PRIVACY POLICY FOR WEBSITES

(Last update October 19, 2023)

Your privacy is very important to us, and we will always use your personal information only for the purposes as described in this Privacy Policy. As used in this Privacy Policy, "OUTFIT7", "we", "us" or "our", "ours" refers to Outfit7 Limited and all of its affiliates and subsidiaries. This Privacy Policy governs your use of https://talkingtomandfriends.com, https://talkingtomandfriends.tv, https://talkingtomherodash.comand any other websites and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the "Website/s").

By using the Websites, you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the apps. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services and content.

INFORMATION WE COLLECT FROM YOU

When you visit our Websites we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimizing the Websites, in connection with promoting our apps and services, and for research or analysis.

1. Technical Information

We collect the data necessary for you to use the Websites and for us to maintain and analyze the functioning of the Websites and to personalize the content of our products.

We automatically obtain certain information about your computing device, including:

IP address; Country code;
Language; Locale (specific location where a given language is spoken);
Time zone;
Network status (Wi-Fi, etc.), browser plug-in types and versions;
Technical device information (e.g. device model and name, operating system name and version, screen size, mobile phone carrier, Internet service provider);
Information we collect via cookies (which are small text files placed on your device). Cookies allow us to collect data, such as your device's model, operating system and screen size and other information about how you use our Services. For more information, please see "Our Use of Cookies and Related Technologies" Section of this Privacy Policy;
For marketing emails, if available: Information we collect via the use of pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emails.

Although some of this information (such as IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US and EU) may treat information that uniquely identifies your device as personal information.

2. Website Usage Information

When you use the Websites, we collect additional information from you by using persistent identifiers that permit identification of your device.

The information we collect includes:

Website usage, including log information, that lets us know how you use the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);

Characteristics obtained by your use, such as data about pages of our Websites that were viewed during your visit, any actions or movements within the Websites and movements to/from the website from/to another website, date and time, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

3. Classical Personal Information

When you request information using the Websites or contact us directly, we may collect personally identifiable information about you that you provide us such as your name and surname, email address and demographic information such as your year of birth. When you voluntarily submit your ideas, participate in our contests and/or surveys or otherwise register with Outfit7, we may collect additional personally identifiable information about you that you voluntarily submit, such as your telephone number, address, etc.

When available from time to time and in case you sign-up for marketing emails, we will collect your information that you submit in the sign-up forms, such as your email address and your marketing preferences.

If you wish to delete your personal information that we received from you, please send an e-mail to [email protected] and your personal information will be deleted from our database. For Privacy enquiries US residents may contact us on our toll-free telephone number: +1 (256) 203-9712.

HOW WE USE YOUR INFORMATION

We use the information we collect from you for delivering our services and Websites and to operate our business. We use it also for improving our services and Websites, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services, apps and Websites, and for complying with our legal obligations.

We use your technical, website usage and classical personal information for the following purposes:

Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, understanding and analyzing trends in connection with usage of the Websites, administering the Websites, and customer communications.
Promoting our apps and services: when you use our Websites we may promote our apps and other services, including new games.
Analytics and research: Understanding and analyzing trends in connection with the usage of Website, auditing, learning about user behavior on the Websites (how often you use the Website, the events that occur on the Website, aggregated usage, performance data etc.). We also use information collected from pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emailing campaigns. We also use information collected from tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates.
Security: We use your information for enhancing the safety and security of our Websites, apps, products and services.
Our legal obligations: We use your information when we are required to do so by law.

We use cookies on our websites for conducting internal analysis about the usage of Websites in order to make them more appealing. For information about cookies and related technologies, please visit " Outfit7 Cookie Policy" available at https://talkingtomandfriends.com/cookies.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what the website and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit https://www.allaboutdnt.com.

SURVEYS AND CONTESTS

We are conducting surveys and online contests in order to improve our services and you may freely decide whether you would like to take part in it or not.

From time to time we may conduct an e-mail survey or an online contest and collect classical personal information, demographic information, usage information and other materials that you voluntarily submit to us for the purposes of internal analysis, marketing and brand development. Participating in a survey or an online contest is completely voluntary. We will use the information to make our services more appealing to users. Collected information gathered via surveys shall be anonymized and aggregated. We may use your information gathered via contests for the purposes of performing the contest and to contact you as per such contest's terms and conditions.

