CALIFORNIA PRIVACY POLICY FOR APPS

(Last update March 13, 2023)

INTEREST-BASED ADS

We promote our Apps and services in ours and other publisher's apps and we also allow our partners to promote and advertise their goods and services in our Apps. We may share information we collect from you to our advertising partners, and they can reuse such data for targeted advertising. We or our advertising partners may display interest-based, or retargeted, ads (''IBA''), but only for the device IDs that have passed the age gate and have not opted out of IBA. By using our Apps and not choosing one of the opt-out options, you give us consent to transfer your data as stated below.

We may pass information we collect from you such as technical information, advertising and application usage information (for example if a device has clicked on a sports ad within our Apps, for more information please see Information and Data We Collect from You Section of this Privacy Policy) as well as age & gender information to our advertising partners and they can reuse such data for targeted advertising. We allow our partners to serve targeted third-party advertisements or other content. They may attach the information gathered from our App to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. For example, we pass advertising IDs to Facebook, and they match it with your Facebook ID, aggregate it and delete the initial identifier. By doing so the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information Facebook receives or infers about users. We cooperate with several providers of IBA that are listed herein in subsection a) and in Opt-Out Section of this Privacy Policy (''Third Parties''). When allowing Third Parties to conduct IBA we adhere to the DAA Principles available here https://www.digitaladvertisingalliance.org/principle/index.html.

"Do Not Sell My Personal Information" Rights

If you are a California resident, California Consumer Privacy Act (CCPA) may permit you to "opt out" of the "sale" of your "personal information" to "third parties" (as those terms are defined in the CCPA). CCPA recognizes certain exceptions to the definition of "sale," such that not all transfers of personal information are "sales." For example, transferring personal information to a "service provider" under the law is not a sale.

You have an option to opt out of the sale of your personal information and data for the purposes of interest-based advertising at all times. When you opt out, you will not stop receiving ads, they just won't be based on topics you like, your interest, behavior, demographics, etc. You can opt out by choosing one of the following options (for more information please read the ''Opt Out'' Section of our Privacy Policy):

a) Via third-party IBA provider:

If you choose to opt out by following one of the third-party IBA provider's opt out mechanism, you should stop receiving interest-based and targeted ads via the selected IBA provider, but you may continue to receive interest-based or targeted ads through other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options b) and c) below.

b) Via "Do Not Track Settings" in mobile phone:

Turn on "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-Based Ads" on your Android device.

c) Via our Apps:

If you would like to opt out of the sale of your personal information, choose "Opt Out of IBA" within the settings of our Apps (where available).

ABOUT US AND THIS PRIVACY POLICY

As used in this Privacy Policy, "OUTFIT7", "we", "us" or "our", "ours" refers to Outfit7 Limited, 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, and all its subsidiaries.

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the "EULA") governing the use of all "OUTFIT7" branded software applications (the "App/s"), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the App. This Privacy Policy covers how we collect, use, disclose, transfer and store information received about you and/or information received about your computing device through your use of the Apps.

By using our Apps you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may 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 Applications. As described in greater detail below, we may share this 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, content, and advertising.

For general information please feel free to contact us via https://outfit7.com/game-support/ and for privacy questions via [email protected], or call us on our toll-free telephone number: +1 (256) 203-9712.

INFORMATION AND DATA WE COLLECT FROM YOU

1. Technical Information and Data

We collect technical data 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.

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

  • IP address; Country code;
  • IDFAs, IDFVs, same app key for iOS, Advertising IDs;
  • Language; Locale (location where a given language is spoken);
  • Time zone, session start/stop time;
  • Network status (WiFi, etc.), browser plug-in types and versions;
  • User agent string (UA), platform, SDK version, timestamp;
  • All Outfit7 apps installed;
  • Technical device information (e.g., device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application;
  • Push notifications token;
  • Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple's Game Center).

