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Privacy Policy

Last Updated: October 24, 2022

Overview

About us and how to contact us

Torn Games Limited provide game services and features and we will process your personal information when you play our games. If you have any questions about our data practices, your rights or have any concerns or complaints, you can contact us at info@torngames.com.

Personal information we collect

We collect personal information from you directly, e.g. when you play games or register for an account. We also generate information about how you use our games, including game play and log data. If you log into one of our games with your social media account, we will receive information about you including your name, profile picture and email address.

How we use your personal information

We use your information to provide you with our games, support and analyse your use, to improve the quality of the services we provide, and to provide support or respond to your questions. We may sometimes send you promotional emails, send push notifications and how you ads targeted to you within our games. You can choose to stop receiving these at any time, by opting out or changing your device settings.

Who do we share your information with

We use third parties for support services, such as game servers, support tickets and analytics. We also work with certain advertising partners to show you ads. We also share your information with our related group companies and as required by law.

Where do we process your information

Our servers are located in Ireland. Our support, engineering and other teams are located in the United Kingdom. Some of our providers are located outside of the EEA such as the United States.

Changes to the Privacy Policy

Any updates or changes to this Policy will be published here. If there are significant changes, we will notify you through the website and in game.

Introduction

This privacy policy (“Policy“) informs you of your choices and our practices regarding any personal information of yours that we process (as defined below). For the purpose of this Policy, “Information” means any information relating to an identified or identifiable individual. Your use of mobile games published by us (“Mobile Games“) and our website http://www.torngames.com (“Website“) involves the collection and use of your personal information. When you use the Mobile Games or the Website ( the “Game Services“), you accept our rules and policies which set out how we handle your Information, and you understand we collect, process and store your Information as described in this Policy

If you do not agree with this policy, you must not use the Game Services. If you change your mind in the future, you must stop using the Game Services and you may exercise your rights in relation to your Information set in in this Policy.

Torn Games Limited (“Torn Games“, “we“, “us“) is a company registered in the United Kingdom. We are the data controller of your data when your use the Game Services.

1. Personal Information We Collect

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information:

Information you provide to us.

    • Registration information: when you register to use the Game Services, you may be asked for your date of birth, email address, username and password and to create an avatar.
    • when you register for and interact with customer support via our website, our service provider Freshdesk collects your full name, email address and a password. You may submit an ad hoc request to customer support where only your email address is provided. Any content you choose to share with customer support is also collected.
    • if you invite your friends to use the Game Services, we will collect the email address of your friend. Please make sure you have permission from your friend before sharing this Information with us.
  • Information we automatically collect or is generated about you when you use the Game Services
    • Identifiers such as your IP Address, device, Advertising ID, country level location data and device information (such as model, brand and operating system)
    • Information you generate and display when using the Game Services, such as profile photos.
    • Information relating to your use of the Game Services, such as timestamps of game events, interactions with our team, transaction records, or evidence of you using cheating software or modified versions of the Game Services.
  • Information received from third parties
    • Third party registration: when you register with a third party, such as Facebook, Apple or Google Play, we may receive your third party ID, name, avatar, city level location. If you give the Game Services permission, we may also collect your email address, friends list and date of birth.
    • Payment processing: when you make payments in the Game Services, we receive information from our payment processors about your transactions including your Apple ID number from Apple and your postcode and state for Google.
    • Analytics Information: we integrate Unity Analytics, provided by Unity Technologies (A US and Finnish company), a third party analytics provider in some of our Game Services. This provides reports which help us optimise our in game features and events which includes your User ID and information on your in-game activity

Children

Our Game Services are not targeted at children. Where Children under 16 use our Game Service, we advise that they obtain permission from a parent or guardian.

2. How we use your personal information

We use your Information to:

  • Provide you with the Game Services. Specifically, we will use your Information to perform our contractual obligation to you to allow you to create an account, use the Game Services and remember your game progress, using the Game Services with your friends, allow you to make purchases via Google Play, iOS Appstore or Facebook and maintain a record of such purchases. The Information we process when doing so includes your registration information, information you provide to us when using the Game Services, identifiers, information you generate and display when using the Game Services, and information regarding your use of the Game Services such as transaction records.
  • Improve and monitor game use. It is our legitimate interest to improve our Game Services for our customers. When doing so, we may collect information automatically or is generated about you when you use the Game Services, as well as non-personal information about your device such as battery levels, Wi-Fi strength, device model and operating system and the amount of free space on your device.
  • Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to create an account to respond and resolve your queries and complaints. When doing so, we perform our contractual obligation to you. The Information we process when doing so includes your registration information, identifiers and other information collected via our customer support channels
  • Conduct analytics. It is our legitimate interest to analyse the use of our Game Services and advertising campaigns, or any other interaction or interest in the same. When doing so, we will process information we automatically collect or is generated about you when you use the Game Services or interact with our advertising campaigns to create anonymised and aggregated data, create segments of users who show particular characteristics or interests and conduct predictive analytics about your interests.
  • Provide you with advertising. We will present you with ads and suggestions in our Game Services and elsewhere. These may be ads relating to our other Game Services or other services you may be interested in. These ads and suggestions may be tailored specifically to you. Where it is required, we will only do so where we have your consent. In situations where your consent is not required, or where we provide contextual advertising, we do so on the basis of our legitimate interests. If you no longer want to receive targeted advertising you can withdraw your consent in the Game Service settings. To tailor ads and to allow our advertising partners to tailor ads, we process information we automatically collect or is generated about you when you use the Game Services and information received from third parties.

