(Last update April 12, 2023)
Before sharing any information with advertising partners for the purposes of interest-based advertising, we will always ask for your consent. Based on your consent we share information we collect from you that can be used to personally identify your device, e.g. persistent identifiers such as advertising ID, IDFA, IP address and other information that may be personal to you, such as age and gender with our advertising partners and they can use such data for interest-based advertising. For example they can show you an ad based on your age and gender, they may attach the information gathered from our App to information gathered from other apps, websites, or via other services, and then build profiles, show you an ad based on such profile (for example they might know that device with your advertising ID has clicked on a sports ad within other publisher's app and show to you a sports ad in our App). In addition, we may use and share such information with our advertising partners to target and optimize our advertising and promotions in our and other publisher's apps.
We allow our advertising partners to show interest-based ads to you only if you have passed the age gate in our Apps and you have consented to the sharing of your personal information for the purposes of interest-based advertising.
Our advertising partners use different technologies for the purposes of interest-based advertising that process your personal information in different ways, so please review their data processing practices before you provide your consent to sharing your persistent identifiers such as advertising ID, IDFA, IP address and other information that may be personal to you for the purpose of interest-based advertising.
Please see the following list of advertising providers that are allowed to show interest-based advertising and review their data processing practices, including the technologies they use for the purposes of interest-based advertising:
You have an option to withdraw your consent to sharing your personal information for the purposes of interest-based advertising at all times. You can withdraw your consent by going to the app settings and clicking the interest-based ads button where you can manage your preferences by choosing to which advertising partner you allow to share your personal information for the purposes of interest-based advertising.
When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won't be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.
Most of the information that we collect about you comes directly from you when you play our Apps or interact with third party ads in our Apps or with our ads in other publisher's apps. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our apps and may include information that you submit to us when you voluntarily contact us or which you allow us to access when you connect to your social network accounts through our Apps. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (if we never receive your payment or credit card information).
We collect technical information about your device that is necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, to personalize the content of the App, and to display advertisements. Such information includes amongst others the type of device(s) you are using to play our Apps, persistent identifiers, such as IP address, device identifiers, ad identifiers, unique user ID specific for our Apps, and the country or region that you are playing in.
Persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address) that are identifiers that do not identify you personally but may uniquely identify your device. Such online identifiers provided by end user devices, applications, tools and protocols are considered as personal information according to Brazil data protection legislation. Please check the rights you have under Brazil data protection legislation in Section "Your Rights".
We automatically collect certain information about your computing device, including:
Additionally, for playing video advertisements through a video platform provider, we may collect additional information about your device, such as:
In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.
Older versions of our Apps may still obtain information such as UDID number and IMEI number. If you wish to prevent this, please update the App with the latest version available on App Store.
When you use our Apps, we collect additional information from you by using persistent identifiers that permit identification of your device. We collect information about how you play our Apps, how you interact with our ads in other publisher's apps and how you interact with third party ads that are shown to you in our Apps. Such information is used for delivering and improving our service, advertising, cross-promotion and analytics purposes.
We collect information, including log information, that lets us know:
We do not collect classical personal information through our Apps (such as your name, address, email or phone number) and you can use our Apps without providing us with your classical personal information. We will receive your classical personal information (such as your name, address, email or phone number) only when you contact us directly and will use such information only to respond to your inquiry.
We may ask you to submit and we may process other non-personally identifiable information that may be personal to you such as your age range, year of birth and gender, provided that year of birth and gender information is collected solely for users who have passed the age gate in our Apps.
For the some of our Apps we collect information about the nickname you choose or the information about the name you give to your virtual pet and your rating of the Application (if any). Please do not use your real name.
We use the information we collect about you/your device to deliver services and our Apps to you and to operate our business. We use it also for improving our services and Apps, 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 and Apps in our apps and also in other publisher's apps and to display third party advertisements to you. We use your information also for attribution and fraud prevention for advertising purposes and for complying with our legal obligations.
We use your information for the following purposes:
We have two types of notifications in our Apps - local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server. Push notifications are never sent to users who didn't pass the age gate. We use such notifications to remind you about your activities within the App. You will receive such notifications only if you are subscribed to such notifications in the App. You can always unsubscribe from push notifications, please use the instructions provided below.
When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.
We are conducting surveys to improve our services and you may freely decide whether you would like to help us or not. We will always ask for your consent before conducting a survey.
From time to time, we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, whether children use the app on their own or with an adult, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, which Talking Tom and Friends Products have been bought or have been considered, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.
We may use third party providers for the in-app surveys and they may place their tags within an App to collect non-personally identifiable data from the device ("Tag Data") solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated basis together with the data from other partners ("Unified Data") to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.
Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.
We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must therefore share collected information with third parties, including analytics providers, attribution and fraud prevention providers, cloud service providers, third party advertising providers and their attribution and fraud prevention providers and other third party service providers that develop and support the Apps (collectively referred to as "Partners"). We share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners' advertising campaign performance. 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:
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. 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 any additional questions about third party information collection please refer to[email protected].
We offer our Apps for free or at low cost and in order to do that we need to share information we collect from you with our third party advertising partners that assist us in delivering advertisements to you. When you use our Apps we rely on our legitimate interest to show contextual advertisements to you. Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent.
When you use our Apps we show contextual advertisements to you. In order to enable advertising we allow our advertising partners to collect advertising identifiers (such as advertising ID on Android and IDFA on iOS) that are considered as personal information under Brazil data protection legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on anonymized and aggregated basis, this means in a way that cannot be tracked back to your device.
