Privacy Policy

Last updated: January 2025

1. Data Controller

Brown Group (parent company) and its subsidiary CyberFun Hub B.V. are the data controllers responsible for your personal data. You can contact us at:

• Parent Company: Brown Group
• Subsidiary: CyberFun Hub B.V.
• Business Description: Upgradable Upward-Trending Array
• Mission: Maximize E-Business Methodologies
• EIN: 47-4022675
• KVK Registration: 83746675
• VAT ID: NL938475001B03
• VAT Tax Number: 938475001B03
• RSIN: 938475001
• Address: Keizersgracht 123, 1015 CJ Amsterdam, Netherlands
• Email: elroy64@hyatt.com
• Phone: +31 20 123 4567

2. Legal Basis for Processing (Article 6 GDPR)

We process your personal data based on the following legal bases:

• Consent (Article 6(1)(a)): For marketing communications, analytics cookies, and personalization features
• Contract (Article 6(1)(b)): To provide our gaming services and maintain your account
• Legitimate Interest (Article 6(1)(f)): For security, fraud prevention, and website functionality
• Legal Obligation (Article 6(1)(c)): To comply with applicable laws and regulations

3. Personal Data We Collect

3.1 Information You Provide

• Contact information (name, email address)
• Account credentials
• Communications with our support team
• Survey responses and feedback

3.2 Information Collected Automatically

• IP address and location data
• Browser type and version
• Operating system
• Pages visited and time spent
• Game usage statistics
• Device identifiers

4. How We Use Your Personal Data

Purpose	Legal Basis	Data Types
Provide gaming services	Contract	Account data, usage data
Customer support	Contract	Contact information, communications
Website analytics	Consent	Usage data, cookies
Marketing communications	Consent	Contact information, preferences
Security and fraud prevention	Legitimate Interest	IP address, device data

5. Data Retention

We retain your personal data for the following periods:

• Account data: Until account deletion or 3 years of inactivity
• Usage data: 2 years from collection
• Marketing consents: Until withdrawn or 3 years of inactivity
• Customer support records: 5 years for legal compliance
• Analytics data: 26 months (Google Analytics default)

6. Data Transfers Outside EU

We may transfer your personal data to countries outside the European Union, including:

• United States: For analytics services (Google Analytics) - protected by EU-U.S. Data Privacy Framework adequacy decision
• Other third countries: Only with appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission

7. Data Sharing

We share your personal data only in the following circumstances:

• Service providers: Third-party processors who help us operate our services (hosting, analytics, customer support)
• Legal requirements: When required by law or to protect our legal rights
• Business transfers: In case of merger, acquisition, or sale of assets
• With your consent: Any other sharing requires your explicit consent

8. Your Rights Under GDPR

As a data subject, you have the following rights:

8.1 Right of Access (Article 15)

You can request a copy of the personal data we hold about you and information about how we process it.

8.2 Right to Rectification (Article 16)

You can request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure (Article 17)

You can request deletion of your personal data in certain circumstances, including when:

• The data is no longer necessary for the original purpose
• You withdraw consent and there's no other legal basis
• You object to processing and there are no overriding legitimate grounds

8.4 Right to Restrict Processing (Article 18)

You can request that we limit how we use your personal data in certain circumstances.

8.5 Right to Data Portability (Article 20)

You can request your personal data in a structured, commonly used format and have it transmitted to another controller.

8.6 Right to Object (Article 21)

You can object to processing based on legitimate interests or for direct marketing purposes.

8.7 Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to decisions based solely on automated processing, including profiling.

8.8 Right to Withdraw Consent

Where processing is based on consent, you can withdraw it at any time. This won't affect the lawfulness of processing before withdrawal.

9. How to Exercise Your Rights

To exercise any of your rights, contact us at:

• Email: elroy64@hyatt.com
• Subject line: "GDPR Rights Request"
• Include: Your full name, email address, and specific request

We will respond to your request within 30 days (may be extended by 2 months for complex requests).

10. Cookies and Tracking

We use cookies and similar technologies. For detailed information, please see our Cookie Policy.

You can manage your cookie preferences by:

• Using our cookie preference center
• Adjusting your browser settings
• Opting out of analytics cookies

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security assessments
• Staff training on data protection
• Incident response procedures

12. Age Restrictions

Our services are intended for users 18 years and older. We do not knowingly collect personal data from children under 18. If we become aware of such collection, we will delete the data immediately.

13. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last updated" date
• Sending email notifications for significant changes

14. Supervisory Authority

If you have concerns about our data processing practices, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

• Website: autoriteitpersoonsgegevens.nl
• Email: info@autoriteitpersoonsgegevens.nl
• Phone: +31 70 888 8500
• Address: Postbus 93374, 2509 AJ Den Haag, Netherlands

15. Contact Information

For any questions about this privacy policy or our data practices, contact our Data Protection Officer:

• Email: elroy64@hyatt.com
• Address: Brown Group, Attn: Data Protection Officer, Keizersgracht 123, 1015 CJ Amsterdam, Netherlands