Privacy Policy

Introduction

BLACK SOURCE SOFTWARE, LLC (hereinafter referred to as "we," "the Company," or "Black S Play") recognizes the importance of user privacy and is committed to protecting the personal information users provide when using our official website (hereinafter referred to as the "Website") and related services (hereinafter collectively, the "Services").

This Privacy Policy explains how we collect, use, share, store, and protect your personal information.

Please read this Agreement carefully. If you have any questions, comments, or suggestions, please contact us using the contact information provided at the end of this Agreement.

1. Scope of Application

Applicable Persons

This Privacy Policy applies to all users who access and use our Services, whether you are an individual or a business user.

If you are a resident of the European Economic Area (EEA) or California, this Privacy Policy specifically includes provisions regarding compliance with the EU General Data Protection Regulation (GDPR), the US California Consumer Privacy Act (CCPA), and subsequent regulations.

Applicable Services

The services covered by this Agreement include, but are not limited to, website browsing, software product introduction and display, user account registration and management, customer support services, software download and update services, and all other services provided through the Website or related clients.

2. Information Collection

Information You Provide

Registration and Account Information

When you register an account, we collect your username, password, email address, mobile phone number, and other information to create and manage your account, provide personalized services, and communicate with you as necessary.

If you choose to log in using a third-party account (such as a social media account), we will obtain relevant information (such as your name, profile picture, and basic information) from the third party that you authorize to share.

Customer Support Information

When you seek customer support, you may provide us with information such as your name, contact information, problem description, and relevant screenshots or files to help us better understand and resolve your issue.

Feedback and Survey Information

If you participate in our feedback activities or surveys, we will collect your feedback, answers, and suggestions to help us improve our services and products.

Information Automatically Collected

Device and Technical Information

When you visit the website or use the Services, our servers automatically record your device information, including but not limited to device model, operating system, browser type, IP address, and device identifiers (such as IMEI and MAC address, where applicable). We also collect information about your network connection, such as your internet service provider, network type (Wi-Fi, mobile data, etc.), the date and time you visit the website, your browsing history, and clickstream data (such as pages visited and links clicked).

This information helps us optimize website performance, enhance user experience, and conduct security monitoring and analysis.

Cookies and Similar Technologies (if any)

We may use cookies and similar technologies (such as web beacons and pixel tags) to collect and store information.

A cookie is a small text file sent by a website to and stored on your device. It is used to identify your device, remember your preferences (such as language preference and volume settings), analyze website usage, and provide personalized content and advertising.

You can manage and control cookies through your browser settings, such as rejecting or deleting cookies, but this may affect your experience with certain website features.

Information Obtained from Third Parties

Sharing Information with Partners

We may obtain information about you from third parties with whom we work, such as advertising partners, data analytics companies, payment providers, and social media platforms. For example, advertising partners may provide us with data about your ad clicks on their platforms to help us evaluate advertising effectiveness; payment providers may provide us with transaction-related information to confirm payment status.

This information is collected only within the legal and compliant scope and relevant to our services, and with your appropriate authorization (if required by law).

Information from Publicly Available Sources

To the extent permitted by law, we may collect information about you from publicly available sources (such as government data, news reports, and social media content) for purposes such as market analysis and brand protection.

3. Information Use

Providing Services

We use the collected information to provide you with services, including but not limited to creating and managing your account, providing software product downloads and updates, handling your customer support requests, and displaying personalized content (such as recommended software, relevant news, and special offers).

Improving Services

By analyzing the collected information, we can understand user habits, preferences, and needs, thereby improving website design, optimizing software performance, enhancing service quality, and developing new products and features to provide you with a better user experience.

Security

We use information for security monitoring and prevention, including detecting and preventing fraud, malicious attacks, account theft, and other security incidents, to protect the security of your account and personal information and maintain the normal operation of our services.

Marketing and Promotion

We may use your information to send you marketing information related to our products and services, including but not limited to software release announcements, promotional information, and special offers.

If you do not wish to receive such marketing information, you can opt out at any time by following the opt-out procedures we provide.

In addition, we may work with third parties to deliver personalized advertising based on your interests and behavior, displaying advertisements for products and services that may be of interest to you.

When delivering personalized advertising, we will comply with relevant laws and regulations regarding user privacy and ensure the security of your personal information.

Legal Compliance

We may use your information as necessary to comply with applicable laws and regulations, respond to legal process (such as court subpoenas and government investigations), and protect our legal rights and interests or the safety and rights of others.

4. Information Sharing and Disclosure

Sharing with Affiliates

We may share your information internally with affiliated companies to provide you with more comprehensive services or collaborate on business activities. Affiliates will be bound by this Privacy Policy or an equally stringent privacy policy to ensure your information is properly protected.

Sharing with Partners

We may share your information with third-party partners (such as advertising partners, data analytics companies, payment service providers, cloud service providers, software developers, etc.) to achieve the purposes described in this Privacy Policy, such as providing advertising services, conducting data analysis, processing payment transactions, storing data, developing and operating software, etc.

