PRIVACY POLICY
WE
ARE TAPPS GAMES
Welcome to Tapps Games! We are an
international entertainment company specialized in the publishing of mobile
games and applications, headquartered in Portugal.
The purpose of this Privacy
Policy is meant to comply with your
rights under law, and provide you with all important information and
explanations about how and why your data may be collected, processed, conveyed
and deleted by Tapps Games.
THIRD PARTY ADVERTISING
This app
does not actively collect any information from children.
It does collect technical information which does not specifically identify a
user but supports the operation of the app.
device_type, mobile_brand_name, mobile_model_name,
platform_version, country, session, page views
We work with
the following third parties in this app:
We use Firebase Analytics for
database and statistics. We collect this information for internal use only and
it can’t be used to identify a user. This
third party is prohibited from sharing any data. For more
https://firebase.google.com/support/privacy/
We use the following ad providers to serve contextual ads in the Tapps games.
These networks are part of the Google Play certified ad network program. These
networks are restricted from tracking users and serving behavioural ads.
For more information on the use of these third parties please view the privacy
policies through the links provided.
Who Can You Contact?
If you would like further information about the third party service providers
listed please contact us at: data-controller[at]tappsgames.com
If you do not understand any item
of this Privacy Policy, we are at your full disposal
for any questions you may c
1. ABOUT THIS POLICY
Welcome to Tapps Games! We are an
international entertainment company specialized in the publishing of mobile
games and applications.
Tapps Games - Jogos Eletrónicos, Unipessoal
The purpose of our privacy policy (“Privacy
Policy”) is to provide you with all the important information and explanations
about how and why some of your data may be collected and processed by Tapps
when you use one of our applications or browse on websites, as well as ways we
might use or share it.
This Privacy Policy governs the relationship
between you and Tapps and describes the ways we, under and respecting the
specific regulation, collect, store, use, and manage your “data” or
“information”. Please note we are only describing our own practices –
When we say “Tapps services”, we mean any
games, applications, websites (including, but not limited to tappsgames.com)
and services owned by Tapps, regardless of how you access or use them or engage
with us, including through mobile devices. Your use of the Tapps services is
also subject to the
“Children” or “Child” means any user under
the age of 13 years old in the USA or under the age of 16 years old in the EU.
“Personal Information” means any information
relating to a natural person who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification
number, location data, or an online identifier.
Tapps Games is committed to protecting the
confidentiality, integrity, and secure of our users’ personal information. The
principles and rules on the protection of individuals regarding the processing
of their personal data should respect, regardless of their nationality or place
of residence, their fundamental rights and freedoms, including the right to the
protection of personal data.
If you do not understand any item of this
Privacy Policy, we are at your full disposal for any questions you may c
2. WHAT DOES THIS PRIVACY POLICY COVER?
Tapps undertakes to provide the
necessary treatment of personal information/data in compliance with the
specific local laws of access of its users, but is not responsible, under any
circumstances, for the legal treatment of information/data belonging to users
who are located in jurisdictions which do not offer a legislation for the legal
treatment of personal information/data.
3. PERSONAL DATA WE COLLECT
Personal
data is any information that relates to an identifiable individual. When you
you visit our website at https://www.tappsgames.com or you play
Tapps’ games ("Services" or "Games"), we may we may collect
and process the following personal data about you:
Contact Information
You may
provide us with your Contact Information, such as your phone number and email
when you contact us with a question or request.
Note: If a
child under the age of 13 years old in the USA or under the age of 16 years old
in the EU has contacted us through email, and we need to communicate with the
child more than once to resolve the query, we will ask the child to provide us
with the child's parent or guardian's email. Then we will send the parent or
guardian a notice telling that his/her child has contacted us. If we do not
obtain parental consent after a reasonable time from the date of the data
collection, we will delete such data from our records.
Location Data
We do not
collect data about your exact location (address) in any case. We can collect
data about your location, i.e. city or country. We collect this data
automatically when you use our Services or play our Games.
Technical Data
We may
collect such information as your IP address, advertising ID, and other
technologies on the devices that you use in our Services or play our Games. We
can also collect non-personal Technical Data about the mobile operating system,
mobile browser type, screen resolution, device vendor, language. We collect
this data automatically when you use our Services or play our Games.
