(Last updated on 23th Jan 2019)
1. What information do we collect from you?
We may collect and process the following data about you:
Personally Identifiable Information: This refers to information that let us know the specifics of who you are. When you engage in certain activities in the Website or Services, such as registering a user account, downloading and installing Application(s), playing Game(s), purchasing Virtual Money or Virtual Goods, sending and/or posting a user Content, or sending us feedback, we may ask you to provide certain information about yourself. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information. Such information may include your first and last name, mailing address, e-mail address, telephone number, credit card or other payment information.
Usage Information: We collect details of your use of our Services and the resources that you access. Such usage information include information about how and when you access or use our Services (such as Games accessed, game score, pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your game play).
Interaction and Communications among Users: We collection information about (a) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (b) your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).
Technical Information: We collect general technical data pertaining to you (such as information about the device you use to access our Services, IP address, operating system, browser type, and other system information, Device identifier, Locale);
User Communication with Togglegear. If you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence.
Such public posting or shared content will be visible to anyone who has access to our Services and may also be viewable outside of our Websites or Services. You should exercise caution in all public postings, as it may result in the disclosure of private information, for which Togglegear is not responsible.
Information for Third Party Social Networks or Platforms: You may allow our Services to interact with a third party social network and platform, which will provide data about you to us. If you choose to connect to one of our Websites/Apps through a third-party social network such as Facebook or Game Center (for iOS devices), we may collect personal information from your profile on such third-party social networks, such as your name, username, and photograph. You should ensure that you read their terms of service and privacy policies to understand how they treat your data and what data they might share with us.
Payment: When you purchase any products or services, such as Virtual Money or Virtual Goods, through our Services (which called “In-app-purchase”), we may collect certain payment information from you on behalf of our payment service providers. When you purchase our products or services through third party platforms (such as Apple App Store, Google Play Store, or Amazon Kindle), you will be required to provide certain payment and billing information directly to such third party platforms, and we do not collect or store any payment information from you.
Friends Matching: If you log-in the Services, we may, upon your request, periodically access your contact list and/or address book on your mobile device in order to help you find any friends who may also have our Services. We will use such contact information solely for such a friends-matching service, and we will not store such information after fulfilling this purpose.
Telephone Number/ Technical & Usage Information: When you access and/or use the Services, we may collect your telephone number as well as your technical and usage information through automated means.
Customer Support Correspondence: When you ask our customer support team for assistance, we may collect and store from you the contact information as well as your payment information regarding the purchase of Virtual Goods of the Games to the extent reasonably necessary to provide customer support.
2. How do we use the information collected?
We may use the information collected from you for a variety of purposes, primarily, relating to providing our Services and information about our Services. We may also use the information for such other purpose as otherwise allowed by law.
For example, we (or a supplier or our affiliate company acting on our behalf and only under our instructions) may use your personal information, including personally identifiable information, for the purposes of:
(a) contacting you (for example as part of customer service or to send you updates about our Services);
(b) managing your account and relationship with us and improving your experience when you use our Services;
(c) researching or surveying, and asking you to participate in such research or survey, about our product or Services;
(d) marketing and promotion of our Services or related products, including those of a third party’s products which are related to our Services (If you do not want us to use your data in this way please let us know by contacting us through Customer Center which can be found within our Services);
(e) sending you, on our, or a third party's behalf, offers, promotions, information, newsletters, and communication regarding our Services or products and merchandises relating to our Services;
(f) creating reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services;
(g) measuring and analyzing effectiveness of advertising, including advertising of third parties placed within the Services;
(h) monitoring the Services, including the Website, Games, Applications, and networks, and operation thereof;
(i) resolving disputes or issues;
(j) tracking purchases and usage information;
(k) preventing cheating, crime or fraud; and
(l) any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Services, or to comply with requirements of any applicable law.
When you use our Websites we will store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data file, which a website stores on your computer or mobile device that can later be retrieved to identify you to us.
(a) allow us to recognize you and your device, for example by identifying your IP address,
(b) allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
(c) allow our payment processors to process your payment instructions;
(d) provide you with more customized Services, for example to provide our Services in your preferred language; or
(e) obtain data which will allow us to understand how people are using our Services so that we can improve them.
We may use an outside ad serving company to display banner advertisements on our Websites or within our Services. As part of their service, they will place a separate cookie on your computer. We and our third party ad server will collect and use non-personally identifiable information about you, such as your IP address, browser type, device information (such as device type, resolution, operating system, etc.), the server your computer is logged onto, the area code and zip code associated with your server and whether you responded to a particular ad. In addition, we may install third party modules within the smartphone versions of the service application in order to measure the effectiveness of advertising, including advertising of third parties, placed within the Services.
These modules may collect your Advertising Identifiers (IDFA), and the collected information will not be tied to any other information nor be used to identify each individual. Advertising Identifier (IDFA) is a non-permanent, non-personalized identifier similar to that of Android advertising ID and Apple’s Advertising ID. You can change the settings on your device so that the device’s IDFA may not be used to better fit advertisements geared towards you or reset your device’s IDFA. These settings will vary by device, but you can access these settings for most iOS devices by going to [Settings -> Privacy -> Advertising]. As for most Android devices, access [Settings -> Google -> Ads] or [Settings -> Accounts -> Google -> Personal info & privacy -> Ads Settings].
