Children-friendly privacy policy for games
Introduction
Who are we?
We’re Outfit7 – we make the games you’ve been enjoying!
In this document – it’s called a Privacy Policy – we might talk about ourselves in a couple of different ways:
We
Us
Our
Ours
When we do that, we mean Outfit7 Limited – which also includes other companies in the same family of companies.
Who are you?
You’re someone who plays our games and is viewed as a child in your country!
Outfit7 Limited, a company registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London EC3M 6BN, United Kingdom, with a business address at Christaki Kranou 20, 2nd Floor, 4041 Limassol, Cyprus. Contact us: privacy@outfit7.com
Word of the day
“Subsidiary”
A subsidiary is a company that’s owned by a parent company.
So Outfit7 is a parent company – and we have subsidiary companies (or “subsidiaries”).
Who are you?
You’re someone who plays our games and is viewed as a child in your country!
WHAT’S A PRIVACY POLICY?
When you play one of our games, we get some of your information – including personal information.
Basically, a Privacy Policy is an explanation of how we will use your personal information.
But first…
WHAT’S PERSONAL INFORMATION?
Let’s Find Out!
Important things about you
There are some bits of information about you that are really important.
- Your name
- Your email or phone number
This is called classical personal information. It’s information that lets people know who you are – and everyone should protect this information about themselves.
Imagine you’re a superhero… Like Super Tom! Your classical personal information is like your secret identity. For your own protection, you want to keep it secret and only share it with the people you really trust.
You can play our games without giving us this information.
We want you to keep your secret identity safe!
So when you play games and you’re thinking about using an in-game nickname, or you want to give your virtual pet a name – do not use your own name.
YOUR SECRET IDENTITY!
Imagine you’re a superhero… Like Super Tom! Your classical personal information is like your secret identity. For your own protection, you want to keep it secret and only share it with the people you really trust.
You can play our games without giving us this information.
We want you to keep your secret identity safe!
So when you play games and you’re thinking about using an in-game nickname, or you want to give your virtual pet a name – do not use your own name.
INFORMATION ABOUT YOUR DEVICE
Just like there’s information about you, there’s information about your device.
Some information about your device also counts as personal information.
Personal information is information that relates to YOU as described above, but it can also be information that can be used to identify YOUR DEVICE, such as IP address and some device identifiers.
INFORMATION THAT GETS COLLECTED
How does you information get collected?
You provide some information directly
If you want to talk to us directly, you may send us an email or contact us through in-app support. If you decide to write an email to us, your name and email address will be shared with us but they will only be used to reply to you. Once we have replied to you, we will delete your name and email address. Our customer support partner also gets your name and email address. After we use it to reply to you, we both delete your personal information immediately.
Before you get in touch with us, speak to your parent or legal guardian first to ask permission.
When you contact us via email
- Name
- Email address
Some information gets collected automatically
There are a couple of ways how this happens:
- When you play our games
- When you see or click on an ad in our games
- When you see or click on one of our ads in someone else’s games
Device
- What kind of device you’ve got
- IP address
- Device identifiers
- Whether you’re connected to the internet and how you're connected
- Other device data
Game
- How long you play for
- Whether you have any of our other games
This is technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, API key).
Including: user agent string (UA), platform, SDK version, timestamp, and browser plugin types and versions.
Map
- The country you’re in
- The language spoken where you are
- The time zone where you are
A FEW MORE THINGS
We also create a special code name for you – called a unique user ID – which helps us know that it’s you. A unique user ID is needed so you can play the games and so we can see which features of the games you really like and which ones you don’t enjoy. We also use a unique user ID so we can restore your progress for you, in case you change your mobile phone or accidentally delete the game.
By the way:
If you have an older version of one of our games, it may still collect a couple other things – a Unique Device ID and an International Mobile Equipment Identity number.
Don’t want these collected? Just update the app and it’ll stop! Easy.
PHRASES OF THE DAY
“IP Address”
A special string of numbers – a kind of label – that can identify devices on a computer network.
For example, we use your IP address to determine which country you’re located in so we can show you games in your language.
”Device Identifiers”
Unique pieces of information that refer to a digital object. They include things like:
- Device ID
- IDFA
- IDFV
- Advertising ID
They don’t link to one specific person – like you – but they could, over time, help identify you as a user, or your device.