Usage Data
We can
collect statistics on how you use our Services or play our Games. This
information does not contain information that will help us identify you. We
need this information so that we can provide you with the Services, improve
their quality, adapt them to your needs.
Please note,
if you decide to purchase the Tapps games subscription, we may collect and use
additional personal data as stated in section 7. Tapps Subscription.
We are not
collecting or storing any of your financial data as management of any payments
is done by the respective platform you are using to download our apps from,
such as iTunes, Google play, Amazon or others.
We do not
collect and do not intend to collect "special categories of data",
such as any information about health, race, religion, political opinions or
philosophical beliefs, sexual beliefs or orientation, as well as any data that
is not necessary for the provision of our services.
3.1. HOW WE COLLECT PERSONAL DATA
We use
several methods to collect Personal Data:
Personal Data is provided
directly by you
You provide
us with your data when you contact us by email, social networks or phone, ask
to answer your question.
We collect Personal Data
automatically
When you use
our Services, e.g. visit our website, play our games, we can automatically
collect technical information about your IP address, promotional identifiers,
equipment, browsing actions and models you use, as well as statistics. We
collect this Personal Data using cookies, automated event logs and other
similar technologies.
We collect Personal Data from
third parties
We may
receive Personal Data about you from third-party sources, i.e. from other
companies and persons (see section Our third-party data controllers and
processors).
3.2. HOW WE USE YOUR PERSONAL DATA
We will only
use your Personal Data as permitted by law. Usually, we will use your Personal
Data in the following circumstances:
Provide our services or
Pursue legitimate business interests related to providing our services to you
In order to
fulfil our obligations when you use our website or our mobile applications,
e.g. to ensure that the Services are provided, to improve the Services, to
identify subscribers and manage subscriptions, to personalize the content you
use, to respond to your requests and inquiries. Also, in order to fulfil our
legal obligations, we may ask for the child's parent or guardian's email when
we must obtain the consent of parents or guardians to use the child's Personal
Data (email and name). When it is necessary to fulfil our contractual
obligations or safeguard our legitimate interests, we use your Personal Data,
e.g. to provide you with contextual advertising, to analyse your behaviour
using our Services, to ensure the security and integrity of our Services.
Establish, exercise or defend
legal claims
We may also
use your Personal Data to enforce or defend our rights, protect your interests,
prevent and/or detect fraud or deceptive behaviour.
We will not
use your data to provide you with behavioural advertising, as well as
remarketing, profiling and automated decision making.
3.3. ON WHAT LEGAL BASIS WE USE PERSONAL DATA
Generally,
we collect and process your personal information only in order to fulfil our
obligations to you, use it for legitimate interests and protect your rights
(support for the internal operations), or if we have your consent to do so.
Below, we provide you with information on the purposes and grounds for usage of
your Personal Data.
|
Activity |
Data type |
Legal basis for data processing |
|
Manage
and protect our website and our mobile applications |
Contact Data |
(a)
Necessary for our legitimate interests (GDPR) |
|
Provide
Services, improve Services, customize Services for your individual needs |
Technical Data |
(a)
Necessary for fulfilling our contractual obligations (GDPR) |
|
Identify
games subscribers and manage games subscriptions (only if you get
subscription plan) |
Contact Data |
(a)
Necessary for fulfilling our contractual obligations (GDPR) |
|
Submit
contextual advertising to you, analyse your behaviour using our Services |
Technical Data |
a)
Necessary for our legitimate interests and for fulfilling our contractual
obligations (GDPR) |
|
Reply
to your applications, requests, notifications |
Contact Data |
a)
Necessary for fulfilling our contractual obligations and for legitimate
interests (GDPR) |
|
Get
the child's parent's or guardian's consent |
Contact Data |
a)
Necessary to comply with our legal obligations (GDPR) |
We will use
your Personal Data for the purposes for which we have collected them, unless we
reasonably believe that we must use it for another purpose that is compatible
with the original
Please note
that in cases where we must process Personal Data when required by law, we may
process your Personal Data without your knowledge or consent.