4. With whom do we share your information?
Generally: We do provide some of our Services through contractual arrangement with affiliates, services providers, and other third parties. We and our service partners use your personal information, including personally identifiable information, to operate our Websites and to deliver their services.
We will share your personal information with such third parties for all purposes described in Section entitled “How do we use the information collected?” and also:
(a) as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to other companies or individuals we hire to perform the Services on our behalf or to communicate with you);
(b) where it is necessary to carry out your instructions (for example, to process a payment instruction, we must provide your personal information to our payment processors);
(c) when you submit information as part of a competition or otherwise interact with our social media channels (for example, by providing a testimonial about one of our Services), we may publish the information you submitted, alongside your name and home country on our websites and social media channels;
(d) in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you;
(e) to protect the rights, property, or safety of us, our users, or others; or
(f) as we reasonably believe is permitted by law or regulation.
We will encourage our service partners to adopt and post privacy policies. However, the use of your personally identifiable information by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.
Sharing of Non-Personally Identifiable Information: We may also provide non-personally identifiable information about users (where your data is on an anonymous and aggregated basis) to third party companies, including but not limited to third party advertisers, consultants, service providers and our affiliates. Such data will not include any information by which you could be personally identified.
Interactions with Third Party Social Networks or Platforms: You understand that where you allow your account with us to interact with any third party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy playing socially. This data includes your name, your social media profile, picture and your scores and/or progress in our Games.
Compliance with Legal Obligations: Occasionally we may be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities. We will disclose personally identifiable information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
5. How do we keep your information secure?
The security of your personal information is important to us. We maintain appropriate technical and physical safeguards to protect your personal information against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access, use and all other unlawful forms of processing of the data in our possession. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.
(a) We encrypt many of our services using RSA and DES which are most common encryption technologies;
(b) We restrict access to personal information to our company’s employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Your personal information may be transferred to, and stored at, a destination outside of your country or jurisdiction. It may also be processed by personnel of our affiliates and third party service provider who may operate outside of your country or jurisdiction. In such case, we will take reasonable steps to require such third party in possession of your personal information to take commercially reasonable security measures to protect the information.
However, unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, you acknowledge that: (a) the security, integrity and privacy of any and all information and data exchanged between you and us through our Services cannot be guaranteed; and (b) any such information and data may be viewed or tampered with in transit by a third party.
6. How can you update, correct or delete your personally identifiable information?
Information We Receive From SNS : Information that you have shared via our Services on any social network or third party platform cannot be amended or deleted by us where it is in the control of that social network or third party platform. In addition, where any third party copies information which you have made available via the use of our Services (for example, one of your friends on a social network you allow to interact with your account), we may not be able to amend or delete it because it may not be in our control.
Deleting Account: If you choose to terminate or delete your Togglegear Account, we will immediately delete your Togglegear Account information. Even after your Account is terminated or deleted some or all of your information may still remain visible to others, including but not limited to any information that has been incorporated into any User Contents or copied, stored or disseminated by you or other users.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please submit your request in writing at Customer Center in our Services.
We want to make sure that your personal information is accurate and up to date. You may ask us to modify, correct or remove information by contacting us at [firstname.lastname@example.org]. You may also update your account information by logging into your account.
7. What are your choices regarding collection, use and distribution of your information?
You have the right to ask us not to use your personal information for marketing purposes. To change your marketing preferences, or to unsubscribe, please contact us at Customer Center in our Services.
You have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Services may not work properly.
You can also make changes to what data a third party social network or platform shares with us, or stop our Services interacting with that social network or platform by adjusting your settings with that third party provider, however you may find you are not able to enjoy all of the same features of our Services.
8. What should you know about privacy policies and data collection at any third party sites accessible from our Websites?
9. How long do we retain your personal information?
10. Our Policy Concerning Children
While the Websites/Apps may be visited and/or played by children, we do not knowingly collect or use any personal information from children under the age of children (by each Nations) and hereby specifically prohibit any user under the age of children from providing us with any personal information. If you are a parent of a child and you believe your child has provided us with personal information, please contact us at [email@example.com] and we will delete the information from our system.
11. Modification to This Policy
12. International Transfer
All personal information that the company collects to provide the service is stored and transferred to a data center in [United States] using secure cryptographic communication at the collection stage. The company has implemented the appropriate technical and organizational security standards.
13. Your California Privacy Rights
California residents have the right to receive (a) information identifying any third party company to whom Togglegear may have disclosed (within the previous calendar year) his/her personal information for that company’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, please send a request email to [firstname.lastname@example.org].
14. EU Data Protection Rights
The personal information of users in the EU domain is only collected the minimum required information to execute the game and provide service contract, and the other information is collected with the consent of the information subject.
You have the right to oppose the way of personal information processing provided by Togglegear, or to request transfer to wherever you want, if technically possible.
Residents of EU Member States may contact [email@example.com] for any unreasonable treatment that exceeds the time limit required by law, also you can request judicial relief to the authorities.