Most of the information that we collect about the user comes directly from him or her when he or she plays our games, interacts with our websites, advertising or other Services. Broadly the information we collect about the user relates to the type of device he or she is using, how he or she plays our games (such as levels attempted and purchases made) and may include information that he or she submits when creating an account with us or which he or she allows us to access when he or she connects to his or her social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
In more detail, depending on which of our Services you (as the user) interact with, we may collect and process the following types of information:
If the user chooses not to create a Tio Toys profile by connecting your social media account, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:
In some instances, when you make purchases on or through our website(s), we may collect certain payment information from you on behalf of our payment service providers, but this information is temporarily cached in a way that is unreadable by Tio Toys. We do not collect or retain credit card information. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful.
When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.
Occasionally we may ask you for your consent to collect other information from you or your device. In this or a similar circumstance, we will tell you what information we would like to collect, why we need it, and what we’ll use it for.
We, our suppliers and group companies, may use this information:
We may also share your information with third party publishers who develop and provide games and other Services to you on our behalf.
We also analyze and use the information that we collect on an anonymized or aggregated basis for new product development, to analyze the performance of our games, to troubleshoot and to improve and optimize the games to ensure the best player experience for our players as a whole.
1.1 Providing and optimizing our Services
We use your information to enable us to provide our websites, advertising, and other Services to the user, and to optimize all of them so that we can make them the best they can be for all of our users. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.
Some of our Services could eventually include chat functionality. Users of our chat service(s) can send messages to other players, to Tio Toys customer services or publicly on our forums. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history. We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
1.3 Customer Services
We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
1.4 Analytics and Research
1.5 Social and Community
We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
1.6 Promotions and Competitions
When you visit our other websites, such as https://www.tiotoys.com and other websites and forums operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimizing the Websites, in connection with our advertising purposes, and for research or analysis.
The information we collect and process about you when you visit our Websites includes:
We, our suppliers and group companies, may use this information:
When using the comment section on our Tio Toys site, please be aware that in addition to your user name, any questions, answers, comments or submissions that you post will be publicly available and any data you provide can be read and/or used by other users. You should therefore only share content that you are comfortable sharing publicly.
3.1 Tio Toys Profile
When you play our games, we will give you a randomly generated unique identifier which we will associate with a Tio Toys account known as a “Tio Toys profile”. Your Tio Toys profile will not be personally identifiable unless you choose to add your personal information to it by linking the profile to a third-party account.
3.2 Connecting with a third party network
Where we make this available, you can choose to log in to your Tio Toys Profile using your account details with a third party network, such as Facebook or Google. If you do this, you will be able to use your game to log in on multiple devices and synchronize progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other features we make available in our games and other Services, such as inviting friends to play, asking other players for lives, and bonuses or benefits of various kinds.
3.3 Information we receive from Facebook
If you log in to your Tio Toys profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your Tio Toys profile. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country and any other public information.
We may also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can opt out of this at the time at which you associate your Facebook account with your Tio Toys Profile and also later in your Facebook privacy settings.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this in your Facebook settings.
3.4 Information we receive from Google
If you log in to your Tio Toys profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture. If you choose to grant us access to your Contact List, we will use and store this to help you find those of your Google contacts that are already playing our games.
You can revoke future access to your information at any time by following the steps at https://support.google.com/accounts/answer/112802?hl=en.
We use information we collect about you to send you marketing communications about other Tio Toys and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and internet-connected devices. This section also explains how you can opt out of this.
We may use the information we maintain about you to promote Tio Toys services in a variety of ways. This could include:
4.1 What information do we use for marketing?
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:
4.2 Marketing partners
When we market our games in media published by other companies, we use various third party marketing partners to assist us on our behalf.
Our marketing partners help us to serve ads to you by using data which they have collected about you. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Tio Toys’ games or Services, they will serve you with a Tio Toys ad.
You can disable interest-based advertising by Tio Toys or any other company by following the steps at How to adjust your preferences for interest based advertising.
4.3 Opting-out of direct marketing from Tio Toys
You can exercise choices over the direct marketing we send you in the following ways:
You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for Tio Toys products, but that advertising will not be targeted using your personal information.
Our games may include advertising for third party products and services. Unless you opt out of interest-based advertising, we and our advertising partners will use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games.
We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services.
5.1 What information is used for advertising?
5.2 Advertising partners
When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
5.3 Opting-out of interest-based advertising
You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device. For more information, see How to adjust your preferences for interest based advertising below.
Please note that if you opt out of interest based advertising, you may still see advertising in our games but those ads will not be targeted using information that we hold about you. However, they may still be delivered based on contextual criteria such as the game that ad is to be displayed in, or the region in which your device is located.
To provide our games and interest-based advertising, we use ad identifiers and similar technologies. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
6.1 How do ad identifiers and similar technologies work?
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
6.2 How to adjust your preferences for interest-based advertising
You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings.
If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.
Notice: adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests.
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know at email@example.com and we will correct it as soon as we can.
In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, and your high scores may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a Wi-Fi network.
If you have created a Tio Toys account, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as currency or powerups will be lost and we may not be able to restore them in the future.
In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).
If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
You must be over a certain age to play our games and use our Services, depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.
The table below sets out what age you must be to play our games and use our Services, depending on what country you are in while using our games and Services. Our games are intended to be played by adults and we do not knowingly collect, and do not wish to collect, information about children. Please do not play our games or use our Services if you are under the relevant age.
|Country||Age you must be to play our games and use our Services|
|Republic of Cyprus||13|
|Rest of the world (excluding Korea)||13|
If you believe that we might have any information from or about a child under the relevant age set out above, please Contact Us (see the Contact Section in this statement). In the event that we learn that we have collected personal information from a child under the relevant age set out above, we will delete that information as quickly as possible.
We may also share your information with our service providers if necessary to enable them to provide services to us.
Tio Toys takes appropriate security and technical measures to protect your information from unauthorized access, loss, and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
9.3 Legal Bases
In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law. The legal bases which we rely upon are the following:
This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;
This covers data used by us to comply with a legal obligation, such as the prevention of crime or fraud or to maintain records relating to tax;
This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics and research and optimization of our games and other Services; and
Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent.
9.4 Data Retention
9.5 Location of storage
We store your information on servers that we control which are primarily based in the EEA. We may also use servers and engage providers that are located outside the EEA in order to process and store your information and to provide services to us.
9.6 International Transfer
We may transfer your information to affiliated entities or third parties to jurisdictions outside the EEA. Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU model clauses) to allow the transfer of your information across borders outside of the EEA.
By email to: firstname.lastname@example.org
In writing to: Tio Toys SRL, via Pola 4, 09123, Cagliari, Italia