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Privacy Policy

Tota Game Limited Privacy Policy


Tota Game Limited ("we" and “Tota Game Studio”) are committed to protecting your Personal Data. We offer services and games that can collect information from you and your children, so we have prepared a document called the Privacy Policy. In this Privacy Policy, we will explain what we do with the Personal Data that you provide to us or which we can collect from you in the provision of services to you.

This Privacy Policy is in compliance with the US Childrens Online Privacy Protection Act (COPPA) and the European General Data Protection Regulation (GDPR).


WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

While you play Tota games ("Services" or "Games"), we may collect information about you ("Personal Data").

We care about your Personal Data protection, so we have developed this Privacy Policy.

By this Privacy Policy, we want to clearly and comprehensibly explain what data we collect, how we use, disclose and transfer it.

From time to time, we may change the terms of this Privacy Policy, so do not forget to read this Privacy Policy on a regular basis to understand how we use your Personal Data.


WHAT PERSONAL DATA WE COLLECT?

Personal Data refers to any information about a person which can identify that person.

We may collect, use, store and transfer various Personal Data we have grouped into these categories:

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.

 

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 another companies and persons (see section Our third-party data controllers and processors).

 

HOW WE USE PERSONAL DATA?

We will only use your Personal Data as permitted by law. Usually, we will use your Personal Data in the following circumstances:

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 childs parent or guardians email when we must obtain the consent of parents or guardians to use the childs 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.

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 re-marketing, profiling and automated decision making.

 

Tota Game SUBSCRIPTION

If you want to get a subscription to selected Tota Game, we need to identify you by creating a subscribers account. In order to get access to Tota Game subscription, a childs parent or guardian is required to agree to our Terms of Use and Privacy Policy as well as login by choosing a preferable login method (Google or Apple).

If you decide to get Tota Game subscription, we collect and use personal data about chosen login method, email address, current subscription plan, billing, connected devices, unique ID, advertisement ID and device ID.

We will use this data only to authenticate a user and manage users subscription (e.g. to determine on how many devices subscription has been activated). We process your personal data ourselves, therefore personal information is not disclosed to any third party.

With your actively given consent, we may email you and ask for the feedback about Tota Game subscription experience. We will not use your email for any advertising purposes. You can always withdraw your consent by signing in to your subscription account and opting-out.

Please note that you have the right to cancel your subscription anytime, however your personal data collected before subscription cancellation will be stored in order to comply with our legal obligations.

 

WHO MAY ACCESS YOUR PERSONAL DATA

We may share your personal information with a few selected third parties, such as:

  • Companies of our group, third-party service providers and other partners (e.g. to ensure the provision of our Services, to provide services or to improve our Services security), as well as to those who otherwise process Personal Data for the purposes specified in this Privacy Policy. Here is a list of our current service providers and partners (see section Our third-party data controllers and processors).

  • To any competent law enforcement authority, regulatory authority, government agency, court, or other third party, if we consider that disclosure is necessary (i) in accordance with applicable laws or regulations, (ii) to exercise or to protect our rights, or (iii) to protect our or any other persons interests

  • A potential or actual buyer (and its representatives and advisers) involved in the purchase, merger or acquisition of a proposed or actual any part of our business, provided that we inform the buyer that it will have to use your Personal Data only for the purposes specified in this Privacy Policy;

  • Any other person with your consent to disclose information.

 

OUR THIRD-PARTY DATA CONTROLLERS AND PROCESSORS

Kidoz

KIDOZ is an advertising service provided by KIDOZ Ltd. KIDOZ uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

Processing location: USA
Privacy policy: https://kidoz.net/website-and-kidoz-sdk-privacy-policy
Address: KIDOZ, PO BOX 8517, Poleg Industrial park, Netanya, Israel
Phone: +972-9-7716444
Contact: support@kidoz.com

Chartboost (Chartboost, Inc.)

Chartboost is an advertising service provided by Chartboost, Inc. Chartboost 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://answers.chartboost.com/en-us/articles/200780269
Address: 85 2nd Street, Suite 100, San Francisco, CA 94105, US
Contact: privacy@chartboost.com

Flurry, Inc.
Flurry Inc. is an analytics service provided by Oath (Americas) Inc. Flurry 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.oath.com/us/en/oath/privacy/

  • Address: 701      First Avenue Sunnyvale, CA 94089, US

  • Contact:      support@flurry.com

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: US

  • Privacy      Policy: https://policies.google.com/privacy?hl=en

  • Address: 1600      Amphitheatre Pkwy, Mountain View, California 94043, US

  • Phone:      650-253-0000

AdMob by Google (Google Inc.)
AdMob is a mobile advertising platform which allows developers to monetize their app(s) by displaying in-app ads from other advertisers. AdMob allows to set TFUA (Tag for Users under the Age of Consent in Europe) on ad requests. All ad requests that include TFUA disables ads personalization for users under the age of consent and collection of data by third party partners. Admob 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, USA.

