PRIVACY POLICY FOR WEBSITES

(Last update January 16, 2025)

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 and 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

Most of the information we collect about you comes from you or your device when you visit our Websites and interact with their content. Other than that, we may receive information when you contact us directly via email or the website's support page.

INFORMATION YOU PROVIDE DIRECTLY

When you contact us directly – whether through the support form on the Websites or through email, we may collect personally identifiable information about you that you provide, such as your name, email address, your age and the country you're from. This information is collected so that we are able to provide you with the requested answer and that we comply with our legal obligations.

When you participate in our contests or surveys, we may collect additional personally identifiable information that you voluntarily submit and are required for participation.

When available and if you voluntarily sign-up for our newsletter, we will collect your information that you submit in the sign-up forms, (such as email address and your marketing preferences).

INFORMATION COLLECTED AUTOMATICALLY

The information we automatically collect about you relates to the online identifiers that permit identification of the device you are using and your interactions with the Websites, including:

IP address,
coarse (approximate) location (as derived from an IP address),
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 Websites. For more information, please see the "Cookies and Related Technologies" Section of this Privacy Policy;
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 was used to access the Websites);
characteristics obtained by your use, such as data about pages of our Websites that were viewed during the 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).

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

In case you are subscribed to our newsletter, we collect pixel tags (where we have your consent to do so) to measure open, click-through and read rates and allow us to improve our emails.

We use the information we collect from your device to deliver the content of our Websites to you and to run a successful operation. We may share your information with our subsidiaries and with other companies and use it as described below. We use the information collected for the following purposes:

Delivering our Websites

We use the information we collect about you/your device to develop, deliver and improve the content of the Websites or our other products, tailoring our Websites, understanding and analyzing trends in connection with usage of the Websites, administering the Websites. In order to be able to do this, we store information we collect from you on servers provided by our third-party cloud service providers such as Google Cloud Platform – read more information about their privacy practices in their privacy policy located here https://policies.google.com/privacy.

Displaying video content

In order to display video content on our Websites, we use a video hosting provider, JW Player. You can read more about their data processing practices in their privacy policy available at https://www.jwplayer.com/privacy.

Promoting our Games and Content

When you use our Websites, we may promote our games, video content and other products connected to the games.

Analytics and Research

Information collected is used to understand and analyze 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.). To support this, 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.

Advertising

For some territories (excluding EEA, UK and Brazil) we have contracted with a third party advertising network, Google (Google Ads), that assist us in delivering contextual advertising to you via JW Player third-party video hosting provider or when you visit https://talkingtomandfriends.tv website. They may use information logged from your device using cookies or other similar technologies, and their own tracking 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, the information should be used solely on an anonymized and aggregated basis, which means it cannot be tracked back to your device.

For more information on how your data is being collected and processed, read Google's privacy practices here: https://policies.google.com/privacy and JW Player's privacy practices here: https://jwplayer.com/legal/privacy/.

You can also learn more about the cookies connected with the provision of contextual advertising in our Cookie policy, available here: https://talkingtomandfriends.com/cookies.

From time to time, you have an option to subscribe to our newsletter, where we then occasionally provide you with promotional update communications by email about our products and services, news and blogs, media, and partner updates. If you've subscribed to receiving our newsletter, we use information received from pixel tags (subject to consent in the relevant territories) to measure open, click-through and read rates, which allow us to improve our emailing campaigns. We also use information collected from tracking links in the newsletter emails that we send to you (where we have your consent to do so, as applicable) to measure click-through and install rates. To send you our newsletter and to measure its success we use Brevo. You can read more about Brevo's privacy practices in their privacy policy, located at https://www.brevo.com/legal/privacypolicy/.

If you have subscribed to our newsletter, 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].

Customer Support

When you reach out to us, we use your information to provide you with the requested customer support.

Whether you contact us through a support form within the Website or directly through the email, we receive your query through the customer support tool is provided Zendesk. For the data processing by them, please see Zendesk's privacy policy available at https://www.zendesk.com/company/agreements-and-terms/privacy-policy/.

Surveys

We are conducting surveys in order to improve our games or content, 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 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 is completely voluntary. We will use the information to make our games or content more appealing to users. Collected information gathered via surveys shall be anonymized and aggregated.

Security

We use your information for enhancing the safety and security of our Websites, games, video content and other services.

Our legal obligations

We use your information when we are required to do so by law. 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.

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.

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, TikTok 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.

We use cookies on our Websites for conducting internal analysis about the usage of Websites in order to make them more appealing. On certain subpages we also occasionally use cookies and pixel tags connected with the campaigns. 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.

THIRD PARTY TERMS AND CONDITIONS

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. 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 other companies we have partnered with by stopping the use of our Websites.
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, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain why we are unable to provide it to you. We will try to respond to any request for a right of access as soon as possible, but we will always do so within one month (or as required by the applicable legislation) of receipt of your (verifiable) request. 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 the personal information you have requested we delete as soon as possible, but we will always do so within one month (or as required by the applicable legislation) 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. In some instances, personal information about you that is visible through gameplay and is cached on other players' devices, such as your username or your high scores, may not be removed or updated from there if that device is not connected to a Wi-Fi network.
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 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.
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 non-discriminatory treatment for exercising any rights. You have a right to not receive discriminatory treatment for exercising your rights described under this section. This for example means we will not deny any services or provide a different level of service based on the fact you chose to exercise any right.

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.

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 Interest. 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.
Consent. 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, TRANSFER AND RETENTION OF INFORMATION

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 Websites or other requested services (eg. customer support). Traffic information is deleted or anonymized when it is no longer needed for the purpose of the transmission. 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.

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. We may also contract with additional companies or change existing service providers to perform any services in connection with the Websites. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices. The most current version of the Privacy Policy will govern our use of your information and will be available at https://talkingtomandfriends.com/privacy-web/en.

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 EEA data protection officer: ePrivacy GmbH, Burchardstraße 14, 20095 Hamburg, Germany;
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.

For certain data received from https://talking-ginger.com/campaigns/ subpages we and Meta Platform Ireland Limited process data for the purposes of using data for targeting our ads and to improve ad delivery and ad targeting. For these purposes we and Meta Platform Ireland Limited and joint controllers (as defined in the applicable legislation), and we have entered into a joint controller terms available at https://www.facebook.com/legal/controller_addendum.

OUTFIT7 PRIVACY POLICY FOR WEBSITES, last updated January 16, 2025