Before sharing information, we will enter into a data processing agreement with our partners to clearly define the data protection responsibilities and obligations of both parties, requiring them to implement appropriate security measures to protect your information and use it only for authorized purposes.

Legal Requirements and Protection of Rights

We may disclose your information when required by law, such as in response to a subpoena, government investigation, or request from a law enforcement agency.

In addition, we may disclose information if we believe disclosure is necessary to protect our legal rights, prevent fraud or other illegal activities, or protect the personal safety or vital interests of others.

Business Transfers

In the event of a merger, acquisition, asset sale, reorganization, or other similar business transaction, your information may be transferred to the relevant third party as part of the transaction. In such cases, we will require the recipient to comply with this Privacy Policy or provide equivalent data protection measures to protect your information.

5. Information Storage and Security

Storage Location

We store the collected information on servers in the United States.

When transferring personal data of European Economic Area (EEA) residents outside the EU/EEA, we will ensure appropriate safeguards are in place to meet GDPR requirements for cross-border data transfers, such as using Standard Contractual Clauses (SCCs) for data transfers, obtaining an adequacy determination from the European Commission, and implementing Binding Corporate Rules (BCRs).

For the personal information of California residents, we will also comply with the data storage and transfer requirements of the CCPA and related regulations.

Storage Period

We will retain your information for the minimum period necessary to fulfill the purposes for which it was collected, while complying with applicable data retention requirements under applicable laws and regulations.

For example, we may be required to retain certain transaction-related information for a certain number of years to comply with tax, accounting, and other legal requirements.

Once the information is no longer necessary to fulfill the purposes for which it was collected and the retention period has expired, we will securely delete or anonymize it.

Security Measures

We prioritize information security and implement a series of reasonable technical and organizational measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction.

These measures include, but are not limited to:

Data Encryption

Sensitive information (such as passwords and payment information) is encrypted during transmission and storage using industry-standard encryption algorithms (such as SSL/TLS) to ensure data confidentiality.

Access Control

We implement strict access control mechanisms to limit access to your information to authorized personnel only, with access levels determined based on their job responsibilities and needs.

Employees are required to comply with our company's confidentiality policy and internal compliance requirements when accessing and processing your information.

Vulnerability Management

We regularly scan and detect security vulnerabilities in our systems, promptly update and fix security vulnerabilities, and install security patches to mitigate malicious attacks and data breaches.

Employee Training

We provide employee training on information security and privacy protection to enhance their security and compliance awareness and ensure they understand how to properly handle and protect your information.

Emergency Response Plan

We have developed a data breach emergency response plan to ensure timely response and mitigation measures in the event of a data security incident, minimizing losses and impact. In the event of a data breach, we will notify affected users and relevant regulatory authorities in accordance with applicable laws and regulations.

6. User Rights

Right of Access

You have the right to access the personal information we hold about you.

You can view and access some of your personal information by logging into your account and accessing it through your account settings or relevant functional modules.

If you require additional personal information or a copy of it, you may contact us using the contact information provided at the end of this Agreement. We will respond to your request within the legally prescribed timeframe (generally no more than 30 days) and provide it to you in an easily understandable format.

Right to Correction

If you find that the personal information we hold about you is inaccurate or incomplete, you have the right to request that we correct or supplement it.

You can modify some of your information yourself through your account settings. For information that you cannot modify yourself, you can submit a correction request to us, which we will verify and process promptly.

Right to Deletion

You have the right to request that we delete your personal information, subject to legal requirements.

For example, if your personal information is no longer necessary for the purpose for which it was collected, if you withdraw your consent and there is no other lawful basis for processing, or if you object to our processing and have legitimate grounds. You can request deletion by contacting us. We will delete your information as soon as possible after confirming that the conditions for deletion have been met, unless we are required to retain such information by law or regulation.

Right to Restrict Processing

In certain circumstances, you have the right to request that we restrict the processing of your personal information.

For example, if you dispute the accuracy of your information while we verify it; if our processing is unlawful but you do not wish to have it deleted immediately; or if we no longer need the information for the purposes for which it was collected but require it for legal proceedings.

You can request restriction of processing, and we will assess and process it on a case-by-case basis.

Right to Data Portability

For EEA residents who qualify for the right to data portability under the GDPR, you have the right to receive the personal information you have provided to us in a structured, commonly used, and machine-readable format, and to have it transferred to another data controller, where technically feasible.

You can request data portability from us, and we will assist you in accordance with the relevant regulations.

Right to Object

You have the right to object to our processing of your personal information based on our legitimate interests (such as marketing and data profiling).

If you object, we will cease the relevant processing unless we can demonstrate compelling legitimate grounds for continuing the processing that override your interests. You may exercise your right to object by contacting us.

Right to Opt Out

Marketing Opt-Out

As stated above, you have the right to opt-out of receiving marketing communications from us. You can opt-out by clicking the unsubscribe link provided in marketing emails, following the unsubscribe instructions in text messages, or by selecting the appropriate option in your account settings.

