(Last update November 15, 2022)
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.
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:
Additionally, for displaying video advertisements through a JW Player third-party video hosting provider, we may collect additional information about your device, such as:
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.
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).
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, cooperate 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, resume, job position, etc.
When available from time to time and in case you voluntarily pre-register for any new games and sign-up for marketing emails, we will collect your information that you submit in the pre-registration or sign-up forms, such as your name, your date of birth, your email address and your marketing preferences.
When you voluntarily engage with us on Social Media (as defined below), we may collect:
If you wish to delete your personal information that we received from you, please send an e-mail to firstname.lastname@example.org 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.
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, for providing customer support and for complying with our legal obligations.
We use your technical, website usage and classical information for the following purposes:
See more below in section "Participation In Social Media Engagement".
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 site 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.
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, displaying advertisements, 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:
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.
From time to time, we offer marketing emails. If you have passed the age screening and 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 our products and services. For more detailed information please also read the section "Important Information for Younger Users That Want to Sign Up for Marketing Materials" below.
If you have subscribed to marketing emails, you can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to email@example.com.
When you want to pre-register for our new game and you give us your name, date of birth and email address and you tick the first box on the pre-registration form, you are saying that you are happy for us to use this information about you to let you pre-register for this game and get the free item if enough people pre-register, and to use your email address to send you information about the game, such as when it is ready for you to play, and when any new updates or new features of the game will be available. If you also tick the second box, you are saying that you are happy for us to email you also with news and information about our other games.
When you want to sign up for marketing emails and you give us your name, date of birth and email address and you tick the first box on the sign up form, you are saying that you are happy for us to use your email address to send you information about the particular game you are signing up for, such as when any new updates or new features of the game will be available. If you also tick the second box, you are saying that you are happy for us to email you also with news and information about our other games.
In any emails that we send you, we use something called pixel tags, that let us see whether you have read our emails and clicked on any of the links in those emails. We do this so we can make our emails better. We also use something called tracking links, that lets us see if you ended up downloading the game. We do this to keep a track of how many people decided to download the game after receiving an email from us. We use other companies to help us send these emails and use these pixel tags and tracking links, so the information about you that you give to us is shared with those companies so that they can help us with this.
If you are unsure what any of this means, you should speak to an adult. You can always ask us to stop sending you emails at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to firstname.lastname@example.org.
You can also ask us to delete all the information that we have about you by sending us an email to email@example.com. If you have any questions, you can ask us by email: firstname.lastname@example.org, and US residents may call us on our toll-free telephone number: +1 (256) 203-9712.
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").
Subject to the terms, conditions, obligations, affirmations, representations, and warranties set forth in Social Media Engagement Policy, available here, you may voluntarily engage with us by emailing, posting, uploading or otherwise submitting "User Generated Content" or "UGC" as defined in the Social Media Engagement Policy, on any Outfit7 page, profile, or feed (collectively referred to as "O7 Page") to any Outfit7's Social Media platform or tagging or hash tagging us on any Social Media platform.
In order to engage with you via Social Media and to further use and distribute your content in accordance with our Social Media Engagement Policy, if agreed with us, we will process your personal data, such as your name, username, images, voice, likeness, caption, contact information or other identifying information in connection with any use of your User Generated Content, or your personal information that may be included in comments, texts, posts, videos, images, or other content, if accompanied with or contained in your User Generated Content. We will only use, store and share the personal data we collect for the purposes of interacting with you via Social Media and to comply with the Social Media Engagement Policy we have agreed with you, such as to re-share, post and tag you in connection with your User Generated Content, to mention you in our posts containing your User Generated Content and to upload or otherwise submit your User Generated Content on Outfit7 Page to any Outfit7's Social Media platform and/or Outfit7's websites, to respond to your messages or comments, to statistically process and segment User Generated Content for the purpose of improving marketing strategies and implementing them in future marketing and user engagement products and action and to communicate with you for additional use and cooperation we may have or propose for use of User Generated Content. The legal basis for data processing under the Social Media Engagement Policy is contractual necessity. For any additional use and cooperation we may have or propose for use of User Generated Content, we will obtain your consent.
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.
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 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.
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.
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 13 or under the age of digital consent according to EEA, UK and 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 13 or under the age of digital consent according to EEA, UK and 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@example.com.
We recognize the importance of safeguarding children's personal information collected online. The only personal information we collect on Websites from children under 13 or under the age of digital consent according to EEA and UK data protection legislation are persistent identifiers (such as IP address and cookies). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to deliver and optimize our Websites, place contextual advertisement (solely through embedded video gallery and on https://talkingtomandfriends.tv/ Website), to maintain or analyze the functioning of the Websites and Apps, personalize the content of the Websites and Apps, to perform network communications to protect the security or integrity of the user or the Websites and Apps, to ensure legal or regulatory compliance.
In an instance that a child submits personal information to us, we will retain such information only so long as reasonably necessary to fulfill the activity request, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the parent's consent for that collection.
Outfit7 Limited is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program ("the Program"). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates Outfit7 Limited has established COPPA compliant privacy practices and has agreed to submit to PRIVO's oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us on our toll-free telephone number +1 (256) 203-9712 or at firstname.lastname@example.org. If you have further concerns after you have contacted us, you can contact PRIVO directly at email@example.com.
COPPA Safe Harbor Certification
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 firstname.lastname@example.org.
Your rights include:
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:
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 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:
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 them for providing our services.
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.