Who we are?

We are Brainfreeze , a mobile game development studio. Our website address is: https://brainfreezestudio.ro.



We use Google’s services to help provide you with great content and make it easier for you to enjoy our games. We publish our games on Google Play Store and thus agree to their terms and the way they process information. For more details on how Google uses our information see Google’s Privacy Policy.

Ad Networks

AdMob* is a mobile application advertising platform created by Google. It’s used to promote mobile apps and to help advertisers make money through mobile apps by enabling in-app advertising. To generate income we provide our users with relevant ads through AdMob services. They also use anonymous identifiers to generate personalized content for users and give us insight on how our apps are used so we can improve them. AdMob applies the same privacy policies as Google.

We also distribute inside our apps ads from the following providers: Heyzap, Adcolony, Applovin and Unity Ads.  Please check their privacy policy for more information.

Brainfreeze Studio

We collect and share anonymous identifiers from our apps with above mentioned partners, available to us with your given consent for generating relevant content based on your preferences, consent that can be revoked by you at any time if you choose so. For more details on how we process your information, contact us.



LAST UPDATED: February 1, 2019


  1. Your Privacy

This privacy policy (this “Privacy Policy”), as amended from time to time, applies to all of the products and services offered by Brainfreeze Studio Interactive Inc. or its subsidiaries (collectively, “Brainfreeze Studio”).

Brainfreeze Studio respects the privacy rights of its customers and visitors (“Users”) and is committed to protecting the information collected through its online or mobile applications, services and websites (collectively, “Services”). Brainfreeze Studio has adopted this Privacy Policy to explain how Brainfreeze Studio collects, stores, and uses the information collected in connection with Brainfreeze Studio’s Services.

The English version of the Privacy Policy is the governing version. Any translation of the Privacy Policy is just a reference for your convenience and should not be relied on in legal proceedings.


  1. Information We Collect & How We Use It
    Brainfreeze Studio may collect and use both personal and non-personal data from Users using Brainfreeze Studio’s Services. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used.

2.1. Personal Data

2.1.1. Definition

For the purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual and includes those items specifically listed below.

2.1.2. Registering for Services

Users may make personal data such as their name, email address, username and password available to Brainfreeze Studio when they register for Services, enter contests and special events, subscribe to newsletters, request technical support or otherwise communicate with Brainfreeze Studio, and when using Brainfreeze Studio’s Services where personal data is required for use and/or participation.

2.1.3. Information about Users Received from an SNS
When Users access the Services through a social networking site (“SNS”) such as Facebook or Google +, Users allow Brainfreeze Studio to access certain information from their profile for that site. The information Users allow Brainfreeze Studio to access varies by application and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games. For example, Brainfreeze Studio may access and store some or all of the following information, as allowed by Users, the SNS and their preferences:
• first and last name;
• profile picture or its URL;
• user ID number, which is linked to publicly available information such as name and profile photo;
• the user ID numbers and other public data for Users’ friends;
• the login e-mail provided to that SNS when Users register;
• Users’ physical location and that of Users’ access devices;
• gender; and
• birthday.
By using the Services through an SNS, Users are authorizing Brainfreeze Studio to collect, store, and use, in accordance with this Privacy Policy, any and all information that Users agreed the SNS could provide to Brainfreeze Studio through the SNS Application Programming Interface (“API”).

2.1.4. Optimize Interactive Experience

Brainfreeze Studio may collect, store and use personal data to provide Users with an optimized interactive experience. For example, the information collected may be used to create Users’ accounts, provide enhanced interaction with Brainfreeze Studio’s apps and websites, manage any in-game voting features, notify Users of in-game updates, provide technical support and respond to Users’ inquiries.

2.1.5. Other Purposes

Additionally, Brainfreeze Studio may collect, store, and use personal data to solicit Users’ feedback to help improve the Services and other Brainfreeze Studio products, inform Users about new products or promotional material offered by Brainfreeze Studio or its trusted third party business partners and affiliates, notify Users about changes to Brainfreeze Studio’s Services or other products, provide Users with advertising and marketing material from Brainfreeze Studio and its trusted business partners and communicate with Users for other commonly accepted purposes such as notifying them that they are a potential winner of a contest.

Finally, Brainfreeze Studio may collect and use personal data as required or permitted by applicable law.

2.1.6. Mobile Devices

If Users access Brainfreeze Studio’s Services on mobile and tablet devices, Brainfreeze Studio may collect mobile device identifiers, including MAC Address and IP Address, and Brainfreeze Studio may assign to your device an identifier that is similar to an account number. Brainfreeze Studio may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Services.

2.1.7. SMS Notifications, Push Notifications & Local Notifications

Brainfreeze Studio may store the information you provide, including your telephone number, when you sign up to have SMS notifications sent directly to your mobile phone. These messages notify you of in-game activity and may allow you to play the game from your phone. With your consent Brainfreeze Studio may send push notifications and local notifications to your mobile device to provide game updates and other relevant messages.

