Welcome to Turtle &
Sons, a mobile video game company. This Privacy Policy explains our privacy
commitment to our players (hereinafter ÒUsersÓ). At Turtle & Sons we
collect personal data to support our products and services, while respecting
regulation (EU) 2016/679 of the European Parliament and of the Council of 27
April 2016, directly applicable from May, 25th, 2018 (hereinafter, ÒGeneral
Data Protection RegulationÓ, or ÒGDPRÓ). According to GDPR, Òpersonal dataÓ
means any information relating to an identified or identifiable natural person,
directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person. By using Turtle
& SonsÕ services, you authorize Turtle & Sons and its affiliated companies
to process your personal data according to this Privacy Policy. If you do not
accept the terms of this Privacy Policy, please refrain from using our online
games or our gamesÕ online functionalities, our websites, our mobile apps and
any other online Turtle & Sons products and services (hereinafter
ÒServicesÓ). In accordance with this Privacy Policy, the Data controller is
Turtle & Sons, with its headquarters at 50 Portland Street, Toronto,
Canada.
Table of contents :
1. When does Turtle & Sons collect your personal information?
2. What personal information does Turtle & Sons collect?
3. How does Turtle & Sons use my personal data ?
4. For how long does Turtle & Sons keep my personal data ?
5. With whom does Turtle & Sons share my personal data ?
6. Does Turtle & Sons make my personal information public ? Who can see my personal information ?
7. Minors
8. What are my rights ?
9. Privacy Policy changes
10. Contacts
Turtle & Sons
collects and processes your personal information at different times when you
interact with our Services. Generally, personal information is collected when:
(a) you use a Service,
(b) you create an Account,
(c) you make a purchase within our Services,
(d) you create user generated content,
(e) you watch advertisements within our Services,
(f) you sign up for a newsletter,
(g) you contact Turtle & Sons customer service and during technical support sessions,
(h) you enter into a contest or sweepstakes,
(i) you chat with other users of the Services,
(j) you participate in a beta or otherwise download a patch or a demo, or
(k) you share or otherwise contribute to our social media channels or other community websites.
Whatever the activity
may be, and in accordance with the minimization principle stated in the GDPR,
we will only collect personal information to the extent necessary to provide
you with the Services and fulfil your requests.
2.1.1 While Browsing Turtle
& Sons websites
Cookies. Turtle & Sons uses
cookies on the Services. A "cookie" is a small bit of record-keeping
information that web sites often store on a user's computer. Cookies are not
intended to include people's names, or other information that is directly
identifiable; rather, they are typically used to quickly identify a user's
device and to "remember" things about the user's visit. Turtle &
Sons may set cookies for your web browser as you visit our websites, use our
products, or visit a website where Turtle & Sons provides ads, content or
analytics. For example, Turtle & Sons uses cookies to keep track of
selected items in your shopping cart on our online store, and to remember your
Account identifier. You can disable cookies or set your browser to alert you
when cookies are being sent to your computer, although this may affect your
ability to shop online or to access certain features of our Services. Each
browser is different, so check the "Help" resources for your web browser
to learn how to change your cookie preferences. In addition to Turtle &
Sons using cookies on our network of websites, Turtle & Sons may allow
certain partners to set and access their cookies on your computer. These
companiesÕ use of cookies is subject to their own privacy policies, not the
Turtle & Sons Privacy Policy. Please review them carefully. For more
information about cookies, please see http://www.allaboutcookies.org.
IP addresses. Turtle & Sons also
collects Internet Protocol (IP) addresses for safety and security reasons. An
IP address is a number that is used by computers on the network to identify
your computer every time you log on to the Internet.
Other passively collected information. While
browsing our sites, Turtle & Sons may, on its own, or with the help of
third party tools, collect non-personally identifiable information concerning
your gaming hardware, habits, behaviors and use of our Services. Turtle &
Sons collects such information to better adapt our Services to usersÕ
interests, and for a better quality of our Services. The information collected
may contain the following, without limitation: device unique identity,
including MAC address, console, mobile, tablet and console unique identifier or
other device identifiers and settings, internet provider, carrier, operating
system, hardware information, localization information, date and time spent on
the Services, game scores, game metrics, achievements, rankings, time played
and statistics, feature usage, advertising conversion rates, monetization rate,
purchase history and other similar information.
2.1.2 Registering on a Turtle
& Sons service
To access certain
Services, you will need a Turtle & Sons Account. During the creation of
your Account, we will ask your user name, password, email address, date of
birth (or age) and country of origin. This information is mandatory to create
an Account. On other Services, Turtle & Sons may ask you additional
personal information relevant to the Service such as your phone number, home
address, or geo-location information (for example, you will be asked your home
address when purchasing a product within our online shop, in order for Turtle
& Sons to deliver the product to your home address).
