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CHILD PRIVACY POLICY

Last Updated: October 21, 2022

 

This Children’s Privacy Policy (“Policy”) explains how Tilting Point Media LLC (referred to as “Tilting Point”, “we”, “us”, or “our” in this Policy) collects, stores, uses, or otherwise processes personal information of children of our Services (as defined below), and what rights you (or your parent) have if we are processing your personal information. 

This Policy governs our practices relating to children in connection with the online games or applications listed here (the “Services”). For more information about Tilting Point’s general privacy practices, please visit our general audience Privacy Policy

In this Policy, when we refer to “children” or “child,” we mean users of the Services who tell us that they are under the age of 13, and when we refer to a “parent” we mean parents and legal guardians.

HOW WE COLLECT AND USE PERSONAL INFORMATION

When a user tells us they are under the age of 13 on the Services, we will collect and use only limited personal information in accordance with the U.S. Children’s Online Privacy Protection Act. For example, we will collect persistent identifiers automatically when children interact with the Services, such as IP address and device advertising identifier, and use that information to support internal operations. These operations may include maintaining or analyzing the functioning of the Services, performing network communications, authenticating users, personalizing content, serving contextual ads or frequency capping, protecting security and integrity, and for legal or regulatory compliance. 

If a child provides us with their online contact information, we may also use their information to respond to the child’s request. In some cases, we may also use contact information for the child and/or parent to collect parental consent. If we ask for parental consent to use a child’s personal information, we may also use children’s personal information as described in the notice provided to parents and in our general audience Privacy Policy.

We will not condition a child’s participation in an activity within the Services on the child disclosing more personal information than is reasonably necessary for that activity.  

HOW WE DISCLOSE PERSONAL INFORMATION

We may share children’s personal information with third parties to achieve the purposes described in this Policy, such as:

  • other companies in the Tilting Point group (which includes our parents and subsidiaries) or our Services related affiliates, for example where they help us develop or operate the Services;
  • persons or companies outside of the Tilting Point group that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services);
  • prospective or actual buyers or investors (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
  • competent courts of law or other government authorities where disclosure is necessary as a matter of applicable law or regulation,
  • any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
  • otherwise with parental consent.

The operators that may collect or maintain personal information from Children through the Services are the companies identified here.  Questions about any operator’s privacy practices and the use of children’s information may be directed to Tilting Point by contacting privacy@tiltingpoint.com.

PARENTAL CONTROLS AND CHOICES

Parents of children who use the Services can email us at privacy@tiltingpoint.com if they wish to:

  • review their child’s personal information, request that it be deleted, or refuse to allow any further collection or use of their child’s personal information; 
  • agree to our collection and use of their child’s personal information without allowing disclosure to third parties unless the disclosure is part of the Services; or
  • ask any other questions about this Policy or how we handle their child’s information.  

Depending on the applicable law in your jurisdiction, you may have additional rights in respect of your personal information. If you have any questions about what rights and choices apply in your jurisdiction, please contact us. You may also review our country-specific privacy notices in Tilting Point’s general audience Privacy Policy

CHANGES

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also inform you of any changes by other means that are appropriate to the significance of the changes.

CONTACTING US

If you have questions regarding this Policy or our practices relating to children, you can reach us by email at privacy@tiltingpoint.com. You can also reach us by mail at Tilting Point Media LLC, 521 Fifth Avenue Floor 21 New York, NY 10175, USA.