We cannot provide all services necessary for the successful operation of the Website by ourselves. We must therefore share collected information with third parties, including analytics providers, and other third party service providers that support the Website (collectively referred to as " Partners"). We may share information that can be used to personally identify your device (e.g. IP address) for the purposes of delivering our services, promoting our apps and services and conducting analysis and research. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

Third party analytics providers: For some Websites we use third party web analysis service Plausible Analytics from Plausible Insights OÜ. ("Plausible") for the purposes of delivering our services, conducting analysis and research. Plausible collects your IP address and user agent for a short period of time before anonymizing it. This data is stored and being encrypted on the servers located in the EEA. Plausible will use this information to analyze your use of our Website in order to compile reports about website activities for us and to perform other services connected with the use of the Website. Plausible will also send this information to third parties where applicable, if this is required by law or if third parties process these data on behalf of Plausible. To get more information about how your data is being collected and processed you can visit Plausible's privacy site, located at plausible.io/privacy.
Our cloud service providers: We store information we collect from you on servers provided by our third party cloud service providers such as Google Cloud Platform.
Our video gallery providers: For some Websites we use YouTube embedded videos in order to display our video content. YouTube may in accordance with their privacy policy display contextual advertising in its videos.
Our other service providers: We use third party service providers, such as SendinBlue to send you marketing emails, where we have your consent to do so, and to measure open, click through and read rates and allow us to improve our emailing campaigns.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Website. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

For detailed information about information collection and the usage practices of our partners please see the "Our Use of Cookies and Related Technologies" section of this Privacy Policy. For any additional questions about third party information collection please refer to [email protected].

MARKETING EMAILS

From time to time, we offer marketing emails. If you have given us consent for marketing emails, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about topics such as our products and services, news and blogs, media, and partner updates.

If you have subscribed to marketing emails, you can object to further marketing at any time by selecting the "unsubscribe" URL at the end of all our marketing and promotional update communications to you, or by sending an email to [email protected].

If you are at least 18 years old or at least the age of majority under applicable law, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in the applicable terms as defined below, you may voluntarily engage with us through Facebook, Instagram, Twitter or any other social media now known or hereafter devised ("Social Media").

Your ability to interact and engage with us through Social Media platforms is subject to their terms and conditions and privacy policies. You recognize and agree that Outfit7 is not liable for any such terms and conditions and their use of your personal information. Our use of Social Media platforms does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is our use an endorsement of their privacy or information security policies or practices or their compliance with laws. Information collected by them is governed by their privacy practices. Please review each respective Social Media privacy policy and terms and conditions to learn about their privacy or security practices.

GIVEAWAYS OR SWEEPSTAKES

Subject to the terms, conditions, obligations, affirmations, representations, and warranties set forth in the applicable rules governing any Outfit7 giveaway or sweepstake ("Official Rules"), you may voluntarily participate in the giveaway or sweepstake through any Outfit7's Social Media platform.

If you decide to do so, we may collect your personal data, such as your username and/or profile picture included in the comments. We will only use, store, and share the personal data we collect for the purposes of conducting a giveaway or sweepstake and to comply with the Official Rules we have agreed to with you, such as to contact you directly or to make an announcement if you are selected as the winner or the receiver of the reward, or to respond to your comments or messages. If you are selected as the winner or receiver of the reward, we may contact you directly and request additional personal information, such as your name, address, and phone number, in order to deliver the reward. The legal basis for data processing in connection with any Outfit7 giveaway or sweepstake is contractual necessity.

HOW OUR PARTNERS MAY USE YOUR INFORMATION

We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us. They adhere to this Privacy Policy, but in some cases we must use their privacy policies.

We strive to commit our Partners to using the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of providing the service to us or for contextual advertising, but for any other purposes they should use the information solely on an anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices.

In addition, Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about visitors to the Websites. Partners may share anonymous information that they collect with their clients. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.

Our Partner's information gathering practices, including their policies regarding the use of cookies, Web beacons, and other tracking technologies, are governed by their own privacy policies, not this one. We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us.