3. Who we share your personal information with

We share your Information with selected third parties, including:

  • Other players and users will see your profile information and in game activity
  • Vendors and service providers we rely on for the provision of the Game Services, these include:
    • Cloud service providers who we rely on for data storage, including Amazon Web Services who are based in the U.S;
    • Customer support solution providers, who help us manage and respond to customer questions and complaints. This includes Freshdesk, who are based in the U.S, and host our customer support function
    • Analytics providers, provided by Unity Technologies, who are based in the U.S and Finland
    • Social media, to integrations with Facebook to enhance social features within the Game Services, which as accessing your friends and your profile picture.
  • Advertising partners. We are an ad-supported service. Depending on your device settings, we provide certain Information to advertisers who will use them to server you with ads in our Game Services, and we measure to see who see and clicks their ads. We also provide Advertising Identifiers to help partners decide on the ads to deliver.
  • Payment processors. We use the payment processors such as Google or Amazon (if you run Android on your mobile device) or Apple App Store Payments (if you run iOS on your mobile device). These payment processors are responsible for the processing of your Information and may use this Information for their own purposes in accordance with their privacy policies below:
  • Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, asset sale or other transaction, we may disclose your Information as part of that transaction.

If you choose to access any Game Services through a third party platform such as Facebook or Google then that third party may collect other information about you (including about your use of the Services) in accordance with its terms and own privacy policy. Any data you share on these third party platforms directly (such as posting comments on our Facebook page) will also be dealt with in accordance with its terms and privacy policy. They may share data with us which we handle in accordance with this privacy policy.

Although we have in place security practices to maintain the privacy and integrity of your personal information, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Information, for example, when you provide us with your password as part of the registration process, we apply a one-way hash, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

4. Where we process your personal information

In order to perform our contract with you, your Information will be accessible from and wil lbe processed by our employees and on our servers located in the United Kingdom and Ireland.

5. How long we store your information

Your Information is kept as long as you are registered or using our Game Services, and then for up to three years from the date you stopped interacting with the Game Services. When deleting your Information, we ensure that this is irrecoverable and irreproducible.

6. Your rights and access

You have certain rights in relation to the Information we hold about you. Some of these only apply in certain circumstances which are set out in this Policy. We must respond to your request to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise your rights, please email us at support@torngames.com.

  • Access. You have the right to access Information and receive and explanation of how we use it and who we share it with. This right is not absolute, for example we cannot reveal trade secrets or give you Information about other individuals
  • Erasure. You can delete your account, or remove certain parts of Information, by logging into your Game Account and accessing the Settings. We will need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
  • Portability. You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you. You have the right to receive this information in a structured, commonly used and machine-readable format.
  • Correction. You have the right to correct any Information held about you that is inaccurate.
  • Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes

7. Contact and Complaints

Any questions, comments or requests regarding this Policy are welcomed and should be directed to support@torngames.com.

If you wish to make a complaint about how we process your Information, please contact us at support@torngames.com and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

8. Changes

Any updates or changes to this Policy will be published here. If there are significant changes, we will notify you through the website and in game.

 

9. Advertising and Acquisition Partners

We use the following user acquistion and advertising partners, that are integrated into some of our Game Services. Please check the following privacy policies to learn more about their practices, including how you may exercise your data subject rights.

This list was last updated on 24th October 2022.

Advertising Partner Link to Privacy Policy
AdColony https://www.adcolony.com/privacy-policy/
Admob (Google) https://policies.google.com/technologies/partner-sites
AppLovin https://www.applovin.com/privacy/
Bidstack https://www.bidstack.com/privacy-policy/
Chartboost https://answers.chartboost.com/en-us/articles/200780269
Fyber https://www.fyber.com/legal/privacy-policy/
HyprMx https://www.hyprmx.com/privacy-policy
InMobi https://www.inmobi.com/privacy-policy
ironSource https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Meta (Facebook) https://www.facebook.com/policy.php
Mintegral https://www.mintegral.com/en/privacy/
Ogury https://ogury.com/privacy-policy/
Pangle https://www.pangleglobal.com/privacy
Tapjoy https://www.tapjoy.com/legal/#privacy-policy
UnityAds https://unity3d.com/legal/privacy-policy
Vungle https://vungle.com/privacy/
Yahoo https://legal.yahoo.com/us/en/yahoo/privacy/