Additionally, for playing video advertisements through a video platform provider, we may collect additional information about your device, such as:

  • "do not track" flag;
  • page URL;
  • Iso code of the country set on device;
  • device date;
  • whether Limit Ad is enabled or disabled;
  • type of device (tablet or not).

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 on iOS. If you wish to prevent this, please update the App with the latest version available on App Store.

2. Advertising and Application Usage Information and Data

When you use our Apps, we may collect additional information by using device identifiers that permit identification of your device. Such information is used for advertising and analytics purposes.

The information collected includes:

  • Which advertisements are shown;
  • Length of time an advertisement is visible and the size of the advertisement;
  • Advertisement response (if any), including clicks on ads;
  • Angle of view;
  • Application usage information, (how often you use the app, for how long you use the app, the events that occur within the app, in-app progress, in-app purchases you make and their value, aggregated usage, performance data, lifetime value of user etc.).

3. Classical Personal Information

We do not collect any personal information about you through our Apps, with the sole exception of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers are identifiers that do not identify you personally but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.

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. We will use such information to personalize the content of the App, and for users who passed the age gate and have not opted out from behavioral advertising we may use such information to display targeted ads. You can opt out from receiving targeted ads by choosing one of the options described in the ''Opt Out'' Section of our Privacy Policy.

When you voluntarily contact us directly, we may collect information about you that you provide us (such as your name and surname, email address). We will use such contact information only for the purpose for which you provided it to us. We will not share this information with third parties.

If you wish to delete your contact information that we received from you when you contacted us, please send an e-mail to [email protected] and your contact information will be deleted from our database.

For the My Talking Tom App and the My Talking Angela App and the My Talking Hank App we also collect the information about the name you give to Tom/Angela/Hank and your rating of the Application (if any) and for the Talking Tom Bubble Shooter App we collect information about the nickname you choose. Please do not use your real name.

HOW WE USE YOUR INFORMATION

1. In General

We use the information we collect about you/your device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

  • Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Apps, administering the Apps, and customer communications.
  • Displaying advertisements: displaying third-party advertisements in our Apps and showing advertisements for our Apps in other publisher's apps. Please see more in Advertising Section of this Privacy Policy.
  • Cross-promotion: cross promoting our Apps and services, meaning we may promote one of our Apps while you are playing a different App of ours.
  • Attributionand fraud prevention for advertising purposes: for some of our Apps we use third-party services for attribution and fraud prevention for advertising purposes and for privacy compliance purposes. Please see more in Tracking Section of this Privacy Policy.
  • Analytics and research: understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new game features and content. We use the data we receive from Third-Party Social Network only for internal analytics. For opting out from analytics please visit Opt-Out Section of this Privacy Policy.

2. Game Notifications

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 identified themselves as under 16. We use such notifications to remind you about your activities within the App. You will receive push notifications only if you are subscribed to such notifications in the App. To unsubscribe, please use the instructions provided below:

  • For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap "Notifications"; Find the App; Tap on the icon of App; Manage the "Notifications" option by sliding it OFF or ON.
  • For Android and Windows: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the "info screen" on the homepage of the App and choosing the "Settings" option. Here, push notifications can be disabled by unchecking the "Notification" option within the App.

We collect push notification tokens for us to be able to determine whether you are subscribed to push notifications. When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

For the restriction on the usage of information please see 'Children's Privacy' Section of this Privacy Policy.

3. Survey

We are conducting surveys to improve our services and you may freely decide whether you would like to help us or not.

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 under the age of 16 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.

