Last Modified on October 4th, 2019
We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
- Who we are
Tonk Tonk Games, Inc (“Tonk Tonk,” “We,” or “Us”) collects, uses and is responsible for certain personal information about you, as part of Tonk Tonk’s “uFighter” game (the “Service”).
For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.
- The Personal Information we collect and use
Information collected by us: In the course of providing you with the Service, we collect the following personal information when you provide it to us:
- Your name, username, age, and email address, when you make use of the Service to play a game; input your age into the Service; link a social media or app store account to the Service; submit a request to receive customer or technical support; or participate in Service feedback, questionnaires, surveys, or contests.
- Your photo, when you upload it to generate your 3D avatar on the Service.
- Your credit card or other billing information when you make a purchase on the Service.
Information shared with us by others: If you purchase a Game from a third-party service like the Apple App Store or Google Play Store, your username, profile, and purchase information from that third-party service may be shared with us.
How we use your Personal Information: We use your personal information as follows:
- We may use your screen name to identify you in the Service.
- We may use the photograph that you upload, with your consent, to generate a personalized 3D avatar that may be displayed to other players.
- We may use your linked social media account to see if you have friends playing the game and connect you with them.
- We may use your linked app store account to enable in-app purchases for downloadable content and other game enhancements.
- We will use your location in determining the best server for you to play the game.
- We may share your gameplay and other personal information for the purposes of analyzing gameplay and other related player data.
- We may use your email address to contact you if you submit a support request or otherwise contact us through the Service or our website.
Who we share your Personal Information with: We share your Personal Information with certain third parties as part of our operation of the Service. This data sharing enables you to purchase the Game and us to provide you with the Service in the optimal way.
Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.
We share your Personal Information with the following third parties:
- We use your linked Google Play account if you’re using the Service on an Android-based device: https://www.google.com/intl/en/policies/privacy/
- We use your linked Apple App Store account if you’re using the Service on an iOS-based device: http://www.apple.com/privacy/privacy-policy/
- We use Microsoft Azure as our cloud network provider: https://privacy.microsoft.com/en-us/privacystatement
Other Sharing: We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Tonk Tonk, its employees, clients, or users of the Service.
We will not share your personal information with any other third party.
How long your Personal Information will be kept: We will keep your Personal Information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide.
Please note that some data may be retained if necessary to resolve disputes, enforce Tonk Tonk user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.
Reasons we can collect and use your Personal Information: The laws in some jurisdictions require that we notify you of the lawful basis for collecting your Personal Information.
To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:
- Consent: At times we may collect, process, store, transfer or disclose your personal data on the basis of your implied or explicit consent.
- To fulfill our contractual obligations: In order to fulfill our contractual obligations to you, we must collect, process, and store your personal data and information. We must handle your personal data in this manner to process purchases on the Service.Additionally, we may at times have to transfer or receive your personal data to or from third parties, in order to fulfill other contractual obligations to you. For example, we may have to transfer or receive billing and payment information to or from payment processors for any purchases you make.
- Furtherance of legitimate interests: We may collect, process, store, transfer or disclose your personal data in furtherance of those legitimate interests of ours which are not overridden by your interests or fundamental rights and freedoms as set forth in the applicable laws. These legitimate interests include, but are not limited to, (i) providing you with the Service, (ii) protecting our users, staff, and property from fraud and other harm, (iii) collecting information on how you use the Service in order to optimize the design and functionality of the Service, and (iv) communicating with you via e-mail for communications you have explicitly opted into (e.g., notifications about new products and services) or for important communications with you regarding the Service.
- Legal compliance: We may collect, process, store, transfer or disclose your personal data to comply with our legal obligations.
Depersonalized Information: We may make your Personal Information non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information and is used to analyze usage and improve the Service.
Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, allow them to create accounts, sign up for newsletters, or use the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. Tonk Tonk takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when on-line. If you have any concerns about your child’s personal information, please contact us at firstname.lastname@example.org.
Do Not Track: Because there is not yet a consensus on how companies should respond to web browser-based or other do-not-track mechanisms, we do not respond to web browser-based do-not-track signals at this time.
Social Media Sign-In: You can log in to the Service using sign-in services such as your Google Play, Apple ID, or Facebook accounts. These services will authenticate your identity and may provide you the option to share certain personal information with us such as your name and email address to do things like track game progress and sync across multiple devices. These services give you the option to post information about your game activities to your social media profile page to share with others within your network.
Additional Information You Should Know About Third Parties: Please be aware that we cannot control the activities of third parties to whom we provide data, and as such we cannot guarantee that they adhere to the same privacy and security procedures as us.
For example, your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the Service, such as personal information, payment information, geolocation information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.
- Transfer of your Information out of the EEA
Tonk Tonk is based in the United States. No matter where you are located, you consent to the processing, transfer and storage of your information in and to the U.S., and other countries, in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
If you would like further information, please contact us (see “How to contact us” below).
- Your Rights
Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.
- By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
- If we are processing your personal data for reasons of consent or to fulfill a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
- If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
- You have the right to ask us to stop using your information for a period of time, if you believe we are not doing so lawfully.
- Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email us at email@example.com. We may ask for additional verification information, such as your username and other information required to be sure that you are the owner of that data.
- Keeping your Personal Information secure
We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.
For example, data encryption using https, encrypted password protection, server-side verification, and other security measures are taken on our cloud servers and many other third-parties with whom we share data.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
- How to complain
We hope that we can resolve any questions or concern you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.
If you are an EU citizen, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
- Changes to this Privacy Notice
This privacy notice was last updated on October 4th, 2019.
We may change this privacy notice from time to time. When we do, we will inform you via email to the email address you have provided us with through your account, or by posting a message about the change on the Service.
- How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to firstname.lastname@example.org