Rabu, 01 Januari 2020

Privacy Policy


(Last update February, 2020)

We promote our Apps and services in ours and other publisher’s apps and we also allow our partners to promote and advertise their goods and services in our Apps. We may share information we collect from you to our advertising partners and they can reuse such data for targeted advertising. We or our advertising partners may display interest-based, or retargeted, ads (''IBA''), but only for the device IDs that have passed the age gate and have not opted out of IBA. By using our Apps and not choosing one of the opt-out options, you give us consent to transfer your data as stated below.

We may pass information we collect from you such as technical information, advertising and application usage information (for example if a device has clicked on a sports ad within our Apps, for more information please see Information And Data We Collect From You Section of this Privacy Policy) as well as age & gender information to our advertising partners and they can reuse such data for targeted advertising. We allow our partners to serve targeted third party advertisements or other content. They may attach the information gathered from our App to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. For example we pass advertising IDs to Facebook and they match it with your Facebook ID, aggregate it and delete the initial identifier. By doing so the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information Facebook receives or infers about users. We cooperate with several providers of IBA that are listed herein in subsection a) and in Opt-Out Section of this Privacy Policy (''Third Parties''). When allowing Third Parties to conduct IBA we adhere to the DAA Principles available here http://www.digitaladvertisingalliance.org/principles/.

You have an option to opt out from sharing your information and data for the purposes of interest-based advertising at all times. When you opt out, you will not stop receiving ads, they just won't be based on topics you like, your interest, behavior, demographics, etc. You can opt out by choosing one of the following options (for more information please read the ''Opt Out'' Section of our Privacy Policy):

a) Via third party IBA provider:

MoPub http://www.mopub.com/optout/;
Facebook Audience Network https://www.facebook.com/about/privacy/update?ref=old_policy;
Facebook Ad Campaigns https://www.facebook.com/about/privacy/update?ref=old_policy
InMobi http://www.inmobi.com/page/opt-out/;
AppLovin https://www.applovin.com/optout;
Google (Adx) https://www.google.com/ads/preferences/html/mobile-about.html;
Google (AdMob) https://www.google.com/ads/preferences/html/mobile-about.html;
My.Com https://target.my.com/privacy/;
OpenX http://openx.com/legal/privacypolicy/interestbasedadvertising/;
Inneractive - Please see Section MANAGE YOUR PRIVACY of Inneractive's privacy policy available at http://inner-active.com/privacy-policy/;
Machine Zone http://www.networkadvertising.org/mobile-choices;
Madgic http://www.madgic.com/opt-out-and-identifier-reset/;
AerServ https://www.aerserv.com/third-party-opt-out/;
Triapodi Ltd., dba Appreciate http://appreciate.mobi/page.html#/appoffers-opt-out;
Smaato https://www.smaato.com/privacy/#section4;
SMARTSTREAM.TV http://www.smartstream.tv/optout/cookieOptOut.php;
Maiden Marketing PTE Ltd, dba Pokkt - Please see Section “10. Your choices and opting-out” of Maiden Marketing PTE’s privacy policy available at https://www.pokkt.com/privacy;
Vungle https://vungle.com/opt-out/;
PubMatic https://pubmatic.com/legal/opt-out/#IBA;
AdAction https://www.networkadvertising.org/mobile-choices;
AdColony https://www.adcolony.com/privacy-policy/#targetingchoices;
Apple (Search Ads) https://support.apple.com/en-us/HT202074;
Google (Ad Words) https://support.google.com/ads/answer/2662922?hl=en;
Chartboost www.chartboost.com/useroptout;
Motive Interactive http://motiveinteractive.com/privacy#opt-out;
Max Advertising Systems, Inc., dba MAX http://maxads.io/optout.html;  
Matomy Media Group Ltd., dba Mobfox https://www.mobfox.com/privacy-policy/#opt-out;
Click Tech Limited (dba Yeahmobi) https://en.yeahmobi.com/can-users-opt-out-of-devices/;
Snapchat https://support.snapchat.com/en-US/a/advertising-preferences;
Gameloft S.E. – Please see Section “Limit Ad Tracking / Do Not Track of Gameloft Cookie Policy available at http://www.gameloft.com/en-gb/legal/showcase-cookie-policy;
IQzone Inc. https://iqzone.com/about/privacy/#optout;
Twitter https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads;
Etermax S.A. http://www.etermax.com/en/privacy/#publicity-analytics.
Adverty AB https://www.adverty.com/privacy-policy#optout;
Mintegral (Mobvista) https://www.mintegral.com/en/privacy/#yourDataRights;
ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#how-to-control-your-info;
Fyber Monetization Ltd. https://www.fyber.com/privacy-policy/#user-choice;
AdTiming Technology Company Limited https://www.adtiming.com/privacy-policy.php#opt-out;
A9.com, Inc. and Amazon Europe Core S.à.r.l https://www.amazon.com/adprefs;
The Rubicon Project, Inc https://rubiconproject.com/privacy/consumer-online-profile-and-opt-out/;
If you choose to opt out by following one of the third party IBA provider’s opt out mechanism, you should stop receiving interest-based and targeted ads via the selected IBA provider, but you may continue to receive interest-based or targeted ads through other IBA providers. For opting out from receiving interest-based or targeted ads through all IBA providers, please see opt out options b) and c) below.