HOW WE MAY SHARE YOUR INFORMATION TO THIRD PARTIES

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, tracking providers, third-party advertising providers and other third-party service providers that support the Apps (collectively referred to as "Partners"). We may 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 delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners' advertising campaign performance. We may share such information to:

  • Our analytics providers: For some Apps we use third-party analytics such as BigQuery, and Firebase Analytics for the purposes of delivering our services, conducting analysis and research. To get more information about how your data is being collected and processed you can visit the site "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/. Additionally, we have also integrated Google Play Developer Console data like Impressions, Downloads, and Traffic Sources into a Google Analytics account to see how many times people viewed or downloaded our apps from Google Play. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. Third-party analytics providers have the right to process the data in accordance with their privacy policies (https://www.google.com/intl/en/policies/privacy/#nosharing) and such collection and processing is limited to the disclosure in aggregated manner, for the purposes of showing trends about the use of their services, for advertising services and marketing purposes. We can aggregate the data for benchmarking feature.
  • 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 and Google's Android Backup Service.
  • Our attribution and fraud prevention providers: For some of our Apps we use third-party services for attribution of our advertising campaigns, for fraud prevention and privacy compliance purposes. Please see more in Tracking Section of this Privacy Policy.
  • Third - party advertising partners: We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Apps for free or at low cost. Such third-party advertising partners include but are not limited to advertising providers listed at https://outfit7.com/third-party-ad-providers/. Please see more in Advertising Section of this Privacy Policy.
  • Advertising partner's third-party tracking provider: For some Apps we may allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. Please see more in Tracking Section of this Privacy Policy.
  • Built-in customer support tool: In some of our Apps we offer an in-app customer support tool, which allows users to get answers faster and easier. The tool provides answers to the FAQ, and enables users to contact us within the App. The in-app customer support tool is provided by 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/.
  • Video hosting provider: In some of our Apps we use a third party video hosting provider, JW Player, that assists us in delivering video content to you. You can read more about their data processing practices in their privacy policy available at https://www.jwplayer.com/privacy/.

Other third - party service providers: For some Apps we use Unity Software to develop such Apps. For the data processing by Unity please see Unity's privacy policy available at https://unity3d.com/legal/privacy-policy.

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].

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 in this Privacy Policy. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices. While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information and therefore you acknowledge that we are not liable for any third-party privacy breach and that our liability for our Partner breaches is limited to the amount we are able to receive as indemnification from our Partners (legal costs exempted).

Some of the Apps allow you to submit content generated in or by the Apps to third-party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols of such third parties, which are designed to enable content sharing with such third parties.

ADVERTISING

When you use our Apps we may display contextual advertisements to you. To enable advertising, we allow our advertising partners to collect online identifiers (such as Advertising ID on Android and IDFA on iOS) that might be considered as personal information under some 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.

For some territories, we may use and share with our advertising partners technical and advertising and application usage information we collect from you (please see Information and Data We Collect From You Section of this Privacy Policy) in order to enable our advertising partner to deliver, target and optimize third-party advertising in our Apps, so that the advertisements you see are more relevant to you and are based on your app and device usage, online behavior and interests (this is commonly referred to as online behavioral or interest based advertising, i.e. IBA). 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 will always follow applicable legislation and accepted market practices; thus, we will not use and share information for the purposes of behavioral advertising for users who did not pass the age gate in our Apps and for those who opted-out of IBA. For more information on behavioral advertising and our IBA providers please see Interest-Based Ads Section of this Privacy Policy. For opting out from sharing your information and data for the purposes of behavioral advertising please visit Opt-Out Section of this Privacy Policy.

ATTRIBUTION

When you use the App, we or third parties operating the advertisement serving technology may use information logged from your device using SDKs, cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the App and to calculate the number of unique and repeat views of advertising.

For some of our Apps we use third-party attribution and data collection tools from our service providers for the purposes of attributing performance, ad visibility and privacy compliance of third-party SDKs in our Apps.

We use third-party attribution and data collection tools from our service providers, such as AppsFlyer, for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such tools may use cookies, APIs, and SDKs in our Apps to enable them to collect and analyze user and device related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.

In addition, our Partners may use their own attribution technologies (including and without limitation: SDKs, cookies, Web beacons, HTTP cache, local shared objects and other technologies) to attribute impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third-party advertising campaign performance.

