PRIVACY POLICY FOR GAMES
Updated October 21, 2024
ABOUT US AND THIS PRIVACY POLICY
Your privacy is very important to us, and we will always use your personal information only for the purposes as described in this Privacy Policy for Games (the "Privacy Policy"). This Privacy Policy sets out the privacy practices Outfit7 Limited and its subsidiaries (referred to as "Outfit7", "we", "us" or "our", "ours") follow in the "Outfit7" branded software applications (the "Game/s"), which may operate on any type of computing device, and applies to your interaction with the Game(s), and is a part of, and incorporated by reference, into the End User License Agreement ("EULA"). EULA is available at https://talkingtomandfriends.com/eula/. Additional information is available for players who come from certain regions:
- for EEA, UK and Switzerland, click here,
- for the US (including California), click here,
- for Brazil, click here.
You can always determine your country of residence in the app settings by clicking a "Country" button and selecting your country.
INFORMATION WE COLLECT FROM YOU
Most of the information that we collect about you comes from you or your device when you play our Games, interact with third-party ads in our Games, or interact with our ads in apps or websites of others. Other than that, we may receive your information when you contact us directly via email. Some data is provided directly by you, whereas other data is collected automatically.
We follow the data minimization standards when collecting information, meaning that we'll only collect information necessary for a certain purpose and not reuse it for a different, undisclosed purpose.
Information you provide directly
If you decide to contact us directly via email, we will use your data solely to respond to your inquiry. You may also be asked to participate in a survey or testing of our Games - which is all voluntary; please read more about this in the section Participation in the testing and surveys. Other than in these cases, we do not collect any "traditional" personal information through our Games (such as your name or email address, with which you could be personally identified directly).
If you are in any way engaging with User Generated Content, note that no information is collected from you from the Game; please read more information about this in our Social Media Engagement Policy, accessible at https://talkingtomandfriends.com/social-policy.
For some of our Games we collect information about the nickname you choose or information about the name you give to your virtual pet and your rating of the Game (if any). Please do not use your real name. Please note that if you are a Child (as defined below) your nickname is only shown to you and not to any other players in order to provide an additional layer of safety.
Information collected automatically
The information we automatically collect about you relates to the type of device you are using, information that helps us identify your device, how you play our Games, how you interact with our ads, and third-party ads. This includes your approximate geolocation and online identifiers, which do not identify you personally but may uniquely identify your device, and other device data. We may also collect information from app store platforms, partners and other third parties, such as information about your interests and in-app purchases (but we never receive your payment or credit card information).
We also ask you to submit, and we may process, other non-personally identifiable information that may be personal to you - like your year of birth.
HOW WE USE AND SHARE YOUR INFORMATION
We use and share your information to provide you with Games and to run a successful operation. As described in greater detail below, we may share your information (including personal data) with our subsidiaries and with other companies and use it for the purposes as described below.
Providing You with Games and Support
We use the information we collect about you/your device to provide Games to you and to operate our business. Your information is used to develop, deliver and improve our Games and video content, to provide Game updates, and fix any bugs and crashes that may occur.
We use your information to provide timely and accurate customer support to you and to respond to your inquiries. In case we are contacted by Children, we will delete all the communication, including any personal information included, after a one-time response.
To learn more about who your data is shared with, please expand this section.
Analytics and Research
We use your information to understand and analyze trends in connection with the usage of our Games, gather demographic information about our user base, and data about where the Game was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence. We also analyze how you play our Games - how often and for how long you play, how you progress through the Game and which events occur in the game. We also use your information to improve Games and to enhance security.
To learn more about who your data is shared with, please expand this section.
Advertising
We offer our Games for free or at low cost, which is possible because of the advertisements we show in the Games. When playing our Games, information from your device is collected and used by us and other companies so that ads may be delivered and displayed to you. Information may be logged from your device using different technologies, such as Software Developer Kits (SDKs) or web beacons, to ensure that appropriate advertising is presented within the Game and to calculate the number of ads shown to you and how you interact with them.
You can read more about the types of advertisements we show in the Games and which of your information is used for each type below.
Please read more about interest-based advertising practices and the choices you have in regards to them in the Interest-based Ads Notices link currently available at talkingtomandfriends.com/privacy-general/iba-notices. We never allow advertising providers to show interest-based (personalised) ads to Children (as defined below).
To learn more about who your data is shared with, please expand this section.
Advertisement of our Games
When you use other apps or other online services, you may see ads for our Games in them. When you use these other online services, you are subject to the terms and privacy practices of the online service provider you are using at the time.
Information from your device is used to attribute performance of our advertising campaigns, to assess and measure their success, and to identify and prevent any fraud. We also use certain information from your device to not show you repetitive advertisements or ads for those of our Games which you have already installed. In addition, information on how you play our Games and how you interact with the ads may also be used and shared with advertising providers to optimize our advertising campaigns and to show our ads to the audience that may be more interested in our Games. If you would like to know more about the choices you have regarding the sharing of your information for these purposes, read our Interest-based Ads Notices available at talkingtomandfriends.com/privacy-general/iba-notices.
Information from your device may be logged using SDKs, cookies, web beacons and other technologies. These technologies enable us or other companies we've partnered with to check how you interact with ads and attribute views, impressions, clicks, installs or other performance indicators.
We check data like impressions, downloads and traffic sources to see how many times people viewed or downloaded our Games from the app stores. The device data used and shared with providers for this purpose are encoded. The providers assign a random ID to this data and they are not able to match it back to you personally. We also aggregate this data for benchmarking.
To learn more about who your data is shared with, please expand this section.
Cross promotion of our Games
We use some of the information we automatically collect from you (read more about the collection of information in the section Information Collected Automatically of this Privacy Policy) for cross promoting our Games, which means we promote one of our Games while you are playing a different Game of ours.