Your privacy is important to us, so we follow not only applicable legislation, but also accepted market practices, such as respecting your privacy preferences on your device. You can choose to opt out of interest-based advertising via "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-Based Ads" on your Android device and all advertising providers are bound to comply with such setting, but we cannot provide any guarantees on their behalf. If you choose to withdraw your consent available via our Apps, we will not share your advertising ID with advertisers for the purposes of interest-based advertising.
You can find the setting for your mobile device by following the directions below or contact your device provider.
_ IOS DEVICE _
Go to your Settings > Select Privacy > Select Advertising > Enable the "Limit Ad Tracking" setting
Go to your Settings > Select General > Select About > Select Advertising > Enable the "Limit Ads Tracking" setting
More information about the iOS setting can be found here:https://support.apple.com/en-us/HT202074
_ ANDROID DEVICE _
For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:
Open your Settings app > Google > Ads > Enable "Opt Out of Interest-Based Advertising"
Some of our Apps enable you to connect to third party social networks, to share the content you created within the Apps on such third party social networks or to participate in leader boards or multiplayer apps. If you connect to third party social network, such as Google Play Games Service or Apple Game Center, you will be able to use your account to log in on multiple devices and to synchronize progress across those devices. If you connect to third party social network, such as Facebook, you may be able to interact, compete and connect with your friends (please see more in "Special Privacy Features in Some Of Our Apps"). Some of our Apps enable you also to share the content you created within the App on third party social network, such as Facebook, YouTube, Twitter or Vkontakte. When you log in to your social network account or by using the App to share content on social network, we will receive some of information you have on such social network account (please see more below).
Some of our Apps use third parties' services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte ("Third Party Social Network/s"). Such Apps enable you log in to your Third Party Social Network account to connect to our App by using the "Log in with" or "Connect to" feature in our App. You may also share the content you created within the App on Third Party Social Networks. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions you can contact us [email protected].
The information you allow us to access varies by App, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at the Third Party Social Network in question. When you use the "Log in with" or "Connect to" feature we may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the "Log in with" or "Connect to" process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the "Log in with" or "Connect to" feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.
The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.
If you use Third Party Social Networks to participate in game related activities, such as in leader boards and multi-player games, you share your information with other players and Third Party Social Networks (for example scores, rankings and achievements).
Some of our Apps offer you the option to talk to the virtual character of such Apps, but you will always be asked to give us the permission to access the microphone in advance. Such Apps do not have a function to record audio, please learn more below. Some of our Apps offer special features that enable you to interact and connect with your friends, compete with your friends and to chat with your friends. Such features collect additional information from you and share such information also with others. Learn more about such features below and please do not use these additional features if you are not comfortable with all the additional information that is collected when you use such features. Please note that we may age gate some of these features, so they are not available for use by users under the age of digital consent.
Some of our Apps offer you the option to talk to the virtual character of such Apps. All of our Apps that offer such feature will always ask you in advance for your permission to access the microphone on your device. If you decide to give us the permission, the virtual character will be able to repeat what you say to him. Please note that our Apps do not have a function to record audio, so what you say to the virtual character is not stored on our servers, it is only used by the App to repeat to you in real time. If you decide not to give us the permission to access the microphone on your device, the virtual character will not be able to repeat after you.
Some of our Apps offer you to compete and interact with your Facebook friends, but you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the permission for sharing the list of friends in the notice that appears during the "Log in with Facebook". If you choose to login with Your Facebook account, the App will show Your public profile to your Facebook friends.
Some of our Apps can be played in a single or a multiplayer mode. In a multiplayer mode you can play matches with random players or your Facebook friends. Such Apps will ask you to choose your name. Please do not choose your real name. You can always change your name by going to "Settings" and selecting "Change Name". The name you enter and your rank will be publicly displayed when playing with random players in a multiplayer mode. To play matches with Your Facebook friends, you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the list. However, you cannot play matches with your Facebook friends without giving the App the permission to share your public profile. If you choose to login with Your Facebook account, the application will show Your public profile when playing with your Facebook friends or random players.
Some of our Apps have in-app chat, so you may communicate with your friends who also play the same App as you. Users of our chat service can send messages to other players. Your messages are used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 1 month your in-app chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
Our Apps may contain links to third party websites, products, or services. For example, the Apps may feature offers from third party advertisers or the ability to engage in transactions with such entities. 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.
We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under the age of digital consent according to Brazil data protection legislation, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than persistent identifier of a child under the age of digital consent according to Brazil 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].
In order to preserve the family-friendly reputation of our Apps, we age-gated some of the features in our Apps, so that they are not available for use by children under the age of digital consent according to Brazil data protection legislation. The age gate is being conducted after the download of some of our Apps to assure the privacy and protection of younger users of our Apps. The features enabling potential collection and sharing of personally identifiable information, with the exception of persistent identifiers, are disabled for users who did not pass the age gate. For user's safety, it is not possible to change the age later. We do not store the year of birth of users who have identified themselves as below the age of digital consent according to Brazil data protection legislation in our Apps, but only the information that their unique user ID did not pass the age gate.
The only personal information we collect from users who have identified themselves as below the age of digital consent according to Brazil data protection legislation for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, publisher provided ID, IP address). Such persistent identifiers are used and shared with third parties only to place contextual advertisement (including frequency capping, fraud prevention and attribution and billing purposes), to authenticate users of or personalize the content on Apps, to maintain or analyze the functioning of the Apps, personalize the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.
You have certain rights in connection with your personal information and how we handle it, including but not limited to a right to obtain information about whether we hold and process personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information, to portability 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].
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under Brazil data protection law.
The legal bases that we rely upon are the following:
We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across border and from your country to other countries around the world. Please note that not all these countries have the same data protection laws as your own country, but we always strive to take appropriate steps to safeguard the privacy of your personal information.
When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data will delete your data as described above in "Your Rights" Section.