2.1.8. Payment Information

If you purchase a license to use in-game virtual currency or virtual items directly from Brainfreeze Studio, we will collect the billing and financial information necessary to process your charges, which may include your postal or ZIP code and e-mail address. Brainfreeze Studio may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Facebook (for Facebook Credits) or Apple (for purchases on iOS devices), Google, Barnes and Noble, or Amazon.

Please refer to Brainfreeze Studio’s Terms of Service to review the policies and terms relevant to our charges and billing practices and the terms of service of third party channels (such as those mentioned above) for their practices and terms of service.

2.1.9. Data Storage

Brainfreeze Studio may store and/or transfer your personal data outside of Romania in accordance with applicable legislation and this Privacy Policy.

2.1.10. Third Party Privacy Policies

While accessing or using Brainfreeze Studio’s Services, Users may interact with third parties, such as application stores, mobile software platforms, social networking services and payment providers. Users recognize and agree that Brainfreeze Studio is not liable for their use of Users’ personal data and Users should review the privacy policies of these third parties.

Brainfreeze Studio may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, you are using products or services that are not affiliated with or controlled by Brainfreeze Studio. Brainfreeze Studio is not responsible for those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies.

2.1.11. User Generated Content

Users should be aware of the open nature of certain social networking and other open features of the Services Brainfreeze Studio may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Brainfreeze Studio is not responsible for any personal data you choose to make public in any of these forums.

2.1.12. Minors

Before disclosing a minor User’s personal data to a third party, Brainfreeze Studio shall disclose:
• the kinds of businesses in which the third parties are engaged;
• the general purposes for which the information is used; and
• whether the third parties have agreed to maintain the confidentiality and security of the information.

A legal guardian may provide consent to Brainfreeze Studio collecting and using the minor’s personal data, without consenting to the disclosure of the minor’s personal data to third parties.

A legal guardian may review or require Brainfreeze Studio to delete or stop collecting and further using or disclosing the minor’s personal data at any time by contacting Brainfreeze Studio at the coordinates found at the end of this Privacy Policy. In this case, Brainfreeze Studio may no longer be able to provide the same level of Services.

Brainfreeze Studio does not knowingly collect any personal data from children below the aforementioned age without receiving the consent of a legal guardian. If Brainfreeze Studio learns that it has inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, Brainfreeze Studio will take reasonable measures to promptly erase such personal data from their records.

2.2. Non Personal Data

2.2.1. Definition

For the purpose of this Privacy Policy, “non-personal data” means: (1) information that does not directly identify you; and (2) “aggregate” and “de-personalized” information, which is data Brainfreeze Studio collects about the use of Brainfreeze Studio Services, from which any personally identifiable data has been removed.

Brainfreeze Studio may use tools or third party analytical software to automatically collect and use certain non-personal data. You will not be identifiable through the use of these tools or third party analytical software. The types of non-personal data Brainfreeze Studio may collect and use include, but are not limited to:
1. Device properties, including, but not limited to:
(a) IP address;
(b) Media Access Control (“MAC”) address; and
(c) Unique device identifier or other device identifier (“UDID”);
2. Device software platform and firmware;
3. Mobile phone carrier;
4. Geographical data such as zip code, area code and coarse location;
5. Game progress, score and achievements; and
6. Other non-personal data that Brainfreeze Studio may require to enhance the Services and other Brainfreeze Studio products.

2.2.2. Trusted Partners and Contractors

Brainfreeze Studio may use and disclose to its affiliated companies, contractors or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of Brainfreeze Studio’s Services and to further develop the Services and other Brainfreeze Studio products.

2.2.3. Cookies, Beacons and Tracking

Brainfreeze Studio may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Brainfreeze Studio treats information collected by cookies and similar technologies as non-personal data.

A “cookie” is a small bit of record-keeping information that is sent to the Users’ computer. Brainfreeze Studio’s cookies do not include personal data and may be used to: (1) facilitate Users’ login authentication, (2) help Users navigate around the Brainfreeze Studio’s websites, (3) monitor how many people are using Brainfreeze Studio’s Services, and (4) store Users preferences and track trends.

Most browsers are initially set up to accept cookies, but Users can disable cookies or set their browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to use the Services.

Brainfreeze Studio may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate.

You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or by visiting www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.

Brainfreeze Studio may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Brainfreeze Studio sends to you may contain pixel tags that enable Brainfreeze Studio to track your usage of the communication, including whether the communication was opened and/or what links were followed.

2.2.4. Ad Serving Technology

Brainfreeze Studio reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Brainfreeze Studio or Brainfreeze Studio’s trusted partners and contractors. Brainfreeze Studio may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through the Services.

Brainfreeze Studio or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. Brainfreeze Studio or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-game information.