3.4. WHO MAY ACCESS YOUR PERSONAL DATA
We may share
your personal information with a few selected third parties, such as:
4. COLLECTION AND USE OF INFORMATION BY THIRD PARTIES
4.1. Ad Networks
Tapps publishes advertising on
the Services so that we can continue to offer many of the Services for free.
Such advertisements are provided by Ad Networks, which are carefully selected
to preserve compliance with the applicable privacy laws as well as such
information are clear to all users in an accessible format that you can decide
not to consent, or change your mind later by activating our specific toll for
that purpose.
Nevertheless, we have the
necessary tools to formalize your choice, if you decide not to consent anymore,
or change your decision later if you have already consented. Please note that
Ad Networks may collect and use your Information, such as:
●
performance
data (like the number of clicks on an advertisement);
●
●
and
other contextual data about your game play (e.g., your session activity);
●
Device
identifiers, such as your IP address,
●
●
Information
about your use and downloads of our applications;
● Information about the offered,
viewed, or clicked ads such as the type of ad where the ad was offered, whether
you clicked on it,
The above information is intended
to provide transparency to Tapps’ users, but Tapps emphasizes that it is not
responsible for information collected by third parties outside of its control.
The Information collected may be
used for the following purposes:
●
measure
how effective advertisements are and/or;
● undertake web analytics (which
are used to analyze traffic and other user activity to improve your
experience).
Ad Networks may collect this
Information through the use of tracking technologies like browser cookies and
web beacons, and they may use a single tracking technology or multiple tracking
technologies at the same time. Such practices are subject to those Ad Networks’
policies which we recommend you review before interacting with them.
Please note that after clicking
on an advertisement you may be redirected to a website that is not hosted by
Tapps.
Moreover, we may, at our
discretion, advertise other Tapps Services within our Applications. Such
advertisements are not directed towards specific users but are rather broadly
posted on random Tapps Applications.
In addition, you may see our
Services advertised in other games, applications, websites and places. After
clicking on one of these advertisements and installing or accessing the
Services, you will become a user of our Services. In order to verify the installation
of the Application, a Persistent Identifier may be shared with the third party
who published our advertisement.
4.2. Mobile Analytics
Tapps allows Analytics Providers
to use and collect users’ Information, such as and not limited to your Non Persistent
Identifier, locale (specific location where a given language is spoken),
general geo-location information, your Internet Protocol (IP) address, device
type, operating system, the links and advertisements on our Services that You
clicked on, the amount of time You interact with the Services, the events that
occur within the Services, performance data and other statistics.
We display this Information to
Analytics Providers in order to improve and enhance the Services by expanding
their features and functionalities and tailoring them to our users’ needs and
preferences. We also use the Persistent Identifier to generate and aggregate
non-identifying information about how our Services are used. We do not link the
information we store within the analytics software to any identifying
Information you submit within the Services.
If you want (or not) your
Information to be collected by Analytics Providers, we offer an opt-in and
opt-out options in our game’s settings.
Please refer to our list of
Analytics Providers for more information on how to opt out in Section 14.
4.3. Social Media Features and Game Center Features
Our
Your interactions with these
Social Features are governed by the privacy policy of the respective company
providing them. Links to these privacy policies are provided in Section 14.
Our Applications may enable
certain game center features (“Game Center Features”) and may include Social
Features as well. The Game Center Features and the Social Features are operated
or
These Social Networks and Social
Platforms are created and maintained by third parties (“Social Partners”) who
are not affiliated with and/or controlled by Tapps.
If you enable integration with
such Social Networks and Social Platforms, your use of the Game Center Features
and/or the Social Features is subject to the applicable Social Partners’ terms
of use and privacy policies (collectively, “Social Terms”), for example:
●
Apple
Game Center (terms are available at http://www.apple.com/legal/internet-services/itunes/gamecenter/us/terms.html);
●
Google
Play Games (terms are available at https://play.google.com/store/apps/details?id=com.google.android.play.games);
●
Amazon
GameCircle (terms are available at: http://www.amazon.com/gp/help/customer/display.html?nodeId=201371550);
● Huawei App Store (terms are
available at https://consumer.huawei.com/en/privacy/privacy-policy/)
You should ensure that you have
read the Social Terms in order to comprehend how they treat your information
and to understand the methods for changing the privacy or sharing settings on
the Social Networks and Social Platforms.
