Published on September 18th, 2018

PLEASE READ THIS PRIVACY POLICY CAREFULLY

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

 

1. WHEN DOES TURTLE & SONS COLLECT YOUR PERSONAL INFORMATION?

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. WHAT PERSONAL INFORMATION DOES TURTLE & SONS COLLECT?

2.1 When you use Turtle & Sons services

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 Whenever you play Turtle & Sons games

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.

2.3     Online payment

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.

3. HOW DOES TURTLE & SONS USE MY PERSONAL DATA?

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.

3.1     Legal basis for your personal data collection and processing

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.

3.2     Security

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.

4. FOR HOW LONG DOES TURTLE & SONS KEEP MY PERSONAL DATA ?

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.

5.    WITH WHOM DOES TURTLE & SONS SHARE MY PERSONAL INFORMATION?

Turtle & Sons does not disclose your personal data to any third party without your prior consent.

5.1     Sharing your personal data with Turtle & Sons affiliated companies

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.

5.2     Sharing your personal data with third parties

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.

5.3     Sharing your personal data with governmental authorities

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.

5.4     Sharing your personal data in case of mergers

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.

5.5     Transfers of personal data to third countries

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/)

6.    DOES TURTLE & SONS MAKE MY PERSONAL INFORMATION PUBLIC? WHO CAN SEE MY PERSONAL INFORMATION?

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.

7.    MINORS

Minors under 16 residing in the European Union cannot access Turtle & SonsÕ apps.

8.    WHAT ARE MY RIGHTS?

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.

9. PRIVACY POLICY CHANGES

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.

10.  CONTACTS

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