Last Updated: February 28, 2020
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy applies to Toe Studio’s games, apps, websites and related services (together the “Services” or “games”, “apps”, “websites” for individual categories). This Privacy Policy explains how we, and affiliated companies (collectively, "Toe Studio" or "we", "us", "our") collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.
While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes:
Basic Identifiers and Contact Information
We collect some information from you when you provide it to us
directly, such as via an email or online form, through the support
feature embedded in our Services, or through another form of inquiry.
This information may include your name, email, and phone number.
Device Information
When you download and use our Services, we automatically collect
information on the type of device you use, operating system,
resolution, application version, mobile device identifiers (such as
your device ID, advertising ID), language, time zone and IP address.
Usage Information
We collect information automatically about your activity through our
Services, such as the date and time you used a service, features you
have used, your in-app purchases history, subscriptions, your
interaction with advertisements, and data generated when you use our
Services (for example your game progress which may be stored with your
Apple ID on iCloud for iOS Devices or with your Google Play Games
profile for Android Devices in some of our Services).
Location and Other Information
We may collect, with your consent, other information such as precise
geolocation (latitude and longitude) using information including GPS,
Bluetooth or Wi-Fi connections. Similarly, we may ask for access to
your camera in case you want to use certain features of our Services.
Information we obtain from third parties
We may receive information about you from our third party service
provider, who collects this information through our Services in
accordance with their own privacy policies. A list of the third
parties that operate in our Services can be found in the APPENDIX B
below.
Information we obtain from Facebook
If you use our Services on Facebook, we may receive any of the
information you provide or permit to be provided to us via Facebook.
Such information may include your user ID and your use of our game,
including with whom you share our game on Facebook and your email
address in case you wish to contact us for support. The information we
receive depends on the Services you are using, Facebook's terms of
service and privacy policy, your privacy settings, and, if applicable,
your friends’ privacy settings. If you are uncertain about what
information Facebook is sharing with us, please go to Facebook’s
website to find out more about Facebook’s privacy practices.
The information we receive from Facebook and other third parties is
stored and used by us in accordance with this Privacy Policy.
User generated content we obtain from you
We may collect content from posts or uploads on social networks or
platforms or direct contact, subject to your consent if applicable.
Such content may include, your name, social media username, image,
likeness, voice, other identifiable information available in such user
generated content.
Cookies and similar data collection technologies
We and our third party advertising networks and their partners may use
cookies and similar technologies, such as mobile “SDK”, to provide and
personalize our Services and to provide targeted advertisements. Some
of these technologies can synchronize behavior across different mobile
apps, devices and websites so that advertisements can be tailored to
your interests. This process is called personalized advertising. In
addition, we and certain advertising networks may access your
inventory of installed apps to avoid advertising already installed
apps. If you'd like to opt-out from having advertisements personalized
in this way on your mobile device, please see the ‘Opt-out of targeted
advertising’ section below.
For more information on how third parties may use cookies in our
Services, go to APPENDIX A and APPENDIX B further below.
We have set out below a description of the ways in which we use your Personal Data, the legal bases we rely upon to do so and to provide you with an option to opt-out of certain practices, where applicable. We may use your Personal Data:
To provide and maintain our Services, recognize you when you return to our apps, and perform essential business operation, our legal basis for processing is performance of a contract with you which you entered into with us when you download our Services and accept our Terms of Service.
To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data). Our legal basis for processing is legitimate interests for running our business, provision of administration and services.
To communicate with you about any career requests, contact forms,
helpdesk support and to understand how you use our Services so that we
can continuously improve our offerings. Our legal basis is performance
of a contract, legitimate interests or consent depending on the
particular case to keep our users updated about our Services and our
new features in accordance with your preference, and to continue to
improve the Services we offer.
To opt-out of communication with us for our Services, send us your
request through the online contact us support feature.
To cross-advertise our Services and products and to send push
notifications for changes to our Services, to allow you to participate
in new features of our Services when you choose to do so. Our legal
basis is legitimate interests to be able to advertise our Services and
products to our users and keep our users updated about our Services
and our new features in accordance with your preference.
You can opt-out of receiving push notifications by turning them off at
the device level through the settings of the device.
To serve personalized advertisements in our Services using third-party
advertising networks. Our legal basis is legitimate interests
to run our business. However, if you are in the European Economic
Area, Norway or Switzerland, some of our third-party advertising
networks, will rely on your consent to process Personal Data in order
to provide personalized advertising to you, therefore you will be
asked whether you consent to the collection of your mobile device
advertising identifier and IP address so that they can provide a
personalized advertisement experience.
To opt-out or withdraw your consent from receiving personalized
advertisements, see the “Opt-out of targeted advertising” section
below.
To use user generated content which has been provided by you and such content includes Personal Data. Our legal basis is consent which is obtained directly by you from the medium (e.g. e-mail, social networks, social platforms) used to obtain such content. You may withdraw your consent by providing us with written notice by email at lekehien5431@gmail.com.
To respond to legal proceedings and other obligations or requirements under applicable law.
