Last Updated: July 16, 2020.
By “data controller”, we mean an entity that determines how and why personal data is processed. With regard to the personal data we process as described in this Policy, we are the data controller. Our company name is Tilting Point Media LLC. Our address is 521 Fifth Avenue Floor 21, New York, NY 10175, USA. While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 6 of this Policy.
In matters related to this Policy, you can reach us by email at firstname.lastname@example.org. You can also reach us by mail at 521 Fifth Avenue Floor 21 New York, NY 10175, USA.
When we process or collect your data, we ensure that we have a legal basis to do so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons: To perform our contract with you (e.g. the license we grant to you to use our Services in accordance with the Terms of Service), we may process your data as necessary to:
Based on our legitimate interest to constantly improve our Services, we may process your data to:
Based on our legitimate interest to make sure you have the best possible user experience in our Games, we may process your data to:
Based on our legitimate interest to make sure our Services are a fair and safe environment for all users, we may process your data to:
Based on our legitimate interest to promote our Services and to make sure we reach interested audiences, we may process your data to:
Based on our legitimate interest to maintain security for our Services and business, we may process your data to:
With your consent, we may process your data:
Finally, we may process your data as necessary:
In addition, we may process your data for additional purposes which are compatible with any of the purposes listed above.
Advertising is one of the tools that helps fund our Services and enables us to make our Games available free of charge. In some of our Games, we may show our own ads and also ads from third parties. We also advertise our Games outside of our Services on third-party properties such as websites or applications. This section provides more information on how we may use your data for advertising purposes, and how you can control the use of your data for these purposes. Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An “Advertising ID” is an alphanumeric string of digits provided by the operating system of your mobile device (e.g. your phone or tablet). It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers (“IDFA”) on iOS devices and Google Advertising Identifier (“GAID”) on Android devices. Advertising IDs are used for interest-based advertising and other advertising related purposes. You can control the extent to which your Advertising ID is used for these purposes. Using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising ID. For example, you can “limit ad tracking” on iOS devices or “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them as you prefer on each of your devices individually. It may take some time for your updated settings to take effect. Please consider that resetting or limiting the use of your Advertising ID will not stop you from seeing ads or necessarily reduce the number of ads you see, but the ads you see may be less relevant to you and will not be served based on your personal data. For more information on mobile privacy settings, you may refer to third-party resources such as: https://www.networkadvertising.org/mobile-choice
When you see ads in our Games, we may share your Advertising ID and IP address with our advertising partners if you have given your consent to the use of your data for personalized ads. Our advertising partners may also collect information directly from our Games through technologies such as software development kits (SDKs). In each case, they may use your data for a number of purposes, including to limit the number of times you see an ad or to personalize the ads you see to make them more relevant to you (for example, based on the past activity they have associated with your Advertising ID). For more information, please refer to the privacy policies of our advertising partners listed here. If you do not provide us with consent to use your data for personalized ads, we will not share your personal data (such as Advertising ID) with our advertising partners and will indicate to them that you have not consented to the use of this data for personalized ads.
When you see our ads outside of our Services (for example, on third-party properties such as websites or applications), the ad network involved in delivering that ad to you may, based on information such as the past activity they have associated with your Advertising ID, have determined that you may be interested in our Services. Ad networks may also use your data to:
In addition, ad networks may provide services where they use Advertising IDs or other identifiers to find users who are likely to be interested in our Services because their past activity or interests are similar to those of others known by the ad network to use our Services. When ad-networks use your Advertising ID in these ways, they do so based on their respective privacy policies or notices.
For both ads in our Games and our ads outside of our Services, Advertising IDs or other identifiers are also used for ad measurement, which involves the collection of metrics such as total views, clicks, or installs generated by an ad. Measurement data may be directly or indirectly collected or received by multiple parties involved in ad delivery (including us and our advertising partners), for example through technologies such as web beacons inserted into ads. This data is used for purposes such as to provide measurement services, to detect, investigate and prevent fraud or fraudulent behavior, or to settle payments between the parties involved in ad delivery.
We may process the following data relating to you:
We do not expect or intend to collect or otherwise process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions. Please do not provide this kind of information to us or use the Services to make it available to others.
We may collect data relating to you from the following sources:
Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them. You have a number of options to limit or control the extent to which your data is processed. For example, you can choose to not connect your third-party accounts with our Games, use your device settings to reset or limit the use of your Advertising ID, withhold consent for customized advertising, or disable some or all cookies from your browser settings.
We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:
In addition, please consider that some information you submit or make available through the Services may be visible to other users of our Services. This typically applies to, for example, your public profile information in our Games (such as your in-game alias), your chat messages in our Games, and information used to provide social features such as clans or leaderboards. We encourage you to carefully consider what information you wish to share in this manner.
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period, we will either delete or de-identify your data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (for example, aggregate data).
We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the data processing activities described in this Policy. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary depending on the sensitivity of the data, but typically include, for example, encryption, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.
For users located in the European Union (“EU”) and the European Economic Area (“EEA”), if we are processing your data, you have the right to:
Where our processing of your data is based on your consent, you also have the right to withdraw your consent at any time. Please be aware that we may continue processing your data despite your withdrawal of consent, if we also have another lawful basis for doing so. To access your data in our Games or to request its deletion, please contact us at email@example.com. To unsubscribe from our marketing communications, please use the unsubscribe link provided in the messages we send. The unsubscribe link is typically found at the end of the message. To exercise any of your rights, you may also contact us at firstname.lastname@example.org. To fulfill requests submitted by email, we may need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. For example, we may ask you to provide sufficiently detailed information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf. While we will usually not do so, we reserve the right to charge you an appropriate fee for the exercise of your rights where permitted by applicable laws and regulations. If you believe that we have infringed your privacy rights, please contact us so that we can try to resolve the issue. However, if you are an EU resident, you have the right to lodge a complaint with your local supervisory authority.
Tilting Point is a company based in the United States and your data will be transferred to the US for processing. US privacy laws may be very different from those of your country. However, as described in this Policy, Tilting Point takes steps to protect your data and your privacy rights after international transfer. Tilting Point’s transfer to the US of the data of EU/EEA residents is permitted by EU law (GDPR) on the basis that it is necessary to perform a contract (providing you with the Services under our Terms of Service) between you and us.
If you are a California resident, please be aware that under the California Consumer Privacy Act of 2018, as amended (“CCPA”), you are entitled to receive specific information on how we process your data. You also have specific rights to your data, including the right to opt out of the sale of your personal information. To review this specific information and familiarize yourself with your rights under the CCPA, please review our Supplemental Privacy Disclosure for California Residents.
Under our Terms of Service, you represent that you are at least 13 years of age. However, we do not know the specific age of individual users of our Services, even where we employ an age gate (we ask for your birthday solely to determine if you are over or under an applicable age). If you are under 13 years of age, please do not provide your personal data (including your name, address, telephone number, or email address) to us or use the Services to make your personal data available to others. If we discover that we unintentionally hold personal data relating to a user under 13 years of age, we will take appropriate measures to ensure that we process that data according to the requirements of applicable laws and regulations or promptly delete the data from our records. If you have reason to believe we hold personal data relating to a user under 13 years of age, please contact us.
This Policy may be provided as a courtesy in multiple languages, however, the English language version of this Policy shall control in the event of any ambiguity between the English version and a version provided in another language.
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.