If you do not agree to the
practices described in the Social Terms, you should not allow the Applications
to interact with such Social Networks or Social Platforms. However, you may
find that you are not able to enjoy all the features that may be made available
by the Applications.
You understand that where you
allow interaction with any Social Network or Social Platform, we may share data
about you with your contacts which are considered as the user that already has
on the applicable social network or social platform (“Contacts”), and vice
versa, so that you may enjoy Game Features and Social Features. This data may
include, without limitation, your scores and/or progress in our Applications,
your name, your social media profile picture, descriptions of your service activity
and any test that you may upload. Your Contacts will also be able to send you
requests through the related Social Network or Social Platform.
The use of Social Features or
Game Features enables the sharing of information with your Contacts or the
public, depending on the settings you establish with the Social Partner that provides
such features. You hereby understand and agree that when you share content via
Social Networks or Social Platforms your content may become public and any
person may re-post-it. Your interactions with these Social Features or Game
Features are governed by the privacy policy of the company providing them.
4.4. Tracking Technologies
When you use our Applications,
Tapps or its Partners operating the advertisement serving technology may use
information logged from your device using SDKs, cookies, and other tracking
technologies to ensure that appropriate advertising is presented within our
Applications and to calculate the number of unique and repeat views of
advertising.
It is important to mention that
you can choose in advance and at your own discretion whether or not you wish to
make your personal data available in the game and that your decision is not
only respected by Tapps but also is passed on to our Partners.
Such Partners’ technologies
(“Partners’ Tech”) may be stored on your device by Partners, rather than by
Tapps.
Partners’ Tech usually store
non-identifying Information such as the web pages you have visited, the
duration of your browsing, etc. This Privacy Policy does not cover the use of
tracking tools by Partners. Tapps does not have access or control over its Partners.
In order to understand the functioning of Partners cookies or related
technologies used in our Services, please visit the links in Section 16.
4.4.1. Opting Out of Tracking Technologies
You are always free to opt out
via “Do Not Track Settings” in your mobile phone and all providers of
advertising services are bound to comply with such “Do Not Track” setting, but
we cannot provide any guarantees on their behalf.
It is easy to prohibit Partners’
Techs. Most browsers and platforms will allow you to erase Partners’ Cookies
from your device’s hard drive, block acceptance of cookies, limit the type of
cookies you allow or receive a warning before a cookie is stored. However, be
aware that if you block or erase Partners’ Cookies, your online experience may
be limited, because Partners Cookies are necessary to track and enhance your
Services activities.
5. IN-APP PURCHASES
Although Tapps’ applications are
free, they include in-app purchases (“App Purchases”), but we do not collect
personal’s payment information or process payments through in-app purchases.
All App Purchases are made
through our Partners’ stores (“Stores”). Therefore, in order to make an App
Purchase, you will need to access your Store account (“Store Account”), which
may require entering the Store password (“Store Password”). You hereby agree
and acknowledge that you are responsible for maintaining the security of your
Store Password.
You should be aware that some
Stores may allow for a short window after the downloading of an Application,
during which App Purchases may be made without inserting your Store Password.
Regarding your privacy and in
order to prevent accidental or unwanted purchases, you can create a specific
password/PIN to prevent it from happening at Apple, Google Play, Amazon and
Huawei.
Please note that purchases of
Stores’ credits or currencies may also be subject to their own policies and
Tapps
6. PURCHASE OF MERCHANDISE
Some of our Services may contain
links that will redirect you to a third-party website where they may purchase
certain merchandise (“Merchandise”) which are offered for sale or otherwise
distributed by third-party vendors (“Vendors”).
The Vendors are responsible for
the Merchandise and the Merchandise operations. The Vendors may collect
information from users who wish to purchase Merchandise, which is required in
order to enable the purchase transaction (e.g.,
the User's address in order to deliver them the Merchandise, the User's payment
information in order to enable the billing and the processing of payment via
various payment methods, etc.).
Tapps will not collect, use or
have any access to this information collected by Vendors. Such Information will
be collected, maintained, shared, transferred and/or used in accordance with
the applicable Vendor’s privacy policy and terms of use (“Vendors’ Terms”).
7.