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Your Personal Data collected through our Services will be deleted when they no longer serve one of the above-mentioned purposes but in any event, your Personal Data will be deleted after 14 months of inactivity in your use of our Services. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
Your Personal Data collected through our Get in Touch forms will be deleted after 2 years from the date of receipt. Once we have deleted your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.
You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you a copy of your Personal Data in an electronic format.
You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such withdrawal.
To show you personalized advertisements in our apps we use third-party advertising networks and their partners, including those that need your consent and listed in ‘APPENDIX A - Advertising networks and their partners’ below, to deliver advertisements that are tailored to you based on a determination of your characteristics or interests. To do so they use personal and non-personal information such as advertising identifiers, such as the Android advertising ID and/or Apple's ID for advertising (IDFA), and/or other tracking technologies to enable and optimize this advertising procedure.
You can opt-out from personalized advertisement experience, at any time by checking the Privacy Setting tab in any of our apps or under the privacy settings of your iOS or Android device.
When you choose to opt-out, advertising networks will consider this choice as a withdrawal of consent to personalized advertisement experience and they will show contextual advertisements and not personalized advertisements based on your interests. Note: Irrespective of your choice and/or your device settings, you will continue to see non-customized advertising (e.g. “contextual” advertising) and you may continue to receive personalized ads from our third-party ad networks that obtain your consent on other apps and/or websites. For more information go to ‘APPENDIX A - Advertising networks and their partners’ below.
Any requests to exercise your rights should be made through email at lekehien5431@gmail.com. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.
We may share the above categories of Personal Data for certain business purposes, including:
Storage
Personal Data of our users are stored in our data centers of our third
party service providers in Canada and Germany, who act as data
processors.
Sharing with our service providers and partners
We use certain service providers and partners to help us operate and
improve our Services. These service providers and partners assist us
with various tasks, including hosting and maintenance, on-going
development, analytics, customer care and marketing.
We may also share, or otherwise “sell” the above categories of Personal Data for the following purposes, noting that a "sale" of personal information does not have the literal meaning of the word “sell” and as broadly defined under the California Consumer Privacy Act (and discussed in greater detail below) includes any sharing of information with third parties in exchange for “valuable consideration”:
Advertising
We may share or otherwise “sell” information with advertising partners
who distribute advertising in our Services. For further information on
the advertising networks which may receive this information, go to
‘APPENDIX A - Advertising networks and their partners’ below.
In addition to the above, we may share your Personal Data in the following circumstances or for the following purposes:
For corporate transactions
We may transfer your information if we are involved, whether in whole
or in part, in a merger, sale, acquisition, divestiture,
restructuring, reorganization, dissolution, bankruptcy or other change
of ownership or control.
When required by law
We may also share information if we also under a duty to disclose or
share your Personal Data in order to comply with any legal obligation,
or to protect the rights, property, or safety of our business, our
customers or others.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our
liability in an actual or threatened lawsuit; (ii) as necessary to
protect our legal rights and legal rights of our users, business
partners or other interested parties; (iii) to enforce our agreements
with you; and (iv) to investigate, prevent, or take other action
regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third
parties. In any such case, we will make it clear why we want to share
the information.
Cross-border data transfers
Sharing of information sometimes involves cross-border data transfers,
including transfers outside of the EEA in accordance with the law. We
only transfer Personal Data to entities in third countries that have
provided appropriate safeguards to ensure that their level of data
protection is in agreement with this privacy policy and applicable
law, for example in accordance with the rules and procedures known as
the EU-US Privacy Shield, or under contractual provisions which have
been deemed by the European Commission to provide sufficient
safeguards for Personal Data.
Social sharing features
Some of our Services offer social sharing features which let you share
actions you take in our Services with other media. You must be over
the minimum age limit that is prescribed by the legislation in the
individual jurisdiction to use any social sharing features integrated
in our Services. The use of such features enables the sharing of
information with your friends or the public, depending on the settings
you establish with the entity that provides the social sharing
feature. Our Services have social features from the following
providers:
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of Personal Data, for any reason, please use the in-app support feature in our Services or contact us in email at lekehien5431@gmail.com and we will take reasonable measures to promptly delete such Personal Data from our records.
Our Privacy Policy may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy terms of every site you visit. We have no control over and assume no responsibility for the content, privacy terms or practices of any third-party sites or services.
The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.
Social sharing features
You have the right to know and see what information we have collected
about you over the past 12 months, including:
Right to Delete
You have the right to request that we delete the information we have
collected from you (and direct our service providers to do the same).
There are a number of exceptions, however, that include, but are not
limited to, when the information is necessary for us or a third party
to do any of the following:
Right to Opt-out
You have the right to “opt-out,” or direct us to stop “selling” or
otherwise sharing your information with third parties in exchange for
monetary or other valuable consideration. To submit an opt-out
request, please follow the instruction under the ‘Opt-out of targeted
advertising’ paragraph found above, to configure the Privacy Setting
in any of our app or by checking your device privacy settings.
