Effective from 2018-jul-5
1. What kind of personal information does Toosmart collect?
We aim to minimize how much personal information we collect from users when they play the Games or use the Websites. We collect the personal information that you voluntarily provide to us, but most of our data collection is limited to the following types of data, which do not identify you personally but may uniquely identify the device you are using to play to the Games or use the Websites ("Device"). In some countries, this type of data may be considered as personal information:
"Advertising ID", which means the resettable and unique identifier associated with your mobile phone or tablet that is used by advertisers for ad tracking.
"Location Information", which means general information about the location from which you’re playing the Games or using the Websites (e.g. IP address, country, and city).
"Device Information", which means technical information about your Device. When we refer to Device Information, this means your Device ID, your browser and browser plug-in types, operating system and operating system version, the brand and manufacturer of your Device, the language you’ve set for your Device, the version of the Game installed on your Device.
|Your Age||When you install our Games, you will be asked to provide your age. We use this information to enable or disable certain Game features and certain types of ads shown to you depending on your age and where you are from. For more information about our policies for children’s personal information, please see Section 7.|
|Advertising IDs, Location Information, and Device Information Analytics||Analytics – for more information, please see Section 4.
Advertising – for more information, please see Section 6.
|Name and email address, Location Information, Device Information||You have the option to contact our customer support team directly from some of our Games. When you do, we will collect and use this information to respond to your requests and/or comments.|
|Name, email address, and/or phone number||If you contact our customer team, whether via email or by filling out a contact form on the Websites, we will collect and use this information to respond to your requests and/or comments.|
|Location Information, and Device Information Analytics||Analytics – for more information, please see Section 5.|
2. Does Toosmart Collect My Financial Information When I Make In-App Purchases?
When you make in-app purchases in the Games, we do not collect or have any access to your name and billing information. This information is collected and stored by your platform (e.g. Apple’s Game Store or Android’s Google Play) or your platform’s payment processor.
3. Do third parties have access to my personal information?
Yes. Like most companies, we use tools from service providers to help us with various parts of our business ("Service Providers"), and depending on the service we need, these Service Providers may have access to your personal information. For example, we use Service Providers for hosting content and mobile and web analytics. The Service providers Toosmart is using are; CDN77, Google Firebase, Google Analytics, IPTrans (Hosting), Google Play, Apple Store.
We contractually require all Service Providers to treat your personal information as confidential information and to only use it for the services we need. However, we do not have direct control over how Service Providers use your personal information and we cannot guarantee that our Service Providers will use your personal information as required in our contract with them. For this reason, we are not responsible for our Service Providers’ misuse of your personal information.
In addition to our Service Providers, our Ad Partners may also have access to your personal information. We’ve a separate section about advertising and our Ad Partners, so please check that out in Section 6. We may also share your personal information for our legitimate business and legal purposes as described in Section 12.
4. How long will Toosmart keep my personal information?
How long we store your personal information will depend on the purpose that we originally collected it. We will not retain personal information for longer than is necessary for our business or for legal requirements.
5. How is my personal information used for analytics?
As an online business, it is important for us to know how users interact with our Websites and Games. We and our Service Providers will collect your Location Information, Device Information, and Advertising IDs so that we can deliver our Game and Website services to our users, measure, analyze, and improve performance of the Games and Websites, and to continually update and develop our Games and Websites. For example, we will use this information to assess the difficulty level of Games, fix any bugs or errors in the Games, evaluate the demographic of our users, and to determine whether or not we need to support a new Device type for the Games.
6. How is my personal information used for advertising?
A. Ad Partner Technologies
To help us keep our Games running, we show ads in our Games with the help of third-party advertising partners ("Ad Partners"). We integrate Ad Partners’ technologies into our Games which are then used by the Ad Partners to determine what kind of ads to display to you.
i. Do Ad Partners Collect My Personal Information?
In order to show you ads that you might interesting and/or relevant ("Targeted Ads"), Ad Partners collect and use your Advertising ID, Location Information, and Device Information. If location services are enabled in your Device settings, the Ad Partners may additionally collect your geolocation information. Because these Ad Partners’ technologies control what kind of personal information is collected from your Device and how it is used, we encourage you to review their respective privacy policies. Our Ad Partners are: Admob, Chartboost, AppLovin, AdinCube, Mopub, Vungle, AerServ, UnityAds, Amazon, Tapjoy.
ii. How to Opt-Out of Receiving Targeted Ads.