2.1.3 Creating a Turtle & Sons account
By creating a Turtle
& Sons Account, you agree to receive newsletter or adverts about Turtle
& Sons products, services, and sales. You can unsubscribe at any time by
clicking the unsubscribe link contained in all Turtle & Sons email
marketing messages;
To access certain Services,
you will need to give your consent to allow Turtle & Sons to share some of your personal
data with third parties, such as companies or organizations, which provide
services and products you may be interested in.
2.1.4 Contacting Turtle
& Sons
Turtle & Sons may
ask for your first name, family name, e-mail address and your date of birth to
answer your demands to Turtle & Sons, to confirm any information or
transaction on your Turtle & Sons account, and to give you information
regarding the Services (for instance, if you lose your password or if we make
changes to the Terms of Use).
2.1.5 Participating to contests and sweepstakes
Turtle & Sons may
offer you the opportunity to participate in online surveys, questionnaires,
contests and sweepstakes. To participate, you may need to provide your first
name, your family name, e-mail address, date of birth, your address and country
of residence. If you choose to participate in contests, sweepstakes, surveys
and questionnaires, your personal data may be processed to allow you to
participate, or to inform you of sales on a specific product, or to give you
some information about new products or services, and for internal statistical
use.
2.1.6 Interacting on forums
Whenever you participate
or interact with other users on a forum, Turtle & Sons collects the content
of your communications, the time and the location of your activities, as well
as your online ID and your IP address.
2.1.7 Adverts
Turtle & Sons uses
third party ad-serving technologies that may collect information as a result of
ad serving in the Services. These third parties may display behavioural and
non-behavioural advertisements on our Services. The information collected and
used for the targeted advertising may contain the following, without
limitation: age and gender, number of views of an advertisement, device unique
identifier or other device identifiers and settings, information about your use
of the products and Services, other sites (including third party web pages and
mobile Internet sites) you have viewed (as well as date and time viewed),
advertisement(s) served, the advertisement(s)Õ in-game location and length, and
your response to the advertisement(s) (if any). The analytics tools and ad
serving technologies may use server log files, web beacons, cookies, tracking
pixels and other technologies to collect this information, and may combine the
information collected on other Turtle & Sons Services with information
collected from other third party websites, products and services and with
demographic, advertisement, market and other analytics surveys. Standing alone,
this information is not personal data; however, if Turtle & Sons combines
any of this information with personal data, Turtle & Sons will treat this
information as personal data pursuant to this Privacy Policy. Turtle & Sons
makes its best efforts to provide you with the links to our partnersÕ privacy
policies, and when available, instructions to opt-out from their services.
2.1.8 Social media and other third partiesÕ platforms
Turtle & Sons may
also collect personal information on third party social networks, platforms or
services. By playing a Turtle & Sons game through a social network or other
third party platform, or by connecting to such a third party network, platform
or service via one of our products and/or Services, you are authorizing Turtle
& Sons to (1) collect, store, and use, in accordance with this Privacy
Policy, any and all personal information that you agreed the social network or
third party platform could provide to Turtle & Sons based on your settings
on the social network or platform, and (2) share any and all of your personal
information with the social network or other third party platform, through the
social network/third party platformÕs Application Programming Interface (API).
You agree to this sharing when you connect with the third party network,
platform or service via our products and/or services, and/or when you connect
with, "accept" or "allow" (or similar terms) one of our
applications through a social network, or other third party platform or service.
2.1.9 Custom content
Turtle & Sons may
work with trusted marketing partners to bring you more useful and interesting
advertising content on our Services and on third party sites and services.
Provided that you ticked the ÒShare my information with select partiesÓ box during
your subscription or in your Turtle & Sons Account settings, we may do this
by sharing or matching the personal information you have provided us on the
Services with the information (which may include personal information) you have
provided third party marketing partners. As explained above in the cookies
section, we may share some information via cookies and other technologies.
2.2.1 Creation of user generated content
Some Services give you
access to tools in order to allow you to create and/or share unique content.
This User-Generated Content may be collected by Turtle & Sons; this content
may also contain your personal information or the personal information of
others (for instance, your name, or a picture of you). Please exercise caution:
Turtle & Sons is not liable for any negative consequences linked to the
disclosure of User-generated content.
2.2.2 In-game data collection
Whenever you use the
Services, Turtle & Sons may collect, store and process your in-game data,
including but not limited to: your game scores, game metrics, achievements,
rankings, time played and statistics, feature usage, advertising conversion
rates, monetization rate, purchase history and other similar information.
Turtle & Sons will use this information to improve the Services, to
personalize them to your interests, and otherwise upgrade your gaming
experience. Any information collected by Turtle & Sons in accordance with
Article 1 of this Privacy Policy may also be used in an aggregated form to
identify specific patterns regarding the use of our Services.