With your consent, we may send
push notifications in order to inform you about our products and services, to
communicate you of Application updates and to reengage you in use of the
Application.
Local
notifications are local to your device, contextual and sent in-app only and not
from a server or in conjunction with other User information. By clicking on the “Allow”
button, you accept local notifications, but you may disable these messages at
any time by turning off the notifications from the “Options” or “Settings” page
within the Application.
“Push
notification are sent from the server and are never sent to users who
identified themselves as under 13 (for residents in the EEA) and 16 (for
residents in California). We use such notifications to remind you about your
activities within the App. You will receive push notifications only
You can accept local
notifications, but you may disable these messages at any time by turning off
the notifications from the “Options” or “Settings” page within the Application.
We
collect push notifications tokens for us to be able to determine whether you
are subscribed to push notifications. When you decide to unsubscribe from push
notifications, such push notification tokens will be deleted from our
database.”
For
the restriction on the usage of information please see ‘Children´s Privacy
Section of this Privacy Policy.
8. SECURITY OF YOUR INFORMATION
Although we make good faith
efforts to store the information collected on the Services in a secure
operating environment that is not available to the public, please be aware that
no security measures are perfect or impenetrable.
Furthermore, while we attempt to
ensure the integrity and security of our network and systems, we cannot
guarantee that our security measures will prevent third-party “hackers"
from illegally obtaining access to this information.
We do not warrant or represent
that your information will be protected against loss, misuse, or alteration by
third parties. No method of transmission over the Internet, or method of
electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute
security. Subjected to the applicable local law,
8.1. International Transfe
We operate globally, so we need to transfer
your personal information to our affiliated entities and/or to other third
party service providers across boarder and from your country to other countries
around the world. Please note, that not all these countries have the same data
protection laws as your own country,
9. STORING OF INFORMATION
The
security of your information is important to us. We have measures in place to
protect it against loss, misuse, or tampering. However, no security measures
are 100% effective, so we cannot guarantee against these risks.
We store your information for as
long as
Storing might be different
depending on the territory of collecting the information and the applicable
legislation, but we always strive to store the information only if it is needed
for the purposes of providing, improving or personalizing our services. As a
rule, your information will be stored in the form anonymized data. However,
there may be exceptions to this practice depending on the type of services that
was contracted.
Even so, if you wish to cancel
your account or request that we no longer use your information to provide you
services, please contact us at data-controller[at]tappsgames.com and refer to Sections 11 and 12 below.
If you want to know for how long
our Partners keep your Information, please refer to their privacy policies,
available in Section 16.
9.1. Data Retention
Tapps
will keep the Personal Data of users only for the time necessary to comply with
the purposes to which they are collected, including for the purposes of
observance of any legal obligations (such as the safeguard of access logs to
the application for 6 months, according to the Internet Civil Framework), contractual
obligations, obligations to render account, or request by competent
authorities.
In
order to determine the proper retention period of the Personal Data, Tapps
takes into account the quantity, nature, and sensitivity of such Data, the
potential risk of damages resulting from the unauthorized use or disclosure of
Personal Data, the purpose of processing, and if the respective purpose may be
achieved by other means, as well as the legal requirements applicable.
Nonetheless,
if you play a Tapps game, the information of your account will be maintained as
long as you keep this account active. Your account and the information related
to it will be anonymized if you do not login for 90 days. You may also request
the exclusion of your Data and/or your account, case in which Tapps will keep
the Data for fifteen (15) days from the request of exclusion.
It
is worthwhile noting that Tapps may retain the Personal Data for a period
longer than the indicated above to meet any legal obligations eventually
applicable, under the terms set forth by the pertinent legislation, such as the
consumer defense and tax rules.
Tapps
may retain users’ account data internally for the following purposes:
● Billing information and transaction
histories are retained to resolve subsequent billing disputes and inquiries;
● Publicly shared content and virtual items
are retained for use by the community (e.g., a user-created virtual shirt sold
to another user is kept in the system because the recipient now “owns”
a copy of that item);
● User account history is retained to support
subsequent customer service inquiries and to provide, improve and develop the
Service;
● To promote safety and security on the
Service; and
● To resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes, enforce our
agreements, and comply with our legal obligations. We may retain your
information for as long as is necessary for the purposes identified above,
which may include retaining your information beyond the end of your use of the
Service.