If you do not want to receive Targeted Ads on your mobile Device, your mobile Device may give you the option to opt-out of receiving Targeted Ads on all apps on your Device. On Android Devices, you may opt-out by enabling the “Opt out of Ads Personalization” setting. On iOS Devices, you may opt-out by enabling the “Limit Ad Tracking” setting. In addition, you may be able to opt-out of receiving Targeted Ads from a specific Ad Partner. Please review our Ad Partner list found here to see if an Ad Partner offers the ability to opt-out of receiving Targeted Ads. Please note that if you opt-out of receiving Targeted Ads, you will still receive contextual ads, which are non-targeted ads related to the content of the Game you are playing.
B. Ads for the Games on Third-Party Websites and/or Apps
In addition to running ads in our Games, we also run ads to promote our Games in third-party websites and/or apps. When we run our own ads in third-party websites and/or apps, Service Providers help us optimize and measure performance of our ads and use their own tracking technologies to track Game installs and clicks and/or impressions of our ads. In some cases, we will share your hashed or anonymized Advertising ID with our Ad Partners so that the Ad Partner can help us market and promote our Games. In these cases, Ad Partners perform as Toosmart's Service Providers and we contractually require such Ad Partners to only use your personal information on our behalf. If you wish to opt-out of your personal information being shared with Ad Partners in this way, please contact us at [email protected]
7. Children’s personal information.
We do not knowingly collect children’s personal information without parental consent, except as permitted under applicable laws such as the U.S. Children’s Online Privacy Protection Act (COPPA) and the EU General Data Protection Regulation (GDPR). For example, Toosmart, its Service Providers, and its Ad Partners may collect personal information, such as IP addresses and other persistent identifiers, from children under 16 strictly to support Toosmart’s internal operations and/or legitimate interests, such as analytics and to serve children with contextual ads. If you are a parent of a child playing the Games or using the Websites, you may review or have your child’s personal information deleted and refuse the further collection of his/her personal information by contacting us at [email protected] Please contact us at [email protected] if you believe we are collecting a child’s personal information in violation of COPPA or the GDPR and we will delete this information as quickly as possible. For a list of Toosmart's Service Providers, please see section 3.
Toosmart will retain your child's information for as long as your child's account is active (if the app is using an account), or as needed to provide services. If you wish to cancel your child's account or request that Toosmart no longer use the information to provide services, contact Toosmart at the email address listed below. Toosmart will retain and use the information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
8. Cookies and similar tracking technologies.
9. Third-parties and their privacy policies.
Throughout the Websites, you may see links to third-party websites or applications. We are not responsible for the privacy practices of these third-party sites, and when accessing their sites, we encourage you to read their privacy policies.
10. Is my personal information secure?
The security of your personal information is important to us. We follow generally accepted industry standards to protect your information, both during transmission and once it is received. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. While no security system is completely secure, we and our Service Provider stake appropriate security measures to protect against unauthorized access or disclosure of the information collected by us. For Toosmart, this includes, but is not limited to, ensuring that all of your information is disclosed only on a "need to know" basis and ensuring that all information collected by Toosmart is done so via secured connections and protected and encrypted (using secure socket layer technology,"SSL") by industrial grade security software to guard against unauthorized access.
11. Push notifications.
After downloading a Game, some apps will show push notifications. We don't collect any data of the notifications. You may disable push notifications at any time by going to your Device settings.
12. Social media features and tools.
The Websites and Games may include integrated social media features and tools, such as a general share button. We don't integrate any social media platform into our apps or websites. We don't use or share any data with social media sites like Facebook or YouTube.
13. Sharing your personal information for business/legal reasons.
14. How do i access, manage, or update my personal information?
For all other Games, please contact us at [email protected]
15. For users in the european union.
A. Legal Basis for Processing. Our legal basis for collecting, using, and sharing your personal information will depend on the purpose for which we use your personal information. Typically, we will rely on the following legal bases for processing your personal information: (i) your consent; (ii) where our processing is in our legitimate interest (e.g. processing for analytics or direct marketing) or in the legitimate interest of our Ad Partners or Service Providers; or (iii) where our processing is necessary to perform a contract with you (e.g. to make the Games or Websites accessible to you). If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
B. Your Personal Information Rights. If you would like to exercise your rights of access, rectification, erasure, restriction of processing, data portability, and/or your right to object to the processing of your personal information, please follow the instructions described in Section 14. If you would like to opt-out of your personal information being shared with our Ad Partners, please follow the instructions in Section 6(A)(ii).
C. Transfer of Personal Information Outside of the EU. Because our Service Providers are located in countries outside of the European Union, your personal information will be transferred to other countries that may not offer the same level of data protection as the laws of your country of residence. We rely on model contractual clauses and/or the Privacy Shield certification for such transfers.
D. How to File Complaints. If you believe your rights under the GDPR have been violated, you may lodge a complaint with the supervisory authority of your country of residence.