For some Services, you
may make purchases, whether you shop on Turtle & Sons websites or directly
in-game. When you do this, you agree that Turtle & Sons may share your
personal data with third parties, companies, or organisations, which may
collect and process your personal data in order to effectuate online credit
card transactions, delivery, discounts, and promotional gifts. To make a
purchase on Turtle & Sons store and process your online payment, you may be
asked to provide the following information to a payment provider: your first
name, your family name, your address, your e-mail address, your country of
residence and your banking details, i.e. your credit card number, the name of
the credit card owner, the expiration date and security code. This information
may be stored in Turtle & SonsÕ premises, or, when relevant, in the third
partiesÕ premises. Such storage is necessary to allow Turtle & Sons to manage
internal accounts, checking, accounting, compliance, and for legal purposes, in
accordance with Article 3 of this Privacy Policy. You may be asked to give your
telecommunications providerÕs name, your cell phone model, and a valid phone
number in order to provide you with purchasing instructions directly via your
cell phone.
The information you
submit to our Services is collected and used by Turtle & Sons as set out in
this Privacy Policy. In addition, Turtle & Sons may use the submitted
information to answer your demands, to send your order confirmations and other
information regarding your Turtle & Sons Account, to send you advertising
or promotional materials, including information about special rebates, promotional
offers and other events of interest in accordance with your choices. We also
use your personal information for our internal marketing and demographic
studies, so we can constantly improve the Services we provide you and to better
meet your needs. Additionally, Turtle & Sons may use your personal
information outside of its Services to provide you with products, services or
advertisements we believe may be of interest to you. Turtle & Sons may have
to duplicate some of your personal data within its databases for technical
reasons, or for any other reason indicated in this Privacy Policy. In case of
misuse of the Services by any User, Turtle & Sons reserves the right to
block such UserÕs Turtle & Sons Account, or IP address. Turtle & Sons may
use your date of birth or your age to control access to its forums and live
chats, in accordance with the relevant laws. Turtle & Sons does not monitor
all chat communications on its services. However, Turtle & Sons reserves
the right, at its sole discretion and without notice, to modify or delete any
communications on its service. Turtle & Sons may use all data collected in
the forums and chat logs to enforce its Terms, to carry out its legal
obligations, and to protect its rights and the rights and safety of its affiliated
companies, users, and employees. Your information may be disclosed to any
relevant judiciary or administrative entity, in accordance with the relevant
legal provisions.
Turtle & Sons
processes your personal data, wherever necessary:
- To provide you with the Services (creation of your Turtle & Sons account, bug detection, fighting fraud, online payment, etc.)
- To offer the best possible experience to users, and improve the Services (in-game data analyticsÉetc). It is in Turtle & SonsÕ legitimate interest to process your data for these purposes.
- To provide you with supplementary services (custom contentÉetc.). In such case, Turtle & Sons systematically requires your consent before processing your personal data for this purpose.
We take your privacy and
the security of your personal information very seriously. To protect your
personal information, Turtle & Sons maintains appropriate safeguards to
ensure the security, integrity and privacy of the information you have
provided. We use robust security measures to protect personal information from
loss, misuse and alteration. We use industry-standard practices such as
encrypted communications, physically secured rooms, firewalls and password
protection systems to safeguard the confidentiality of your personal
information. In addition, we take reasonable steps to assure that third parties
who collect personal information on our behalf provide sufficient protection of
personal information, in addition to requiring their compliance with this
Privacy Policy at all times. However, please note that no existing data
transmission method on the web, or electronic storage, can guarantee the
absolute security of your personal data. If your Turtle & Sons accounts and
personal data are protected by a password, you are responsible for ensuring
this passwordÕs confidentiality. Please do not disclose this password. If you share
a computer with other people, please consider disconnecting from your accounts
before allowing others to use your computer. Services may contain links leading
to third party websites, such as but not limited to social media sites.
Whenever you click on a link leading to a third partyÕs website, you agree to
leave Turtle & Sons Services as governed by this Privacy Policy, and you
understand and agree that Turtle & Sons does not control such third partyÕs
website. Turtle & Sons cannot guarantee that third partiesÕ websites will
be governed by the same security and confidentiality obligations. Turtle &
Sons is not liable for the use of your personal data by these third parties.
Please consider checking privacy policies of any service provider you transfer your
personal data to.
Unless relevant legal
provisions mandate a different data retention period, Turtle & Sons will
store your personal data for the duration necessary to process it according to this
Privacy Policy. We archive your personal data during the entire statutory
period of limitations. For instance, we may retain certain information after
you close your account for a period of time needed to protect Turtle & Sons
from legal claims.
Turtle & Sons does
not disclose your personal data to any third party without your prior consent.
Turtle & Sons may
share your personal information among the Turtle & Sons group of companies.
To the extent that our corporate affiliates and/or technical partners have
access to your information, they will follow practices that are at least as
restrictive as the practices described in this Privacy Policy.