10.
We
consider ourselves to be family oriented, however we have decided to
voluntarily implement higher child protection standards we do not knowingly
collect personal information from children under 13, with the sole exception of
persistent identifiers as described in the Privacy Policy. If we learn that we
have collected personal information other than persistent identifier of a child
under the age of 16, 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 data-controller[at]tappsgames.com
To
preserve the family-friendly reputation of our Apps, we age-gated some of the
features in our Apps, so that they are not available for use by children under
16. The age gate is being conducted after the download of some of our Apps for
specific territories to assure the privacy and protection of younger users of
our Apps. The features enabling potential collection and sharing of personally
identifiable information, are disabled for device IDs of users who did not pass
the age gate. For user's safety, it is not possible to change the age later. We
do not store the year of birth of users who have identified themselves as below
the age of 16 in our Apps, but only the information that their device did not
pass the age gate.
The
only personal information we collect from users who have identified themselves
as below the age of 16 for the purposes of offering our services are persistent
identifiers (such as IDFA, IDFV, advertising ID, IP address). Such persistent
identifiers are used and shared with third parties solely for providing support
for the internal operations meaning to place contextual advertisement
(including frequency capping), to authenticate users of or personalize the
content on Apps, to maintain or analyse the functioning of the Apps,
personalize the content of the App (such as sending push notifications), to
perform network communications to protect the security or integrity of the user
or the App, to ensure legal or regulatory compliance.
When
using the persistent identifiers, we will not contact users under the age of
16, display behavioral advertising to them, nor do
any user tracking or profiling. In addition, we strive that all our advertising
partners adhere to the same standards for the collection, usage and disclosure
of children's personal information as we do, but we cannot be responsible if
they breach the commitments, they gave to us regarding the collection of
information. In case of such breaches, you agree that our liability is limited
to the amounts we are able to receive as
indemnification for the breaches from our advertising partner. For the detailed
information
about disclosure to third party service providers used in relation to users
under 16 please see section How do we share your information and data to third
parties of this Privacy Policy. For any additional questions about third-party
information disclosure please see section Information about third-party data
controllers and processors.
We
will send push notifications only to users who allow us to do so to reengage
them in terms of using the App. You may unsubscribe at any time by following
the instructions in section Push Notifications of this Privacy Policy. We
strive to ensure that the content of the push notifications will always be family-friendly. Local notifications are local, contextual
and sent in app only and not from a server or in conjunction with other user
information.
You
have the right to request deletion of the personal information that we hold
about you. Should you wish to do that, please contact us via data-controller[at]tappsgames.com.
We reserve the right to ask to provide us additional information to verify your
identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we
will delete your personal information you requested us as soon as possible, but
we will always do so within 1 month of receipt of your request and verification
of your identity. Please note that we may still retain part or all information,
for instance for complying with our legal obligations and protecting or
enforcing legal rights. We may also retain your info in an anonymized form. In
some instances, personal information about you that is visible through gameplay
such as username, avatar, your high scores and any chat messages may be cached
on other players´ devices and we may be not able to remove or update that data
from those devices, for example if that device is not connected to a Wi-Fi
network.
11.
We consider ourselves to be
family oriented, however we have decided to voluntarily implement higher child
protection standards even though our products and services are not directed to,
and we do not knowingly collect personal information from children under 16 without a consent of a
parent or guardian, with the sole exception of
persistent identifiers as described below. If we learn that we have collected
personal information other than persistent identifier of a child under the age
of digital consent according to EEA data protection legislation, 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 data-controller[at]tappsgames.com
In order to preserve the
family-friendly reputation of our Apps, we age-gated some of the features in
our Apps, so that they are not available for use by children under the age of
digital consent according to EEA data protection legislation. The age gate is
being conducted after the download of some of our Apps to assure the privacy
and protection of younger users of our Apps. The features enabling potential
collection and sharing of personally identifiable information, with the exception of persistent identifiers, are disabled
for users who did not pass the age gate. For user's safety, it is not possible
to change the age later. We do not store the year of birth of users who have
identified themselves as below the age of digital consent according to EEA data
protection legislation in our Apps, but only the information that their unique
user ID did not pass the age gate.