  • Contact:      https://support.google.com/policies/troubleshooter/7575787?visit_id=636888632405295138-51672301&hl=en&rd=2

IronSource Mobile Ltd.

ironSource Mobile Ltd. is a network that connects app developers with advertisers, and helps app developers to serve ads on their apps, a mediation platform that helps app developers to manage all the ad providers with which they have a direct relationship and a marketing platform that helps advertisers to create and optimize advertising campaigns. ironSouce 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://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

  • Address: 121      Menachem Begin Rd., Tel Aviv, Israel

  • Contact:      dpo@ironsrc.com

Vungle Limited

Vungle is an ad network providing a technology platform for clients that want to advertise and/or monetize their applications, games, and other products. Vungle 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://vungle.com/privacy/#section-1

  • Address:      Clover House, 147-149 Farringdon Road, London, England, EC1R 3AB

  • Contact:      privacy@vungle.com

AdColony, Inc.

AdColony is an advertising service provided by AdColony, Inc. AdColony uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

  • Privacy      Policy: https://www.adcolony.com/privacy-policy/

  • Address:      11400 W. Olympic Blvd, 12th Floor Los Angeles, CA 90064

  • Contact:      privacy@adcolony.com

Unity Technologies ApS.

Unity Ads is an advertising service provided by Unity Technologies ApS. Unity Ads uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

  • Privacy      Policy: https://unity3d.com/legal/privacy-policy

  • Address:      Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland

  • Contact:      DPO@unity3d.com

Unity Analytics (Unity Technologies)

Unity Analytics is a data platform that provides analytics. Unity Analytics uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

  • Privacy      Policy: https://unity3d.com/legal/privacy-policy

  • Address: 30      3rd Street, San Francisco, CA 94103, United States

  • Contact:      DPO@unity3d.com

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, USA.

  • Contact:      https://firebase.google.com/support/troubleshooter/contact/

AppLovin Corporation

AppLovin is an advertising service provided by AppLovin Corporation, a Delaware corporation. AppLovin uses Personal and Non-Personal Data only for internal purposes.

Legal basis of processing: legitimate interests (support for internal operations).

  • Privacy      policy: https://www.applovin.com/terms/

  • Address: 849      High St., Palo Alto, California, 94301, United States

  • Contact: care@applovin.com

Mintegral

Mintegral is an advertising service provided by Mintegral Corporation, a Delaware corporation. Mintegral uses Personal and Non-Personal Data only for internal purposes.

Pangleglobal

Pangleglobal is an advertising service provided by Pangleglobal Corporation, a Delaware corporation. Pangleglobal uses Personal and Non-Personal Data only for internal purposes.

Facebook(Meta)

Meta is an advertising service provided by Meta Corporation, a Delaware corporation. Meta uses Personal and Non-Personal Data only for internal purposes.

 

HOW WE PROTECT YOUR PERSONAL INFORMATION?

We have implemented security measures to ensure that your Personal Data is not lost, used or accessed without authorization, altered or disclosed. We restrict access to your Personal Data to those employees, representatives and other third parties who need to know your details. They will process your Personal Data in accordance with our instructions and will be subject to the confidentiality obligation.

We have put in place procedures to combat any alleged breach of Personal Data security and we will inform you and all authorities of the breaches that we are required to notify about.


HOW LONG WILL WE USE YOUR PERSONAL DATA?

We will only store your Personal Data to the extent required by the purposes of this Privacy Policy and to meet any legal, accounting or reporting requirements.

In order to determine the appropriate period of Personal Data storage, we will assess the amount, nature and sensitivity of Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve these objectives by other means and applicable legal requirements.

 

HOW TO CONTACT US?

 You can contact us at any time with any of your Personal Data protection issues at:

 

Tota Game LIMITED

Email: totagamestudio@gmail.com

 

We will respond to all your requests within the shortest possible time.

 

 

 

 

 


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