Sale of Personal Information (For California Residents)

Under the CCPA, California residents have the right to opt-out of the sale of their personal information.

We currently do not sell your personal information (as defined by the CCPA), but if our business model changes in the future and involves the sale of personal information, we will provide you with a clear and conspicuous opt-out mechanism that you can exercise through the methods we provide (such as a dedicated link, email address, etc.).

Protection of Minors

We take the privacy protection of minors very seriously.

If you are a minor, please have your parent or guardian carefully read this Privacy Policy before using our services and obtain their consent to use our services.

We collect and process personal information from children under the age of 13 only in compliance with the Children's Online Privacy Protection Act (COPPA) and other relevant laws. If we discover that we have collected personal information from children under the age of 13 without parental or guardian consent, we will delete the relevant information as soon as possible.

7. Special Rights of California Residents

Right to Know

California residents have the right to know the categories of personal information we collect, its sources, purposes of use, and with whom it is shared.

Specifically, the categories of personal information we collect include, but are not limited to: identifiers (such as name, email address, IP address, device identifier), commercial information (such as purchase history, information about software products viewed), internet or other electronic network activity information (such as browsing history, clickstream data), geolocation data (if you authorize it), and audiovisual materials (such as screenshots and videos provided in response to feedback).

This information primarily comes from direct information you provide, automatic collection by us, and information obtained from third-party partners (where legal and compliant and with your authorization).

The purposes for which we use and share this information are detailed in the "Information Use" and "Information Sharing and Disclosure" sections of this Privacy Policy.

Right to Access and Obtain Specific Information

California residents have the right to request that we disclose the specific personal information we have collected about you and to obtain a copy of that information. You may submit a request to us using the contact information provided at the end of this Agreement. We will respond and provide the relevant information within the timeframe required by law, but we may need to verify your identity to ensure the security of your information.

Right to Deletion (Reiteration)

As previously stated, California residents have the right to request that we delete personal information we collected from you or retained, subject to certain legal exceptions, such as where we need to retain the information to complete a transaction, provide a service, maintain security, or comply with legal obligations.

Right to Opt-Out of Sale (Reiteration)

We currently do not sell the personal information of California residents.

If such sales occur in the future, we will provide you with clear notice before such sales and an easily accessible opt-out mechanism so you can opt-out of the sale of your personal information at any time.

Right to Fair Dealing

California residents have the right not to be discriminated against for exercising their rights under the CCPA, including but not limited to pricing, quality of service, or product features.

We will ensure that all users are treated equally and will not take any adverse action against you for exercising your rights.

Rights Exercised by an Agent

California residents may authorize an agent to exercise their rights under the CCPA on their behalf.

When an agent makes a request, we may require the agent to provide appropriate proof of authorization and your identity verification information to ensure the legitimacy and security of the request.

8. Special Rights of EEA Residents (GDPR-Related)

Consent Mechanism

For EEA residents, we will obtain your explicit consent when collecting and processing sensitive personal information (such as race, political opinions, religious beliefs, health information, sexual orientation, etc.).

When collecting other personal information, we will ensure that your consent is freely given, specific, informed, and revocable. You may withdraw your consent at any time through your account settings or by contacting us. Withdrawing consent does not affect the lawfulness of processing activities based on consent before its withdrawal.

Data Protection Impact Assessment (DPIA)

Before engaging in personal data processing activities that may pose a high risk to your rights and interests (such as large-scale data collection and analysis, new business models involving sensitive information, etc.), we will conduct a data protection impact assessment to identify and mitigate potential data protection risks and take appropriate measures to protect your rights and interests.

Data Protection Officer (DPO)

We have designated a dedicated Data Protection Officer to oversee our data protection compliance efforts and ensure compliance with the GDPR and related regulations.

You may contact our Data Protection Officer with any privacy-related questions or complaints using the contact information provided at the end of this Agreement.

Right to Complain

If you believe that our processing of your personal information violates the GDPR, you have the right to file a complaint with us, and we will promptly address and respond to your request.

You also have the right to lodge a complaint with the data protection supervisory authority in your member state.

9. Changes to this Agreement

We may modify or update this Privacy Policy based on business developments, changes in laws and regulations, or other reasons. If we make material changes to this Agreement (such as a substantial change in the purpose of information collection, how it is used, or the scope of information sharing), we will notify you via a website announcement, email (sent to the email address you provided during registration), or other prominent means, and provide you with a reasonable amount of time to review and consider the changes before they take effect.

If you continue to use our services after the changes are made, you will be deemed to agree to be bound by the changes.

X. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or wish to exercise your rights or file a complaint, please contact us through the following means:

Email: [email protected]

Postal Address: 819 Pinecreek Dr, Dayton, OH 45458 US

We will strive to process and respond to your request promptly upon receipt, typically within 10-15 business days, but the specific timeframe may vary depending on the complexity of the request and legal requirements.

BLACK SOURCE SOFTWARE, LLC