The only personal information
we collect from users who have identified themselves as below the age of
digital consent according to EEA data protection legislation for the purposes
of offering our services are persistent identifiers (such as device ID, IDFA,
IDFV, advertising ID, IP address). Such persistent identifiers are used and
shared with third parties only to place contextual advertisement (including
frequency capping, fraud prevention and tracking for the attribution and
billing purposes), to authenticate users of or personalize the content on Apps,
to maintain or analyse the functioning of the Apps, personalize the content of
the App (such as sending push notifications), to perform network communications
to protect the security or integrity of the user or the App, to ensure legal or
regulatory compliance.
You
have the right to request deletion of the personal information that we hold
about you. Should you wish to do that, please contact us via data-controller[at]tappsgames.com.
We reserve the right to ask to provide us additional information to verify your
identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we
will delete your personal information you requested us as soon as possible, but
we will always do so within 1 month of receipt of your request and verification
of your identity. Please note that we may still retain part or all of that info, for instance for complying with our legal
obligations and protecting or enforcing legal rights. We may also retain your
info in an anonymized form. In some instances, personal information about you
that is visible through gameplay such as username, avatar, your high scores and
any chat messages may be cached on other players´ devices and we may be not
able to remove or update that data from those devices, for example if that
device is not connected to a Wi-Fi network.
When using the persistent
identifiers, we will not contact users under the age of digital consent
according to EEA data protection legislation, display behavioural advertising
to them, nor do any user tracking or profiling. For the detailed information
about disclosure to third parties please see section How do we share your information and data to third
parties of this Privacy Policy. For any additional questions about third-party
information disclosure please see section Information about third-party data
controllers and processors.
12. CHANGES TO OUR PRIVACY POLICY
Tapps will occasionally update
this Privacy Policy as necessary to protect our users, furnish current information,
and respond to legal and technical changes. The most current version of the
Privacy Policy will govern our use of your information and will be available
at: http://pp.tappsgames.com/?app=default
If at any point you do not agree to any
portion of the then-current version of our Privacy Policy, the Terms of
Service, or any other Tapps policy, rules or codes of
conduct (“Supplemental Policies”), you have an option to stop using Tapps
Services. In case you disagree with Tapps Services, you can click on “privacy
settings” and to choose disable our Services. This option permit you continue
playing our games normally.
13. CONTACT U
If you have any questions,
comments or concerns regarding our Privacy Policy and/or practices, please send
an e-mail to data-controller[at]tappsgames.com.
Tapps Games - Jogos Eletrónicos,
Unipessoal Lda
Rua Dr. Sousa Viterbo,
93, 1
Porto 4050-593
Portugal
14. INFORMATION ABOUT THIRD-PARTY DATA CONTROLLERS AND PROCESSORS
Google Analytics (Google Inc.)
Google
Analytics is a web analysis service provided by Google Inc. (“Google”). Google
Analytics uses Personal and Non-Personal Data only for internal purposes.
Legal basis of
processing: legitimate interests (support for internal operations).
Place of
processing: USA
Privacy policy: https://policies.google.com/privacy?hl=en
Address: 1600 Amphitheatre Pkwy, Mountain View, California 94043, US
Phone: +1-650-253-0000
Kidoz
KIDOZ
SDK provides effective quality monetization that is fully COPPA and GDPR
compliant.
Certified compliant with the Children’s Online Privacy Protection Act (COPPA)
by FTC-approved safe harbor and child privacy experts, PRIVO
Legal basis of
processing: legitimate interests (support for internal operations).
Place of
processing: Israel
Privacy policy: https://kidoz.net/privacy-
Address: Haomanut 12, Poleg Industrial Park
PO BOX 8517, Netanya Israel
Contact: https://kidoz.net/contact
Firebase by Google (Google
Inc.)
Firebase is
a mobile analytics platform which allows developers to analyse crash reporting
and retention. Firebase uses Personal and Non-Personal Data only for internal
purposes.
Legal basis of
processing: legitimate interests (support for internal operations).
Place of
processing: US
Privacy policy: https://policies.google.com/privacy?hl=en
Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, US
Contact: https://firebase.google.com/support/troubleshooter/contact/