A FEW MORE THINGS
We also create a special code name for you – called a unique user ID – which helps us know that it’s you. A unique user ID is needed so you can play the games and so we can see which features of the games you really like and which ones you don’t enjoy. We also use a unique user ID so we can restore your progress for you, in case you change your mobile phone or accidentally delete the game.
By the way:
If you have an older version of one of our games, it may still collect a couple other things – a Unique Device ID and an International Mobile Equipment Identity number.
Don’t want these collected? Just update the app and it’ll stop! Easy.
THE BIG PICTURE
Why information is collected
WHY DO WE COLLECT INFORMATION?
Information we get from you helps us keep our games working – and make them even more fun!
It helps us:
- Develop and improve our apps and other products
- Show you ads in our apps
- Show you other apps we have
- See how ads are working and make sure they are shown to you from our partners
- Understand how you play our apps
- Keep our games safe and secure
- Answer your questions and help other players when they have questions
- Obey the law
Develop and improve our apps and other products
We use information to make our products, deliver updates, fix problems, and keep our apps working.
Show you ads in our apps
To show ads for things you might like, based on the content you are watching or the game you are playing. These ads do not track you or build a picture of you or your habits.
Show you other apps we have
To show you some of our other games that you might want to play.
Understand how you play our apps
To understand how often you play the app, for how long you use the app, the events that occur within the app, in-app progress, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc ,and to help us see where problems are.
HOW WE SHARE YOUR INFORMATION
There’s no “I” in “team”!
WHO SEES YOUR INFORMATION?
We can’t do everything ourselves. To make games that are fun and work well, we work with other companies. They are our partners. They help us with different tasks, like running our apps and showing ads, for example. You can find out more about who our partners are by clicking here.
Working together is important. We’re all better together.
When we work together, we share information. That way, everyone has everything they need to do their jobs.
We share information with our partners that can personally identify your mobile phone or tablet. But we don’t give them important information about you. They can’t identify you personally.
If you have any questions, please ask your parent or guardian to contact us on: privacy@outfit7.com
WHAT DO OUR PARTNERS KNOW?
They know the information is about someone, but our partners don’t know it’s about you.
Remember we talked about you being a superhero like Super Tom? When he’s on a mission, the world sees a superhero called Super Tom. Only the people he trusts the most know that his real name is Talking Tom.
So when we share information with our partners, we keep your secret identity SECRET!
WHO MIGHT WE SHARE INFORMATION WITH?
Information is shared with our partners and they are not allowed to use your data for any other purpose than the purposes described here. If you want to find out more about our partners, speak to your parent or legal guardian and then get in touch with us via our email address: privacy@outfit7.com.
OTHER SITUATIONS WE MIGHT SHARE INFORMATION
- If we start working with new partners. We’ll let you know when that happens by updating this Privacy Policy (a couple of times a year).
- If we’re asked to do so in connection with a legal issue. That means someone from the law or government has asked us to do so. We all have to follow the rules.
- If we need to follow through on our Terms and Conditions, or protect our operations, our users (like you!), or the user experience.
- We may have to share information with another company, if a new company buys us, for example.
If you have any questions, ask your parent or guardian to contact us on: privacy@outfit7.com.
WHAT ELSE HAPPENS IN OUR GAMES?
Ads, notifications, talkback features, and in-app purchases
ADVERTISEMENTS
We want to share the fun of our games with as many people as possible. That’s why they’re free to play!
Part of how we’re able to do that is by showing advertisements.
What are they?
Sometimes, when you’re playing a game, a pop-up or a banner labelled as an “AD” appears on the screen. This is an advertisement. Advertisements appear in different shapes and sizes.
Word of the day
“Advertisement”
An advertisement – also known as an “advert” or an “ad” for short – is a type of communication that positively shows you a product, service, or person.
INFORMATION FROM ADS
From ads, we get information that lets us know a few useful things:
- Which ads you’ve seen
- How long the ad is shown
- How you interact with it (e.g. do you click on it?) - this is for our ads shown in other apps and the ads shown in our apps
Word of the day
“Advertisement”
An advertisement – also known as an “advert” or an “ad” for short – is a type of communication that positively shows you a product, service, or person.
