.
The legal bases include the User's or Visitor's consent, contracts and preliminary contractual procedures (where processing is necessary to enter into the contract with the User), and legitimate interests, provided that such processing does not violate their rights and freedoms.
These interests also include protecting the User and Bratty! Studios from threats, complying with applicable legislation, the regular exercise of rights in judicial, administrative or arbitration proceedings, enabling the conduct or administration of business, including quality control, reports and services offered, managing business transactions, understanding and improving the business and customer relationships, and allowing users to find economic opportunities.
The User has the right to deny or withdraw the consent provided to Bratty! Studios when this is the legal basis for processing personal data, and Bratty! Studios may cease providing its services to this user if such a request is made, which may result in cancellation of the account.
If the User or Visitor has questions about the legal bases for collecting, processing and storing their personal data, they may contact Bratty! Studios and its Data Protection Officer (DPO - Data Protection Officer) by email at legal@bratty.gg.
8. RIGHT TO ACCESS AND CONTROL YOUR PERSONAL DATA
Bratty! Studios offers the User several options regarding what to do with their collected, processed and stored Personal Data, including deletion or correction. The User may:
I. Request data deletion: USERS may request the deletion of some of their personal data stored at Bratty! Studios;
II. Change or correct data: the User may edit or request the editing of some of their Personal Data that may still be registered. The User may also request updates, changes or corrections to their data in certain cases, especially if it is incorrect.
III. Raise objections, limits or restrictions on the use of data: the User may request that the use of all or some of their Personal Data be stopped, or limit the use of such data (if the Personal Data, for example, is incorrect or stored unlawfully), emphasizing that Bratty! Studios may process Personal Data in accordance with the legal bases;
IV. Right to access or take your data: the User may request a copy of their Personal Data and of the data the User provided;
The duly registered and identified User may make the requests listed above by contacting our Data Protection Officer (DPO - Data Protection Officer) by email at legal@bratty.gg, and these requests will be considered in accordance with applicable laws. If there are doubts about the User's identity, the DPO may request additional information or documents, at their sole discretion, proving that the person is the User, so as to provide information securely and exclusively to the data subject.
9. REVISIONS TO THE POLICY
If Bratty! Studios modifies this Privacy Policy, such changes will be published visibly on the Bratty! Studios website. This Policy is effective as of 02/12/2019. If the User has any questions regarding the website's privacy policies, please contact Bratty! Studios through the addresses below/the Data Protection Officer's (DPO - Data Protection Officer) service channel.
10. CONTACT AND APPOINTMENT OF THE DATA PROTECTION OFFICER (DPO - DATA PROTECTION OFFICER)
Bratty! Studios has appointed staff member Dr. Rafael Pinto as Data Protection Officer (DPO - Data Protection Officer), who is responsible for the privacy rules. The user may contact the DPO at the physical address or by email at legal@bratty.gg.
11. APPLICABLE LAW AND CHOICE OF VENUE
This policy is subject to the Law of the Federative Republic of Brazil, and the courts of the Judicial District of São Paulo have jurisdiction to resolve any dispute relating to it.