THIRD-PARTY SOCIAL NETWORKS

1. Connecting to Third-Party Social Networks

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. By logging in to your Third-Party Social Network account to connect to our App or by using the App to share content on such Third-Party Social Network, you are authorizing us to collect, store, and use any and all information, in accordance with this Privacy Policy, that you agreed that such Third-Party Social Network could provide to us through the Application Programming Interfaces ("API"). You authorize us to do so when you "accept" or "allow" (or similar terms) connection of one of our Apps to such Third-Party Social Network. 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. 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 at [email protected].

2. Data We May Access Via Third-Party Social Networks

If 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, including but not limited to participation in leader boards, multi-player games or the downloading and uploading of content, OUTFIT7 and its affiliates may also collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and achievements), or identify content that is created and shared by you with other players. Data that personally identifies you is collected, used, stored and transmitted in accordance with this Privacy Policy.

THIRD-PARTY TERMS AND CONDITIONS

Please note that your access to and ability to use and interact with the Apps 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. You recognize and agree that OUTFIT7 is not liable for any such third-party terms and conditions and their use of your personal information.

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 are not responsible for 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. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.

We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment, or dissemination of information you voluntarily choose to provide to them.

CHILDREN'S PRIVACY

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 16, 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 16, 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].

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 16. The age gate is being conducted after the download of some of our Apps for specific territories to assure the privacy and protection of younger users of our Apps. The features enabling potential collection and sharing of personally identifiable information, except for persistent identifiers, are disabled for device IDs of 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 16 in our Apps, but only the information that their device ID did not pass the age gate.

The only personal information we collect from users who have identified themselves as below the age of 16 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 solely for providing support for the internal operations meaning to place contextual advertisement (including frequency capping), 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.

When using the persistent identifiers, we will not contact users under the age of 16, display behavioral advertising to them, nor do any user tracking or profiling. In addition, we strive that all our advertising partners adhere to the same standards for the collection, usage and disclosure of children's personal information as we do, but we cannot be responsible if they breach the commitments, they gave to us regarding the collection of information. In case of such breaches, you agree that our liability is limited to the amounts we are able to receive as indemnification for the breaches from our advertising partner. For the detailed information about disclosure to third party service providers used in relation to users under 16 please see section How do we share your information and data to third parties of this Privacy Policy click here. For any additional questions about third-party information disclosure please refer to [email protected].

We will send push notifications only to users who allow us to do so to reengage them in terms of using the App. You may unsubscribe at any time by following the instructions in section Push Notifications of this Privacy Policy. We strive to ensure that the content of the push notifications will always be family-friendly. Push notifications are local, contextual and sent in app only and not from a server or in conjunction with other user information.

KIDS PRIVACY ASSURED BY PRIVO: COPPA SAFE HARBOR CERTIFICATION

Outfit7 Limited is a member of the PRIVO Kids Privacy Assured Program ("the Program") for COPPA Safe Harbor Certification. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online.

COPPA Safe Harbor Certification

The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification seal. The 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 [email protected]. If you have further concerns after you have contacted us, you can contact PRIVO directly at [email protected].

"DO NOT SELL MY PERSONAL INFORMATION" RIGHTS

OPT-OUT

You are always free to opt out of the sale of your personal information and data for the purposes of interest-based advertising. You can opt out by choosing one of the following options:

Opting Out of IBA

1. Via third-party IBA providers

FB Ads https://www.facebook.com/settings?tab=ads;

InMobi Ads https://www.inmobi.com/page/opt-out/;

Google (Ad Manager 360) https://www.google.com/ads/preferences/html/mobile-about.html;

Google (AdMob) https://www.google.com/ads/preferences/html/mobile-about.html;

AppLovin https://www.applovin.com/optout;

Smaato https://www.smaato.com/privacy/#section4;

Vungle https://vungle.com/opt-out/;

PubMatic https://pubmatic.com/legal/opt-out/#IBA;

Apple (Search Ads) https://support.apple.com/en-us/HT202074;

Google (Ad Words) https://support.google.com/ads/answer/2662922?hl=en;