Other Rights
You can request certain information about our disclosure of your
information to third parties for their own direct marketing purposes
during the preceding calendar year (to the extent we have shared
information for such purposes within the given period). This request
is free and may be made once a year. You also have the right not to be
discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights
To request access to or deletion of your personal information, to
opt-out, or to exercise any other rights under California law, please
follow the instruction under the ‘Exercise your privacy rights’
paragraph, found above, and follow the necessary steps.
Response Timing and Format
We aim to respond to a consumer request for access or deletion within
45 days of receiving that request. If we require more time, we will
inform you of the reason and extension period in writing.
This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.
In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us by email at lekehien5431@gmail.com.
For personalized advertising, the advertising networks and their partners, that are listed below, and would like your consent, if you reside in EEA, unless they have another legal basis for processing, may collect or receive device information from our apps and other apps that include personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). For more information on how to opt-out go to Opt-out of targeted advertising [hyperlink to take you above] further above. In addition, the advertising networks listed below, with the exception of Fyber, Mobfox, and PubNative who act as data processors upon our instructions, are independent data controllers in respect of your Personal Data and you can learn more about how each handles your data by accessing their respective privacy notices using the hyperlinks below.
Amazon Developer is an advertising service provided by Amazon, Inc. (US). Amazon does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service.
Privacy Policy: https://aws.amazon.com/privacy/
You can manage your personalized ad preferences in relation to Amazon directly from your Amazon account here: https://www.amazon.com/adprefs
AppLovin is an advertising service provided by AppLovin Corporation (US)
Privacy Policy: https://www.applovin.com/privacy
Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our Services, relevant signals are collected directly from the user upon creating an account in such service.
Privacy Policy: https://www.facebook.com/about/privacy/
You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account.
Fyber is an advertising service provided by Fyber Group. (Israel)
Privacy Policy: https://www.fyber.com/legal/privacy-policy/
AdMob by Google is provided by Google Inc. (US)
For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google: https://www.google.com/policies/privacy/
For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903
You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
Google, as a third-party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt-out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: https://www.google.com/ads/preferences/
InMobi is an advertising service provided by InMobi PTE Ltd (Singapore)
Privacy Policy: https://www.inmobi.com/privacy-policy/
Opt-out: https://www.inmobi.com/page/opt-out/
IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.
Privacy Policy: https://www.ironsrc.com/wp-content/uploads/2017/01/ironSource-Privacy-Policy.pdf
Liftoff is an advertising service provided by Liftoff, Inc. (US)
Privacy Policy: https://liftoff.io/privacy-policy/
MoPub is provided by MoPub, Inc. (US)
For more information on what information MoPub collects and how it's used, please read MoPub Privacy Policy: https://www.mopub.com/legal/privacy/
For more information on MoPub Partners, please visit: https://www.mopub.com/legal/partners/
You can opt-out from MoPub service by following the instructions on MoPub Opt-out page: https://www.mopub.com/optout/
OpenX is an advertising service provided by OpenX Software Ltd (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.
Privacy Policy: https://www.openx.com/legal/privacy-policy/
PubMatic is an advertising service provided by PubMatic,Inc. (US) and does not require opt-in or opt-out signals from users in our Services. Relevant signals are collected directly from Amazon for the users who have or create an account in such service.
Privacy Policy: https://pubmatic.com/legal/privacy-policy/
Opt-out: https://pubmatic.com/legal/opt-out/
PubNative is an advertising service provided by PubNative GmbH (Germany)
Privacy Policy: https://pubnative.net/privacy-policy/
Smaato is an advertising service provided by Smaato, Inc. (US)
Privacy Policy: https://www.smaato.com/privacy/
For more information on the Smaato Vendors, please visit: https://www.smaato.com/partner-list/
Unity Ads is an advertising service provided by Unity Ads Inc. (US)
Privacy Policy: https://unity3d.com/legal/privacy-policy
Verizon Media, previously known as Oath, provides advertising services under their AOL, Yahoo and other brands.
Privacy Policy: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/index.html
For more information on VerizonAOL (OATH) Vendors, please visit: https://www.verizonmedia.com/policies/ie/en/verizonmedia/privacy/topics/thirdparties/index.html
We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.
Adjust is analytics service provided by Adjust GmbH (Germany)
Privacy Policy: https://www.adjust.com/privacy-policy/
AWS is cloud computing services provided by Amazon Web Services, Inc. (US).
Privacy Policy: https://aws.amazon.com/privacy/
Fabric is an analytics service provided by Google Inc. (US)
Privacy Policy: https://policies.google.com/privacy
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. (US) that connects data from the Facebook advertising network with actions performed on the Services.
Privacy Policy: https://www.facebook.com/about/privacy/
Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.
Privacy Policy: https://www.facebook.com/about/privacy/
Firebase is an analytics service provided by Google Inc. (US)
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://www.google.com/intl/en/policies/privacy/
Google reCAPTCHA is a spam protection service provided by Google LLC. (US)
It is primarily used to distinguish whether an input is made by a natural person or abusive by automated processing. The service includes sending data required by Google for the reCAPTCHA service to Google. Additional information about Google reCAPTCHA and Google's privacy policy can be found at https://policies.google.com/privacy.