Privacy Policy
Last updated: 25 May 2024
This Privacy Policy explains how your personal data is collected and processed by TO-TO GAMES LTD ("To-To Games") when you use the our mobile applications (the "App").
The App is a free to play game (with optional in-game-purchases), and in order to maintain the high quality and a great game experience we process information from and about you in particular to improve the entire experience in the App and to support internal operations.
We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent.
Storage of information
To-To Games does not store your personal data.
Sharing of information
If you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your Device identifiers to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the following advertising network companies:
In connection with our processing, we use following data processors such as:
- Analytics service providers:
The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.
Collection of information
Information we collect automatically through the app
When you access or use the App, we automatically collect general information about you, including:
- Log Information: We log information about your use of the App, including the type of device you use, the features you use, access times and IP Address.
- Device Information: We collect information about the device you use to access the App, including information about the device manufacture, device model, device's OS, language of device.
- Device identifiers: We collect online identifiers of the device you use to access the App, including IDFA.
- Usage Information: We collect information relating to your use of the App, including your game progress, scores, achievements.
- Consumption information: We collect information about your consumption habits relating to your use of the App, including which purchases you make and the reception of virtual goods in-game.
Use of information – purpose and legal basis
We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below:
- Log-, device-, usage-, and consumption information and device identifiers are being processed:
- to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you;
- to provide and maintain the App and the game experience; and
- to send you technical notices, updates, security alerts, and support and administrative messages;
Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR. - to provide news and information about the App that we think will be of interest to you;
- to personalize and improve the App and provide tailored content and features;
- to monitor and analyze trends, usage and activities in connection with the App;
Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule"). - to provide users that have given us consent to share their advertising IDs with our ad network partners (as further specified under “Sharing of Information”) for the purpose of serving them with personalized advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information).
- Information from other sources are being processed:
- to provide and deliver the products and services you request and send you related information;
Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR. - to link or combine information we get from others to help understand your needs and provide you with better service; and
- to provide news and information about the App we think will be of interest to you;
Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule").
We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.
Children
Use of the App is limited to users aged 13 years and above, except in European Economic Area, where the App is limited to users aged 16 years and above. If you are accepting this Privacy Policy and using the App, you warrant you are 13 (or 16, depends what is applicable) or more years old.
Security
To-To Games takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Does To-To Games actually "sell" personal data?
To-To Games does not, and will not, provide your personal data in direct exchange for money. Therefore, in the literal sense, To-To Games does not sell your data. However, we have disclosed some categories of personal data we collect, explained under ”Sharing of information“, to third parties for business purpose as explained under “Use of information – purpose and legal basis”.
Contact
TO-TO GAMES LTD
Address: 3rd Floor Suite 207 Regent Street, W1B 3HH London, United Kingdom
E-mail: support@to-to.games