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. You recognize and agree that the advertising companies who deliver ads for Brainfreeze Studio may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services; if you do not want to be subject to this technology, do not use or access the Services. Although Brainfreeze Studio may take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, Brainfreeze Studio does not have access to or control of third party technologies.

2.2.5. Location Data

If Brainfreeze Studio makes location enabled Services available and you use such Services, then Brainfreeze Studio may collect and process your location data to provide location related Services and advertisements. Brainfreeze Studio may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS location is not accessed without your consent. Notwithstanding Brainfreeze Studio’s partners who are providing location related parts of the Service, Brainfreeze Studio will not share your geo-location with third parties without your consent. To the extent Brainfreeze Studio makes available geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that Brainfreeze Studio may share your anonymous coarse location with its partners.

  1. Who We Disclose Personal Data To

3.1. Disclosure of Personal Data

In providing the Services, Brainfreeze Studio may disclose the personal data to other companies or individuals in the following limited circumstances:

  1. In cases where Brainfreeze Studio receives Users’ consent;
    2. With applications stores as part of Users’ purchase and use of the Services (including in-app purchases);
    3. Brainfreeze Studio has a good faith belief that access, use, preservation or disclosure of such personal data is reasonably necessary to;
    (a) satisfy any applicable law, regulation, legal process or enforceable governmental request;
    (b) enforce applicable Terms of Use including investigation of potential violations thereof;
    (c) detect, prevent, or otherwise address fraud, security or technical issues; or
    (d) protect against imminent harm to our rights and/or property, or
    4. As required or authorized by applicable law.

3.2. Data Processing

Brainfreeze Studio may also disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. Brainfreeze Studio requires that these parties agree to process such personal data based on Brainfreeze Studio’s instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures.

Brainfreeze Studio may disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of providing marketing and advertising content to Users. Brainfreeze Studio requires that these parties agree to process such personal data based on Brainfreeze Studio’s instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. Users can unsubscribe from this service at any time.

3.3. Sale of Business
As Brainfreeze Studio continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If Brainfreeze Studio becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy.

  1. Choices for Personal Data
    If Brainfreeze Studio proposes to use personal data for any purpose other than those described in this Privacy Policy, Brainfreeze Studio will obtain the Users’ prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes.
    Users may choose to withdraw their consent to the use, collection or disclosure of personal data outlined in this Policy at any time. If a User withdraws his or her consent, then Brainfreeze Studio may no longer be able to provide the same level of Services.
    Users are also given the opportunity to “opt-out” of having their personal data used for purposes such as receiving newsletters or other information from Brainfreeze Studio.
    Withdrawals of consent will not have an effect on data that Brainfreeze Studio has provided to third parties in accordance with this Privacy Policy prior to such withdrawals.
  2. Information Security

Brainfreeze Studio takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Brainfreeze Studio employs physical, electronic and/or procedural safeguards to protect its systems and all personal data under its control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.

  1. Accuracy and Access/Control over Personal Data
    Brainfreeze Studio processes personal data only for the purposes for which it was collected and in accordance with this Policy. Brainfreeze Studio may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but Brainfreeze Studio is not responsible for verifying the correctness of personal data.
    Brainfreeze Studio will allow Users to access their personal data in the custody or control of Brainfreeze Studio, and will allow them to:
    1. update or correct such personal data;
    2. change User preferences with respect to communications, push notifications and other information received from Brainfreeze Studio or third parties; or
    3. delete the personal data of the Users on Brainfreeze Studio’s systems (by submitting a request to Customer Support).
    Users can turn off push notifications (if applicable) by visiting the “options” or “settings” page within the relevant app. Users can turn off local notifications by visiting the “options” or “settings” page within the relevant app.
    Users can stop further use of your geo-location (for example through “check-ins”) (if applicable) by visiting their device’s settings for the relevant application or the “settings” page for the relevant game. Users can also stop checking in.
    Such updates, corrections and changes will not have an effect on other information that Brainfreeze Studio maintains, or information that Brainfreeze Studio has provided to third parties in accordance with this Privacy Policy prior to such update, correction or change.
  2. Retention of Personal Data
    Brainfreeze Studio stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law.

Brainfreeze Studio may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Brainfreeze Studio’s user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.

  1. Enforcement

It is Brainfreeze Studio’s policy to contact a complaining user regarding his or her concerns. Brainfreeze Studio will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Brainfreeze Studio and an individual.

  1. Changes to this Policy

Brainfreeze Studio reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If Brainfreeze Studio makes material or significant changes to this Privacy Policy, Brainfreeze Studio may post a notice on Brainfreeze Studio’s website along with the updated Privacy Policy. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

  1. Contact Information

Should you have any questions relating to this Privacy Policy, please contact us at Teleorman 46/17, Cluj-Napoca, Romania, 400573, or office@brainfreezestudio.ro.