b) Via “Do Not Track Settings” in mobile phone:

Turn on “Limit Ad Tracking” on your iOS device or “Opt Out of Interest-Based Ads” on your Android device.

c) Via our Apps:

Choose “Opt Out of IBA” within the settings of our Apps (where available).

As used in this Privacy Policy, "OUTFIT7", “we”, “us” or “our”, “ours” refers to Outfit7 Limited, registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London EC3M 6BN, United Kingdom, with business address at Agiou Georgiou, 4607 Pissouri, Cyprus, and all of its subsidiaries. 

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the “EULA”) governing the use of all "OUTFIT7" branded software applications (the “App/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the App. This Privacy Policy covers how we collect, use, disclose, transfer and store information received about you and/or information received about your computing device through your use of the Apps.

By using our Apps you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications. As described in greater detail below, we may share this information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

For general information please feel free to contact us via http://outfit7.com/contact/ and for privacy questions via privacy@outfit7.com, or call us on our toll-free telephone number: (855) 9541152.

1. Technical Information And Data
We collect technical data necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, to personalize the content of the App, and to display advertisements.

We automatically obtain certain information about your computing device, including:

IP address; Country code;
IDFAs, IDFVs, Advertising IDs;
Language; Locale (specific location where a given language is spoken);
Time zone, session start/stop time,
Network status (WiFi, etc.), browser plug-in types and versions;
User agent string (UA), platform, SDK version, timestamp;
All apps installed;
Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, International Mobile Equipment Identity (IMEI) on Android, Android ID, Android Serial No);
Push notifications token;
Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple's Game Center).
In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.

Older versions of our Apps may still obtain information such as UDID number and IMEI number on iOS. If you wish to prevent this, please update the App with the latest version available on App Store.

2. Advertising And Application Usage Information And Data
When you use our Apps, we may collect additional information by using device identifiers that permit identification of your device. Such information is used for advertising and analytics purposes.

The information collected includes:

Which advertisements are shown;
Length of time an advertisement is visible and the size of the advertisement;
Advertisement response (if any), including clicks on ads;
Angle of view;
Application usage information, (how often you use the app, for how long you use the app, the events that occur within the app, in-app location, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.).
3. Classical Personal Information
We do not collect any personal information about you through our Apps, with the sole exception of persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address). Persistent identifiers are identifiers that do not identify you personally, but may uniquely identify your device. Some legislation (such as US) may treat such information that uniquely identifies your device as personal information.

We may ask you to submit and we may process other non-personally identifiable information that may be personal to you such as your age range, year of birth and gender, provided that year of birth and gender information is collected solely for users who have passed the age gate in our Apps. We will use such information to personalize the content of the App, and for users who passed the age gate and have not opted out from behavioral advertising we may use such information to display targeted ads. You can opt out from receiving targeted ads by choosing one of the options described in the ''Opt Out'' Section of our Privacy Policy.

When you voluntarily contact us directly, we may collect information about you that you provide us (such as your name and surname, email address). We will use such contact information only for the purpose for which you provided it to us. We will not share this information with third parties.