SHARING AD INFORMATION WITH OUR PARTNERS
In order to show you ads, we share some information with our partners.
As we said before, sharing and collecting information helps us all do our jobs properly. In some territories, some partners might collect something called an advertising identifier. They’ll only use this to show you contextual ads and to check if the ad was shown to you and how you interacted with it. But don’t worry, they aren’t allowed to track you across the internet or build a picture of your habits.
Your secret identity stays safe!
WORD OF THE DAY
“Contextual Ads”
Ads that are shown to you based on the content you’re engaging with at that moment.
Example: When you play My Talking Tom, we will show you ads for similar games.
GAME NOTIFICATIONS
Sometimes you might see little messages pop up on your device. These are called notifications, and they are sent directly from your device.
THE “TALKBACK” FEATURE
Did you know that you can talk to the Talking Tom & Friends characters in some of our games? They’ll even repeat back what you say in a funny voice!
Don’t worry, the game can’t record anything you say – we don’t have your voice recordings. Everything happens on your device.
This feature uses the microphone on your mobile phone or tablet, so we’ll always ask you if this is okay first. If it’s not, that’s fine! It will just mean that this feature doesn’t work.
REMEMBER!
Some of our games let you play in multiplayer mode and connect with other players. To help keep your identity secret, we will pick a name for you if needed.
IN-APP PURCHASES
Sometimes there are special things you can buy in our games. These are called in-app purchases.
When you buy something, it’s between you and the app store on your mobile phone or tablet. We’re not involved in taking the payment from you and we do not see your payment information.
It’s like when you go into a real store – you pay the shop, you don’t pay the toys and game makers
For more information, please read the In-App Purchases Section of the End User License Agreement, which is available here: https://outfit7.com/eula/.
IMPORTANT INFORMATION FOR USERS AT OR ABOVE THE AGE OF CONSENT
This section only applies to you only if you are at or above the age of consent.
WHAT DOES IT MEAN TO BE AT OR ABOVE THE AGE OF CONSENT?
Your county has laws that deal with the protection of personal information. And these laws allow children who reach a certain age to make their own decisions about their personal information. If you have reached such an age, then this section applies to you.
This helps our partners understand how you interact with interest-based ads. They use this information to provide you with personalized ads in the future.
This allows our partners to provide their advertisers with more detailed information about who saw or interacted with their ads, and help build audiences for other advertisers.
INTEREST-BASED ADS
If you are above the age of consent set by the law that deals with the protection of personal information in your country, we may ask you if we can share your personal information with our partners, so they can show interest-based ads to you, measure the performance of such ads and help us and them understand our audience
We will share your information for these reasons, only if you give your consent to do so.
Word of the day
“Interest-Based Ads”
These ads are not random – they’re shown to you based on your age, gender, behavior, interests you have, or things you like. They are also called “personalized ads” or “targeted ads”.
These ads can track you, or build a picture of you or your habits.
Example: You play one of our games and give us permission to share your information. We share your advertising ID with one of our partners – and with it, they know that your device has clicked on a sports ad in a game before. So they will show you a sports ad in our game because they think you will like it.
WHAT INFORMATION WILL BE SHARED?
We will not share your email, name, or address with our partners. We will only share information that can personally identify your phone or tablet, such as advertising ID, and IP address (we talked about these here). We may also share other information that may be personal to you, like your age. Our advertising partners can use this information for interest-based ads.
WHO CAN SHOW INTEREST-BASED ADS TO ME?
You can check who can show interest-based ads to you and find out more about how such providers can use your information by clicking here.
IMPORTANT
You can choose who you allow us to share your information with. We will ask for your consent in the game – and when we do, you have the option to choose the providers that you like and trust.
Can I change my mind?
Yes! You can change your mind at any time. Go to "Settings" in the app and click on the "Interest-Based Ads" button and then on the “Manage consent/opt-out” button. Depending on your country, a new screen will open up: for the European Economic Area and Brazil: a pop-up with a list of providers. You can then deselect some of the providers, or hit “Deselect All” to opt-out from interest-based ads. For the US and rest of the world: a screen will open up where you’ll be able to opt-out of interest-based ads.