Chartboostwww.chartboost.com/useroptout;

Click Tech Limited (dba Yeahmobi) https://en.yeahmobi.com/html/privacypolicy/index.html;

Gameloft S.E. – Please see Section "Limit Ad Tracking / Do Not Track of Gameloft Cookie Policy available at https://www.gameloft.com/en-gb/legal/showcase-cookie-policy;

Adverty AB https://www.adverty.com/privacy-policy#optout;

Mintegral (Mobvista) https://www.mintegral.com/en/privacy/#yourDataRights;

ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#how-to-control-your-info;

Fyber Monetization Ltd. https://www.fyber.com/privacy-policy/#user-choice.

A9.com, Inc. and Amazon Europe Core S.à.r.l https://www.amazon.com/adprefs;

The Rubicon Project, Inc https://rubiconproject.com/privacy/consumer-online-profile-and-opt-out/;

Anzu Virtual Reality LTD https://anzu.io/privacy,https://anzu.io/sub-processor-list/;

My.com B.V https://target.my.com/optout/;

Tappcelerator Media https://www.tappx.com/privacy-policy/#opt-out;

Snap Inc. https://support.snapchat.com/en-GB/a/advertising-preferences;

Firebase Analytics (Google Analytics for Firebase) https://policies.google.com/technologies/ads;

Verve Inc., https://verve.com/product-privacy-policies/#using-personal-information;

Bidmachine Inc. (Stack), https://bidmachine.io/sdk-opt-out/;

TikTok, https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data/personalization-and-data;

Algorix Technology Pte https://www.algorix.co/privacy-policy/#optout;

Index Exchange Inc.https://www.indexexchange.com/privacy/;

LoopMe Limited https://legal.loopme.com/privacy-center#opt-out;

Tappcelerator Media, S.L. https://www.tappx.com/privacy-policy/;

MobileFuse LLC https://mobilefuse.com/privacy-policy;

Bidstack Ltd https://www.bidstack.com/privacy-policy/;

Unity Technologies SF https://unity.com/legal/privacy-policy.

If you choose to opt out by following one of the third-party IBA provider's opt out mechanisms, you should stop receiving ads based on your interest via the selected third-party IBA provider, but you may continue to receive interest-based or targeted ads via other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options 2. and 3. below.

2. Via "Do Not Track Settings" in mobile phone

If you choose to opt out via "Do Not Track Settings" in your mobile phone all providers of advertising services are bound to comply with such "Do Not Track" setting, but we cannot provide any guarantees on their behalf. If you choose the opt-out option available via our Apps, we will not share your advertising ID with advertisers for the purposes of IBA. We provide no guarantees regarding the information provided prior to opting out. Some providers may have additional opt-out mechanisms implemented.

If you turn on "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-Based Ads" on your Android device, you can restore interest-based ads by turning the settings off. When you opt out, 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 your interests. Our advertising partners may continue to serve you ads based on other non-personal information, such as ads related to the content of the application you are using.

Your iOS or Android mobile device may provide a "Limit Ad Tracking" or "Opt Out of Interest-Based Advertising" setting. When you have opted out using this setting on a device, our partners will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.

You can find the setting for your mobile device by following the directions below or contact your device provider.

The reason for switching from device IDs to Advertising Identifier is that advertisers can use this identifier only for advertising and for no other purpose, while users can choose to opt out of tracking via the settings of mobile phone. Advertising Identifier is an anonymous identifier for advertising purposes which enables users to reset their identifier or opt out of interest-based ads. The parties participating in advertising are obligated to follow users' choice for opting out of tracking according to the app store guidelines.