If you wish to delete your contact information that we received from you when you contacted us, please send an e-mail to privacy@outfit7.com and your contact information will be deleted from our database.

For the My Talking Tom App and the My Talking Angela App and the My Talking Hank App we also collect the information about the name you give to Tom/Angela/Hank and your rating of the Application (if any) and for the Talking Tom Bubble Shooter App we collect information about the nickname you choose. Please do not use your real name.

1. In General
We use the information we collect about you/your device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analyzing trends in connection with usage of the Apps, administering the Apps, and customer communications.
Displaying advertisements: displaying third party advertisements in our Apps and showing advertisements for our Apps in other publisher’s apps. Please see more in Advertising Section of this Privacy Policy.
Cross-promotion: cross promoting our Apps and services, meaning we may promote one of our Apps while you are playing a different App of ours.
Tracking and fraud prevention for advertising purposes: for some of our Apps we use third party services for tracking and fraud prevention for advertising purposes and for privacy compliance purposes. Please see more in Tracking Section of this Privacy Policy.
Analytics and research: understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new game features and content. We use the data we receive from Third Party Social Network only for internal analytics. For opting out from analytics please visit Opt-Out Section of this Privacy Policy.
2. Push Notifications
We use push notifications to remind you about your activities within the App. You will receive push notifications only if you are subscribed to push notifications in the App. To unsubscribe, please use the instructions provided below:

For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON.
For Android and Windows: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.
We collect push notification tokens in order 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.

3. Survey
We are conducting surveys in order to improve our services and you may freely decide whether you would like to help us or not.

From time to time we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, whether children under the age of 13 use the app on their own or with an adult, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, which Talking Tom and Friends Products have been bought or have been considered, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.

We may use third party providers for the in-app surveys and they may place their tags within an App to collect non-personally identifiable data from the device (”Tag Data”) solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated basis together with the data from other partners (”Unified Data”) to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.

We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must therefore share collected information with third parties, including analytics providers, tracking providers, third party advertising providers and other third party service providers that support the Apps (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners’s advertising campaign performance. We may share such information to:

Our analytics providers: For some Apps we use third party analytics such as BigQuery, and Firebase Analytics for the purposes of delivering our services, conducting analysis and research. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. Additionally we have also integrated Google Play Developer Console data like Impressions, Downloads, and Traffic Sources into a Google Analytics account to see how many times people viewed or downloaded our apps from Google Play. The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to You. Third party analytics providers have the right to process the data in accordance with their privacy policies (http://www.google.com/intl/en/policies/privacy/#nosharing) and such collection and processing is limited to the disclosure in aggregated manner, for the purposes of showing trends about the use of their services, for advertising services and marketing purposes. We can aggregate the data for benchmarking feature.
Our cloud service providers: We store information we collect from you on servers provided by our third party cloud service providers such as Google Cloud Platform and Google’s Android Backup Service;
Our tracking and fraud prevention providers: For some of our Apps we use third party services for tracking of our advertising campaigns, for fraud prevention and privacy compliance purposes. Please see more in Tracking Section of this Privacy Policy.
Third party advertising partners:  We have contracted with certain third party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Apps for free or at low cost. Such third party advertising partners include but are not limited to advertising providers listed at http://outfit7.com/third-party-ad-providers/. Please see more in Advertising Section of this Privacy Policy.
Advertising partner’s third party tracking provider: For some Apps we may allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign performance. Please see more in Tracking Section of this Privacy Policy.
Other third party service providers: For some Apps we use Unity Software to develop such Apps. For the data processing by Unity please see Unity’s privacy policy available at https://unity3d.com/legal/privacy-policy.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. 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 third party.

For any additional questions about third party information collection please refer to privacy@outfit7.com.

We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us. They adhere to this Privacy Policy, but in some cases we must use their privacy policies.

We strive to commit our Partners to using the information solely for the purposes as stated in this Privacy Policy. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices. While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information and therefore you acknowledge that we are not liable for any third party privacy breach and that our liability for our Partner breaches is limited to the amount we are able to receive as indemnification from our Partners (legal costs exempted).