While browsing on Turtle
& Sons websites, or while using Turtle & Sons Services, external
providers may collect your personal data for and on behalf of Turtle &
Sons, and Turtle & Sons may share some of your personal data with these
partners to allow the functioning of the Services. For example, these third
parties may help deliver your purchases, provide discounts or offer products,
promote the Services, perform electronic payment processing, and any other
service that may be required by Turtle & Sons. External providers must
comply with this Privacy Policy when collecting your personal data. Unless a
third party invites you to accept its own privacy policy and terms, these external
providers will share your personal data with no one other than Turtle &
Sons. Your personal data may not be used by these third parties to marketing
purposes without your prior consent, and you may withdraw your consent to share
your personal data with third parties at any time.
In accordance with
relevant laws, Turtle & Sons may have to disclose your personal data to a
judiciary or administrative entity, whenever such disclosure is deemed
necessary for identification, challenging or enforcing legal rights against any
individual that may potentially jeopardise to Turtle & Sons or any other
Turtle & Sons userÕs rights.
In the unlikely event
Turtle & SonsÕ business activities or shares are transferred partly or
totally to any third party, such third parties may access your personal data.
In this case, Turtle & Sons may also allow your personal data to be
transferred to the acquiring third party.
Please be aware that
your personal information may be transferred to, stored in, and processed by
affiliated companies, subcontractors and/or Turtle & Sons partners, located
in third countries. Some personal data recipients are located in countries that
are not considered as ensuring an adequate protection level according to the EU
Commission. In such case, Turtle & Sons uses the strict framework of the EU
CommissionÕs approved standard contractual clauses, which are available on the
EU Commission website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_fr/)
Turtle & Sons
Services may offer a public profile feature (ÒPublic ProfileÓ) that allows you
to publish information, including personal information, to the public Internet.
Other than as stated on the applicable Public Profile site, the information you
upload or input to your Public Profile will default to the privacy level you
choose at sign-in, and you can choose to change the privacy settings at any
time. By default, certain aspects of the Public Profile are set to ÒpublicÓ.
Those aspects of the Public Profile that are designated as ÒpublicÓ will be
visible to everyone, potentially including people not registered within the
Turtle & Sons environment, and may be indexed and displayed through public
search engines when someone searches for you. If you post your personal
information to a Public Profile, including a video, image or photo, you should
be aware that these may be viewed, collected, copied and/or used by other users
without your consent. We are not responsible for disclosure by other users of
your Personal Information, including without limitation, videos, images or
photos that you choose to make public on the Turtle & Sons Services. Also,
please remember that the Personal Information you provide to us as part of your
Public Profile may reveal or allow others to identify aspects of your life that
you may not choose to state on your Public Profile directly (for example, your
picture may reveal your gender). Certain Services may feature a friend finder
tool. By using our friend finder tools, you acknowledge that these tools will
help you find your contacts, and will also allow your contacts to associate
your Turtle & Sons Account, other Turtle & Sons accounts (if any), and
related gaming entitlements, including games played on PC, mobile and console
platforms with your social networking profile and/or email address. Your
resulting friends' list, which may be accessible across Turtle & SonsÕ
sites, will be subject to this Privacy Policy. Note that the friends that you
choose to include on your friend list may be able to find and/or identify you
in the context of different Turtle & Sons products and Services, and may
see the profiles and information you have made visible to them or to everyone.
Similarly, Turtle & Sons may also collect or receive information about you
from other Turtle & Sons users who choose to upload their emails and other
contacts. This information will be stored by us and used primarily to help you
and your friends connect.
Minors under 16 residing
in the European Union cannot access Turtle & SonsÕ apps.
In accordance with GDPR,
you have a right to access, rectify, erase, object, or restrict processing for
all your personal data processed by Turtle & Sons, as well as the right of
data portability. Turtle & Sons will answer your request within a month
following the receipt of your demand. In accordance with GDPR, Turtle &
Sons reserves the right to extend this delay up to three months if it necessary
regarding the complexity of your demand, or based on the number of demands we
receive. In such case, we will inform you of this extension within a month
following the receipt of your demand. For any data processing activity
requiring your consent (cookies, behavioural advertisingÉetc), you may withdraw
your consent at any time. This withdrawal does not affect the lawfulness of any
previous processing. You may also address any complaint to the national
supervisory authority of your country.
Turtle & Sons
reserves the right to modify this Privacy Policy at any time. As a result,
please consider checking this Privacy Policy from time to time. Your use of the
Services after Turtle & Sons changed this Privacy Policy shall signify that
you agree with these changes. If you do not accept changes made to this Privacy
Policy, you shall refrain from using the Services.
For any question related
to your personal data processing and this Privacy Policy, please contact Turtle
& Sons data protection officer at the following address: contact@turtleandsons.com