YOU HAVE A CHOICE
Make sure you understand how your personal information may be shared for the purposes described above before you make any decisions regarding this. If you don't understand this section, speak to your parent or legal guardian. Together, you can learn more detailed information here.
REMEMBER
When you change your mind, or if you do not provide your consent or if you decide to opt-out of sharing of personal information, you may still see the same number of ads on your phone or tablet. The difference is that these ads may be less of interest to you because they won’t be based on things you like, your age, etc. Our partners may also continue to show you ads based on the content of the game you’re playing.
WHAT ELSE CAN YOU SEE AND DO?
Some of our games let you to interact or compete with other players. We will ask you to pick a name that other players will be able to see. Please do not choose your real name. You can always change your name by going to 'Settings' and selecting the 'Change Name' or 'Edit' button.
RULES AND MORE
Rights, rules, legal bases, and security
YOU HAVE RIGHTS REGARDING YOUR PERSONAL INFORMATION
You have rights when it comes to your personal information (information about you) and you can act on these rights. We’re going to talk about some of these rights now.
YOUR RIGHTS
- The right to object
- The right of access
- The right to correct personal information
- The right to deletion
- The right to complain
- The right to restrict
- The right to move your information (data portability)
- For residents of California: Right to opt-out of the sale or sharing of your personal information
The right to object
If you don’t like how we’re handling your information, you can delete our games to prevent any further collection of information. It’s as easy as that!
The right of access
You’re allowed to know what information we have about you, so you can ask us!
The right to correct personal information
If you think your information isn’t correct, let us know and we’ll fix it.
The right to deletion
If you don’t want us to have your information, you can ask us to delete it. It’s only fair - it’s your information! However, in order to check if it’s really you, we may need to ask you for some additional information. But we may need to keep some of your information because of legal rules. And we might also keep bits of anonymous data.
The right to complain
Are you unhappy with how your personal information has been handled? You can make your voice heard. You can speak to the authorities in the country where you live.
The right to restrict
Sometimes you can ask to put limits on how we use your information.
The right to move your information (data portability)
You can ask us to give back your information so you can give it to another company.
For residents of California: Right to opt-out of the sale or sharing of your personal information
If you don't want your personal information to be shared with our partners so they can: show interest-based ads to you; measure the performance of such ads; and help us and them understand our audience, you can opt-out in the game Settings. Read more about this here.
ACTING ON YOUR RIGHTS
To make one of these requests or to ask us a question about your rights, speak to your parent or legal guardian and then get in touch with us via our email address: privacy@outfit7.com.
There are a few things to remember about requests like these:
1) To be safe, we’ll need to make sure you are you. Why? Because privacy is important. And we don’t want to let someone else know your secret identity.
2) It could take about a month for us to deal with requests like those above. And, at the end of the process, if we can’t do what you asked, we will let you know why. Honesty is important.
STICKING WITH THE RULES
Following the rules is important
To help us with following the EEA and UK data protection legislation we have a “Data Protection Officer” (ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg), as well as a UK representative (PRIVO Verified Limited, Room 3, 168 South Street, Dorking, Surrey RH4 2ES, United Kingdom), who both help us with following the legislations
By the way: When you play our games, we estimate the country where you are located, but you can always change your country via the app settings (by clicking and choosing the right place using the “Country” button) on your device. But you don’t have to.
Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™
Outfit7 is a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPA Safe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online.
COPPA Safe Harbor Certification
The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification Seal. The certification Seal posted on this page indicates Outfit7 has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +1 (256) 203-9712 or privacy@outfit7.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.
GDPRkids™ Privacy Assured
The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids™ Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company's services meet the program requirements, we conduct regular monitoring and consulting.
The right to object
If you don’t like how we’re handling your information, you can delete our games to prevent any further collection of information. It’s as easy as that!
The right of access
You’re allowed to know what information we have about you, so you can ask us!
The right to correct personal information
If you think your information isn’t correct, let us know and we’ll fix it.
The right to deletion
If you don’t want us to have your information, you can ask us to delete it. It’s only fair - it’s your information! However, in order to check if it’s really you, we may need to ask you for some additional information. But we may need to keep some of your information because of legal rules. And we might also keep bits of anonymous data.
The right to complain
Are you unhappy with how your personal information has been handled? You can make your voice heard. You can speak to the authorities in the country where you live.