IOS DEVICE

  • iOS 7 or Higher

Go to your Settings \> Select Privacy \> Select Advertising \> Enable the "Limit Ad Tracking" setting

  • iOS 6

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 Google Settings app \> Ads \> Enable "Opt Out of Interest-Based Advertising"

3. Via our apps

If you would like to opt out of the sale of your personal information, we have created an opt-out option within some of our Apps. You may choose it by visiting ''Info Screen'', ''Settings'' and ticking the ''Disable Interest-Based Ads''. Choosing this option will mean that you will still be served ads, but they will not be tailored to your preferences. Should you decide to opt out of advertising altogether, you may make an in-app purchase to do so, or you can delete the App.

IN-APP PURCHASES

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store.

For more information on in-app purchases in our Apps please see In-App Purchases Section of the End User License Agreement available at https://outfit7.com/eula/.

SPECIAL PRIVACY FEATURES IN SOME OF OUR APPS

Some of our Apps offer you the option to talk to the virtual character of such Apps. All our Apps that offer such feature will always ask you for your permission to access the microphone on your device in advance. 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 offer you the option to connect your device to an entertainment device, i.e. a talking, animatronic streamer GameBud™ Talking Tom® (the "Entertainment Device"). In the territories where the Entertainment Device is available for purchase, all of our Apps that offer such connection feature will offer users an option to connect to the Entertainment Device in the App Settings. To connect to your Entertainment Device, our App will need to use the Bluetooth on your device to find your Entertainment Device. On iOS we will ask you for your permission to access the Bluetooth in advance. On Android, we will be automatically able to scan for the Entertainment Device if your Bluetooth is turned on, if not we will ask you to allow us to turn on the Bluetooth on your device. If you decide to give us the permission, your Entertainment Device will be able to connect to our App and react on your achievements and progress in the App. If you decide not to give us the permission, the game connection function of your Entertainment Device will not work. Please note that privacy practices of your Entertainment Device are not subject to this privacy policy. Please visit Huge Play's privacy policy available at http://gamebud.com/talkingtom/privacy to learn more about privacy practices of your Entertainment Device.

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.

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 the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all our Apps has ceased.

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.

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it, i.e., you have a right to access personal information we hold about you, to request the deletion of your personal information, to opt-out of the sale of your personal information, and right to portability of personal information. 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 of access. You have a right to know what information we have collected 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 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 45 days of receipt of your request and verification of your identity. For Privacy enquiries you may contact us via [email protected] or contact us on by calling us on our toll-free telephone number: +1 (256) 203-9712.
  • Right to 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 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 45 days of receipt of your request and verification of your identity. Please note that we may still retain some or all 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.
  • Right to opt-out of the sale of your personal information. In some cases, you may have the right to request a restriction of the processing of your personal information. You are always free to opt out from the future collection of your personal information by us and our Partners by choosing one of the options, described in "Do Not Sell My Personal Information" Rights section.
  • 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 Business. Should you wish to do that, please contact us via [email protected].

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.

California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, we will provide California customers certain information upon request ("Right to access") or permit California customers to opt out of, this type of sharing ("Right to opt-out of the sale of your personal information").

If you are a California resident and wish to obtain information about our compliance with this law, please contact us via [email protected]. We may request information from you to verify your identity. Please note that Outfit7 is not required to respond to requests made by means other than through the provided email address, mail address, or our toll-free telephone number: +1 (256) 203-9712.

INTERNATIONAL TRANSFER

We operate globally, thus we may for the purposes described in this Privacy Policy transfer your information to our affiliated entities and/or to other third-party service providers across border and from your country or jurisdiction to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, 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.

STORING OF INFORMATION

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 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 if it is needed for the purposes of providing, improving or personalizing our services.

DELETION OF INFORMATION

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://outfit7.com/privacy/.

Should you request so by informing us on [email protected], we will send you all the updates of this Privacy Policy to your e-mail. We will also inform you about any material updates of our Privacy Policy with an in-app banner and a link.

PRIVACY QUESTIONS

If you have questions or concerns about OUTFIT7's Privacy Policy or information processing, please contact us through [email protected], or call us on our toll-free telephone number: +1 (256) 203-9712.

OUTFIT7 Privacy Policy, v. 20.9, updated March 13, 2023