ADVERTISING

We or third parties operating the advertisement serving technology may use information logged from your device using cookies, web beacons and other technologies for the purposes of contextual advertising (including frequency capping, fraud prevention and attribution and billing purposes). In addition, our Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, local shared objects and other technologies) in order to track impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third party advertising campaign performance. For any other purposes they should use the information solely on an anonymized and aggregated basis, this means in a way that cannot be tracked back to your device.

THIRD PARTY TERMS AND CONDITIONS

Please note that your access to and ability to use and interact with the Websites may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers.

Our Websites may contain links to third party websites, products, or services. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party's privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

CHILDREN'S PRIVACY

We do not knowingly collect personal information from children under 13 or under the age of digital consent according to EEA, UK, Brazil, and some US states' data protection legislation. If we learn that we have collected personal information of a child under the age of 13 or under the age of digital consent according to EEA, UK, Brazil, and some US states' data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected].

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it, i.e. you have a right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to [email protected].

Your rights include:

Right to object. In some cases you have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by stopping with the use of our Websites and services.
Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity, unless a shorter period is set with applicable data protection legislation. For privacy enquiries you may contact us via [email protected], and US residents can call us on our toll-free telephone number: +1 (256) 203-9712.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via [email protected] and we will correct it as soon as we can.
Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us via [email protected]. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymized form.
Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via [email protected].
Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
Right to withdraw consent. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us via [email protected].
Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.
We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

GENERAL

Your privacy and security of your information is important to us, and we always pay special attention to ensure that we process your information lawfully, including but not limited in accordance with one of the legal bases set out under Data Protection Laws that apply to EEA and UK users. We have appointed a data protection officer in accordance with Data Protection Laws, ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, to help us ensure compliance with such laws. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners as for the purposes described above in "How We Share Your Information" Section, which may include a transfer of your personal information outside of the European Economic Area (the "EEA"). Please check https://talkingtomandfriends.com/privacy/en regularly for changes to our Privacy Policy.

LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA, UK and Brazil data protection legislation.

The legal bases that we rely upon are the following:

Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested and that we have agreed to provide to you, this is to deliver and improve our services, and to process your information in relation to online contests.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when use our Websites and services, to make sure your information is secure and to provide to you our services free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics and research, for our own promotion purposes and contextual advertising purposes in embedded videos.
Where we ask for your consent to use your data for a particular purpose, such as to send you marketing emails with promotional update communications, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before conducting any surveys.
Legal Obligation. This covers information that is processed by us to comply with a legal obligation.

SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

INTERNATIONAL TRANSFER

We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third-party service providers across borders and from your country to other countries around the world. Please note that not all of these countries have the same data protection laws as your own country, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

We will transfer your personal information outside EEA/UK only when the transfer is based on one of the following safeguards:

To a country with adequate data protection. We will transfer your personal information outside EEA/UK to a country that ensures an adequate level of protection in accordance with EEA/UK data protection legislation.
Based on standard contractual clauses. We will transfer your personal information to our Partner outside EEA/UK, if we have entered into standard contractual clauses with such Partner, that are adopted by Commission of European Union in accordance with EEA/UK data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via [email protected]).
Based on an approved certification mechanism. We will transfer your personal information to our Partner outside EEA, if our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation.

RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for providing our services.

For EEA Countries, UK and Brazil

We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission. Cookies, and provision of value-added services information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy and "Your Rights" section herein. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

For US and rest of the world

We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://talkingtomandfriends.com/privacy.

For previous versions of this Privacy Policy please contact us via [email protected].

CONTACT US

If you have questions or concerns about OUTFIT7's Privacy Policy, please contact us through one of the following ways:

for privacy questions and exercising your rights via our privacy email: [email protected];
our data protection officer: ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg;
our UK representative: PRIVO Verified Limited, Room 3, 168 South Street, Dorking, Surrey RH4 2ES,
our Brazil data protection officer: [email protected];
for privacy enquiries, US residents may call us on our toll-free telephone number: +1 (256) 203-9712.

For information collected under this Privacy Policy that is subject to Data Protection Laws, the data controller is Outfit7 Limited, a company registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London EC3M 6BN, United Kingdom, with business address at Christaki Kranou 20, 2nd Floor, 4041 Limassol, Cyprus.

OUTFIT7 PRIVACY POLICY FOR WEBSITES, last updated October 19, 2023