The right to restrict
Sometimes you can ask to put limits on how we use your information.
The right to move your information (data portability)
You can ask us to give back your information so you can give it to another company.
For residents of California: Right to opt-out of the sale or sharing of your personal information
If you don't want your personal information to be shared with our partners so they can: show interest-based ads to you; measure the performance of such ads; and help us and them understand our audience, you can opt-out in the game Settings. Read more about this here.
BEYOND THE COUNTRY YOU LIVE IN
You can read more about special measures we have in place (in line with the laws that apply in certain country) to keep you and your personal information protected together with your parent or guardian in our Privacy Policy: https://talkingtomandfriends.com/privacy-policy-games/en.
- It might go to a country that has rules that are as strong as those in the EEA or the UK.
- It might go to one of our partners outside the EEA or the UK, but we have a special contract in place – a set of rules – to protect your privacy. Or they might have a special certificate that says they respect the same rules as we do. You can find more information on our website: https://outfit7.com/privacy/en.
LEGAL BASES
Some laws (eg. the laws of the European Economic Area) require us to have an appropriate reason to collect your information.
- Legitimate interests
- Consent
- Legal obligations
Legitimate interests
This is information that we use to give you the best experience playing our games. It helps us improve our games, to respond to you when you write to us, and to make sure that our games stay free-to-play (or at least low cost). We also use it to make sure that your information stays secure and that nothing we do gets in the way of your rights.
Consent
When we need something from you, like some particular information, we’ll ask you first. You can say no and ask us to stop, and we will. If you want us to delete what we already have, you’ll need to ask for this separately.
Legal obligations
This is about information that we have to keep to make sure we obey the rules.
T.O.M.s
We’ve done our very best to make sure that your information is safe.
This means we’ve worked hard to put technical and organizational measures in place. We call these... T.O.M.s!
But even the best measures aren’t perfect.
HOLDING ONTO INFORMATION
We’ll hold onto the information we’ve collected for as long as you want to play our games.
If we keep it for a bit longer, don’t worry – it won’t be about you specifically. It’ll be anonymous.
We’ll get rid of it as soon as we don’t need it. Or if you haven’t played one of our games for around five years.
But you can ask us to delete it sooner if you like!
Keep in mind that we may also have to store your information for a longer period if we have to do so in order to obey the law.
Legitimate interests
This is information that we use to give you the best experience playing our games. It helps us improve our games, to respond to you when you write to us, and to make sure that our games stay free-to-play (or at least low cost). We also use it to make sure that your information stays secure and that nothing we do gets in the way of your rights.
Consent
When we need something from you, like some particular information, we’ll ask you first. You can say no and ask us to stop, and we will. If you want us to delete what we already have, you’ll need to ask for this separately.
Legal obligations
This is about information that we have to keep to make sure we obey the rules.
FINAL THOUGHTS
CHANGES TO OUR PRIVACY POLICY
Change happens!
Sometimes things in our Privacy Policy might change.
If you have questions about that, please talk to your parent or guardian. Together, you can see our current Privacy Policy here: https://talkingtomandfriends.com/privacy-policy-games/en.
And if you want to see old versions of the Privacy Policy, you can email us: privacy@outfit7.com
CONTACT US
If you think that some of your information has been collected by mistake, or you have any questions, please let your parent or guardian know and get in touch with us at privacy@outfit7.com
If you do not understand this children-friendly privacy policy, we encourage you to read it together with your parent or a guardian. Together, you can talk about it, and also read more details on our privacy practices in the Privacy policy for websites, available here: https://talkingtomandfriends.com/privacy-policy-games/en.
For privacy questions and exercising your rights: privacy@outfit7.com.
For reaching out to our EEA data protection officer: ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg.
For reaching out to our UK representative: PRIVO Verified Limited, Room 3, 168 South Street, Dorking, Surrey RH4 2ES.
For reaching out to our Brazil data protection officer: dpo@outfit7.com.
For general information, please feel free to contact us via our customer service page: https://talkingtomandfriends.com/support.
For information collected under this Privacy Policy, the data controller is Outfit7 Limited, a company registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London, EC3M 6BN, United Kingdom, with a business address at Christaki Kranou 20, 2nd Floor, 4041 Limassol, Cyprus
