1. Data controllerBy “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.
2. Contact informationIn 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.
3.Why do we process your data and on what basis?
3.1. Legal basisWhen 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:
- create and maintain an account for you in our Games or other Services where applicable,
- enable you to play our Games or use our other Services,
- provide the correct version of our Games or other Services to you (for example, selecting an appropriate language version for you),
- where available, enable you to communicate with other users in our Games or other Services (for example, by providing chat, forums, or other similar features),
- send you service-related communications (for example, technical notices, security alerts, or administrative messages), or
- verify your purchases or other transactions in our Games or other Services.
- operate and maintain our Services (for example, by making sure our Services are secure and function as intended),
- troubleshoot or debug any bugs, errors, or other issues in our Services,
- measure and analyze the use of our Services or data we collect through our Services (for example, to discover trends or other insights or to inform our operations),
- create data that is not identifiable to you (for example, aggregate data), which we may then use and share freely,
- conduct surveys or other research to learn more about our users, or
- improve our current Services or develop new Services.
- personalize your gameplay experience in our Games based on your activity in those Games,
- provide you with offers and rewards in our Games based on your activity in those Games,
- where available, enable you to save and synch your gameplay across multiple devices (for example, by giving you the option to connect a third-party account with our Games for that purpose),
- where available, provide social features (for example, clans, matchmaking, or leaderboards) or events in our Games or other Services, or
- handle your support requests or otherwise manage our relationship with you.
- moderate and monitor the use of our Games or other Services (including any messages sent through the Services), either automatically or manually, or
- ensure that our Terms of Service are followed.
- keep track of installations of our Games (including the source of each install),
- measure, analyze, and improve the effectiveness of our advertising (including our advertising outside of our Services), or
- send you communications about offers, rewards, events, or other news related to our Services or other operations.
- detect, investigate, or prevent fraud or fraudulent or otherwise unauthorized behavior,
- audit our operations or processes (for example, to verify that they function as intended and according to regulatory or contractual requirements), or
- establish, exercise, or defend our legal rights to the extent permitted by applicable laws and regulations.
- to send you newsletters or other similar communications if you have subscribed to them (for example, through a subscription form on our Websites or link in our Games),
- request our advertising partners to show or not show our ads to you based on your activity (including by limiting the number of times you see our ads),
- request our advertising partners to advertise our Games or other Services to audiences who they believe have interests similar to yours,
- keep track of your activity in our Games to learn about your interests and improve the advertising in our Games, or
- personalize, or ask our advertising partners to personalize, the ads you see in our Games to make them more relevant to you, or
- for other purposes explained to you when we ask for your consent .
- comply with legal obligations which we believe apply to us (including accounting and tax requirements and requirements to provide information to competent authorities upon due request), or
- protect your vital interests or the vital interests of another person.
3.2. AdvertisingAdvertising 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:
- limit the number of times you see our ads,
- inform users who have previously played our Games about new content, updates, or other news related to those Games, or
- refrain from showing our ads to users who already play the Game being advertised.
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.
4. What Data Do We Process?We may process the following data relating to you:
- your name, email address, or other contact information if you have provided them to us (for example, when registering an account or subscribing to our communications),
- online identifiers such as your in-game alias, IP address, internal identifiers we assign to your account, or hardware or operating system based identifiers including your Advertising ID or device ID,
- technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory),
- your coarse location (for example, country, state, or city), inferred from your IP address,
- information about your use of the Services (for example, information about your progress in our Games, your visits to our Websites, or your interactions with ads in our Games),
- information about your interactions with our ads outside of them Services (for example, on third-party websites or applications), including information on how you were referred to our Games or other Services,
- crash logs or other information related to bugs, errors, or other issues in our Services,
- inferences we make based on your activity in our Services,
- messages or other communications you send to us or through the Services (for example, your chat messages in our Games or emails you send to our support team),
- if you choose to connect a third-party account (for example, a social media account) with our Services, information we receive from the third-party account provider (for example, an account name, identifier, or email address to enable cross-device gameplay or a profile name, picture, or friends information to provide social features),
- if you make purchases in our Games, information we receive from third-party payment service providers to validate those purchases,
- if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so (for example, information about your background or experience with our Games),
- any other information you choose to submit to us through our Services or otherwise, and
- with your consent, other information explained to you when asking for your consent.
5. Where Do We Collect Your Data From?We may collect data relating to you from the following sources:
- directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support enquiries to us, or responding to our surveys),
- directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services (for example, on third-party websites or applications), including through cookies or similar technologies or software development kits (SDKs),
- if you interact with ads in our Games or our ads outside of our Services (for example, on third-party websites or applications), from our advertising partners involved in the delivery and measurement of those ads,
- if you choose to connect a third-party account (for example, a social media account) with our Services, from the third-party account provider,
- if you make purchases in our Services, from the third-party payment service provider involved in those transactions, or
- with your consent, from other sources explained to you when asking for your consent.
6. Who Do We Share Your Data With?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:
- other companies in the Tilting Point group (which includes our parents and subsidiaries) or our Game or Services related affiliates, for example where they help us develop or operate our Games or other 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);
- other partners we work with while providing the Services (who may process your data independently of us), including advertising partners, IP licensors, and others listed here;
- 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 we believe 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
- with any other person or entity with your consent.
7. How Long Do We Keep Your Data?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).
8. How Do We Keep Your Data Secure?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.
9. Your RightsFor users located in the European Union (“EU”) and the European Economic Area (“EEA”), if we are processing your data, you have the right to:
- access, correct, or request the deletion of your data,
- request us to restrict our processing of your data,
- object to our processing of your data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
- where technically feasible, request a copy in machine-readable format of the personal data we have collected from you pursuant to this Policy.