Game Notifications
We use game notifications to remind you about your activities within the Game. We have two types of notifications in our Games - local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server.
If you decide to receive push notifications, we get your push notification token so we know we can send them to you. To read more about how you can unsubscribe from receiving push notifications at any time, find the instructions by expanding this section.
Participation in the testing and surveys
We are conducting surveys to improve our Games or customer support service. If any of your personal data may be processed for these purposes and if your local legislation requires consent as the legal basis for the processing of information obtained in the course of the survey, we will always ask for your consent before conducting a survey.
From time to time, we, or our partners, may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. We will use the information to create a better user experience. Collected information shall be anonymized and aggregated.
Participating in any survey is completely voluntary.
In some territories we may invite you to participate in the testing of our Games. You may voluntarily decide to apply. If you do so, you will be directed out of the app to an online survey, where we will ask for your consent for the processing of any personal information we might need to be able to invite you to the testing of our Games. You can read more about our privacy practices in relation to the testing of our Games in the Privacy Policy for User Testing, which is currently available at https://outfit7.com/user-testing-privacy-policy.
App stores' game centers
Some of our Games enable you to connect to app stores' game centers, such as Google Play Games Service or Apple Game Center, where you may be able to participate in leaderboards. Gaming centers are governed by their own privacy policies, terms and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of such centers that operate those sites.
Security and Legal Obligation
We use your information to enhance the safety and security of our Games, and where we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our users, user experience, or our operations. We use your information when we are required to do so by law and in order to comply with any legal requirements. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant successor.
In-App Purchases
Our Games enable in-app purchases. Payment transactions for in-app purchases are completed through the app store via your app store account. We do not process payments for in-app purchases, nor do we have access to your credit card information. Read more details about in-app purchases and refunds in our EULA, available here: https://talkingtomandfriends.com/eula/en.
CHILDREN'S PRIVACY
We consider ourselves to be family oriented and we take the privacy and safety of players below the age limit as required by the applicable data protection legislation ("Children/Child") under special consideration, hence we implemented higher protection standards to ensure this. Even though our products and services are not primarily directed to, and we do not knowingly collect personal information from Children, with the sole exception of online identifiers, we have decided to voluntarily implement higher child protection standards, as described in this section.
If we learn that we have collected personal information, other than online identifier, of Children, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your Child has provided us with personal information without your consent, please contact us at privacy@outfit7.com.
To preserve the family-friendly reputation of our Games, we age-gated some of the features in some of our Games, so that they are not available for use by Children.
To read more details about how the information is used and shared in general, please see the section How we use and share your information of this Privacy Policy. For details about which companies we share information from Children, click here.
Kids Privacy Assured Program
We voluntarily participate in kids privacy assured programs, which means our Games are inspected and certified by an independent third-party organization as being compliant with applicable privacy practices.
SPECIAL FEATURES IN SOME OF OUR GAMES
In some of our Games there is an option for the virtual character to repeat back what you said to it. Before doing so, you will always be asked to give permission to access the microphone. Please note that none of our Games have the option to record audio - you can learn more below.
In the US, some of our Games offer you the option to connect your device to an entertainment device, i.e. a talking, animatronic streamer GameBud™ Talking Tom® (the "Entertainment Device"). To read more about this, please expand this section.
THIRD-PARTY TERMS AND CONDITIONS
Our Games may contain links to third-party websites, products, or services. For example, the Games may feature offers from third-party advertisers or the ability to engage in transactions with such entities. Please note that while using such third-party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third-party's privacy or information security policies and practices, or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.
TRANSFER, SECURITY AND RETENTION OF INFORMATION
Security of your personal information
We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best commercially reasonable efforts to assure that your information remains secure when maintained by us, no security measures are perfect or impenetrable.
How long your information is stored for
We store your information for as long as needed to provide you with our Games. We may store information longer, but only in an aggregated and anonymized form - this means the information cannot be linked to you or your device. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all our Games has ceased.
When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data, we will delete your data as described below in the "Your Rights" section of the territory-specific privacy section of this Privacy Policy.
International transfer
We operate globally, so we may need to transfer your personal data to our affiliated entities and/or to other third-party service providers across borders and from your territory to other territories around the world. Please note that not all these territories may have the same data protection laws as your own territory, but we will always take reasonable steps to safeguard the privacy and protection of your personal data.
Certain territories have safeguards in place which set out the rules on how the personal data from such places may be transferred to other territories. Please read more about such safeguards in the territory specific sections of this Privacy Policy below.
YOUR RIGHTS
You have certain rights in connection with your personal information and how we handle it. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to privacy@outfit7.com.
To read more details about what your rights include, please expand this section.
CHANGES TO OUR PRIVACY POLICY
We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. We may also contract with additional companies or change existing service providers to perform any services in connection with the Games. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices. The most current version of the Privacy Policy will govern our use of your information and will be available at talkingtomandfriends.com/privacy-policy-games.
For previous versions of this Privacy Policy, please contact us at privacy@outfit7.com.
CONTACT US
You can always reach out to us using the following means:
- for questions or concerns about Outfit7's Privacy Policy, information processing, privacy questions, exercising your rights, or filing a complaint directly with us, please contact: privacy@outfit7.com;
- for general information please feel free to contact us via our customer service page: https://talkingtomandfriends.com/support.
Please also see other means of contacting us in the territory specific sections of this Privacy Policy.
EEA, SWITZERLAND AND THE UK ("EUROPE") SECTION
US STATES PRIVACY SECTION
BRAZIL PRIVACY SECTION
OUTFIT7 GLOBAL PRIVACY POLICY FOR GAMES, updated October 21, 2024