Some of the Apps allow you to submit content generated in or by the Apps to third party sites like Facebook, Vkontakte, Google Play Games, Game Center and YouTube. These submissions follow the information transfer protocols of such third parties, which are designed to enable content sharing with such third parties.

When you use our Apps we may display contextual advertisements to you. In order to enable advertising we allow our advertising partners to collect online identifiers (such as Advertising ID on Android and IDFA on iOS) that might be considered as personal information under some legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on anonymized and aggregated basis.

For some territories, we may use and share with our advertising partners technical and advertising and application usage information we collect from you (please see Information and Data We Collect From You Section of this Privacy Policy) in order to enable our advertising partner to deliver, target and optimize third party advertising in our Apps, so that the advertisements you see are more relevant to you and are based on your app and device usage, online behavior and interests (this is commonly referred to as online behavioral or interest based advertising, i.e. IBA). In addition, we may use and share such information with our advertising partners in order to target and optimize our advertising and promotions in our and other publisher’s apps.

We will always follow applicable legislation and accepted market practices, thus we will not use and share information for the purposes of behavioral advertising for users who did not pass the age gate in our Apps and for those who opted-out of IBA. For more information on behavioral advertising and our IBA providers please see Interest-Based Ads Section of this Privacy Policy. For opting out from sharing your information and data for the purposes of behavioral advertising please visit Opt-Out Section of this Privacy Policy.

When you use the App, we or third parties operating the advertisement serving technology may use information logged from your device using SDKs, cookies, web beacons and other technologies to ensure that appropriate advertising is presented within the App and to calculate the number of unique and repeat views of advertising.

For some of our Apps we use third party tracking and data collection tools from our service providers for the purposes of tracking performance, ad visibility and privacy compliance of third party SDKs in our Apps.

We use third party tracking and data collection tools from our service providers, such as AppsFlyer and 24metrics, for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such tools may use cookies, APIs, and SDKs in our Apps to enable them to collect and analyze user and device related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app events.

In addition, our Partners may use their own tracking technologies (including and without limitation: SDKs, cookies, Web beacons, HTTP cache, local shared objects and other technologies) in order to track impressions, clicks, installs or other advertising campaign performance indicators for the purposes of measuring third party advertising campaign performance.

1. Connecting To Third Party Social Networks
Some of our Apps use third parties’ services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte (“Third Party Social Network/s”). Such Apps enable you log in to your Third Party Social Network account to connect to our App by using the “Log in with”or “Connect to” feature in our App. You may also share the content you created within the App on Third Party Social Networks. By logging in to your Third Party Social Network account to connect to our App or by using the App to share content on such Third Party Social Network, you are authorizing us to collect, store, and use any and all information, in accordance with this Privacy Policy, that you agreed that such Third Party Social Network could provide to us through the Application Programming Interfaces (“API”). You authorize us to do so when you “accept” or “allow” (or similar terms) connection of one of our Apps to such Third Party Social Network. The information you allow us to access varies by App, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at the Third Party Social Network in question. Please note, Third Party Social Networks 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 the third parties that operate those sites. For additional questions you can contact us at privacy@outfit7.com.

2. Data We May Access Via Third Party Social Networks
If you use the “Log in with” or “Connect to” feature we may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the "Log in with" or “Connect to” process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the “Log in with” or “Connect to” feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.

The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.

3. Consent To Publicly Display Data On Third Party Social Networks
If you use Third Party Social Networks to participate in game related activities, including but not limited to participation in leader boards, multi-player games or the downloading and uploading of content, OUTFIT7 and its affiliates may also collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and achievements), or identify content that is created and shared by you with other players. Data that personally identifies you is collected, used, stored and transmitted in accordance with this Privacy Policy.

Please note that your access to and ability to use and interact with the Apps may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers. You recognize and agree that OUTFIT7 is not liable for any such third party terms and conditions and their use of your personal information.

Our Apps may contain links to third party websites, products, or services. For example, the Apps 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 are not responsible for 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 or 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. These other websites or services may place their own cookies or other files on your computing device, collect information or solicit personal information from you. We encourage you to learn about the privacy practices of third parties with which you interact.

We are not responsible or liable for your interaction with such third parties, the information requests initiated by such third parties, or the subsequent use, treatment or dissemination of information you voluntarily choose to provide to them.

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