PRIVACY POLICY
(Last Updated: May 2020 with effective date 14 May 2020)
Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.
This Privacy Policy applies to tortoiseandharegames’s apps, website and related services (together the “Services” or “apps”, “websites” for individual categories). This Privacy Policy explains how we collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.
INFORMATION WE COLLECT AND HOW
While using our Services we will not ask you to provide us with personal data or personal information. If you contact tortoiseandharegames then we will collect the contact information necessary to respond.
• Basic Identifiers and Contact Information We collect some information from you when you provide it to us directly, such as via an email or online form, through the support features embedded in our Services, or through another form of inquiry. This information may include your name, email, and phone number.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Your data will only be used to contact you in response to a query you have initiated to us.
RETENTION OF PERSONAL DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
YOUR RIGHTS AND OPTIONS
Access Personal Data we hold about you
You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you a copy of your Personal Data in an electronic format.
Other rights
You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
PURPOSES FOR WHICH WE WILL SHARE YOUR PERSONAL DATA
We may share the above categories of Personal Data for certain business purposes, including:
• Storage Personal Data of our users are stored in our data centers of our third party service providers such as email hosting service.
• When required by law We may also share information if we also under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.
• To enforce legal rights We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
• With your consent or at your request We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
• Cross-border data transfers Sharing of information sometimes involves cross-border data transfers, including transfers outside of the EEA in accordance with the law. We only transfer Personal Data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this privacy policy and applicable law, for example in accordance with the rules and procedures known as the EU-US Privacy Shield, or under contractual provisions which have been deemed by the European Commission to provide sufficient safeguards for Personal Data.
AGE LIMITS
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of Personal Data, for any reason, please use the in-app support feature in our Services and we will take reasonable measures to promptly delete such Personal Data from our records.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.
• Social sharing features You have the right to know and see what information we have collected about you over the past 12 months, including:
◦ The categories of information we have collected about you;
◦ The categories of sources from which the information is collected;
◦ The business or commercial purpose for collecting your information;
◦ The categories of third parties with whom we have shared your information; and
◦ The specific pieces of information we have collected about you.
• Right to Delete You have the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
◦ Complete your transaction;
◦ Provide you a good or service;
◦ Perform a contract between us and you;
◦ Protect your security and prosecute those responsible for breaching it;
◦ Fix our system in the case of a bug;
◦ Protect the free speech rights of you or other users;
◦ Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
◦ Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
◦ Comply with a legal obligation; or
◦ Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
• Right to Opt-out You have the right to “opt-out,” or direct us to stop “selling” or otherwise sharing your information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please follow the instruction under the ‘Opt-out of targeted advertising’ paragraph found above, to configure the Privacy Setting in any of our app or by checking your device privacy settings.
• Other Rights You can request certain information about our disclosure of your information to third parties for their own direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.
• Exercising Your California Privacy Rights To request access to or deletion of your personal information, to opt-out, or to exercise any other rights under California law, please follow the instruction under the ‘Exercise your privacy rights’ paragraph, found above, and follow the necessary steps.
• Response Timing and Format We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may change from time to time, and we encourage you to review it periodically. Your continued use of our Services signifies your acceptance of changes to this Privacy Policy.
In some cases, we may notify you of changes to this Privacy Policy with a prominent notice on our Services (for example by way of notification or pop-up), before the changes become effective and update the "effective date" at the top of this Privacy Policy.
CONTACT US
If you have any questions about this Privacy Policy, please contact us using the in-app support feature in our Services, which is the preferred method to be able to quickly respond your requests.