We Respect Your Privacy Trenzy Studios And its Affiliates (“Trenzy Studios or “we”) are dedicated to protecting the privacy rights of our online users (“users” or “you”). It also describes the choices available to you regarding our use of your personal information and how you can access this information. We respect privacy of our mobile applications users and we take protecting it seriously. Trenzy Studios offers mobile applications intended for children under the age of 13 (Kids Apps), as well as mobile applications for other target population (Other Apps). Your consent By downloading and using our apps, you agree to the terms of this Privacy Policy and you expressly consent with the collection, use and disclosure of your information. You are always free to opt out of the information collection by not using our mobile applications or services. We have to protect children’s privacy and safety online which includes complying with restrictions on marketing to those under 13. Without their legal guardians’ consent, children under 13 cannot use any of our apps. In addition, they may not install, use or access these apps, or are requested to erase them from their device in case of previous installation if they or their legal guardians disagree with any term in this Privacy Policy. Kids Apps Privacy Policy This Kids Apps Privacy Policy is appointed to provide the legal guardian of a child under the age of 13 with guidance regarding our privacy policies that concern collecting, using and disclosing personal information of children under 13. Parents and legal guardians of children under 13 have certain rights under Children’s Online Privacy Protection Act of 1998 (COPPA, http://www.coppa.org/coppa.htm), and Trenzy Studios recognizes those rights. Trenzy Studios does not knowingly and directly collect and store on its servers any personal information from children under the age 13 as that would be a violation of COPPA. Some information may be collected by third party providers of services (advertising networks, etc.) or certain products. Kids Apps Privacy Policy This Kids Apps Privacy Policy is appointed to provide the legal guardian of a child under the age of 13 with guidance regarding our privacy policies that concern collecting, using and disclosing personal information of children under 13. Parents and legal guardians of children under 13 have certain rights under Children’s Online Privacy Protection Act of 1998 (COPPA, http://www.coppa.org/coppa.htm), and Trenzy Studios recognizes those rights. Trenzy Studios does not knowingly and directly collect and store on its servers any personal information from children under the age 13 as that would be a violation of COPPA. Some information may be collected by third party providers of services (advertising networks, etc.) or certain products. Third party advertising solutions providers: We show third party advertisements (Admob, Chartboost, etc.) within our apps. These ads and services are not under the control of Trenzy Studios who is therefore not responsible for the availability or content of such external sites or services. Use of information – purpose and legal basis We use information about you for the following purposes in accordance with the legal bases for each type of personal data as described below: Age -is being processed: a.to identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your data. Our processing for the above purpose is necessary for compliance purposes, see Article 6(1)(c) of the GDPR. Log-, device-, usage-, and consumption information -are being processed: b.to provide and deliver the products and services you request and send you related information as requested by you / as agreed with you; c.to provide and maintain the App and the game experience; and d.to send you technical notices, updates, security alerts, and support and administrative messages; Our processing for the above purposes is necessary for the performance of a contract to which you are party in order to support the operation of the App, facilitate the delivery of requested products and services and enable maintenance and update of the App, see Article 6(1)(b) of the GDPR. e.to provide news and information about the App that we think will be of interest to you; f.to personalize and improve the App and provide tailored content and features; g.to monitor and analyze trends, usage and activities in connection with the App; and h.to provide children (as this term is construed under GDPR in EU, COPPA in the US and relevant applicable legislation in other jurisdictions) with reasonable contextual advertisements in the App. Our processing for the above purposes is justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (also known as "the balancing-of-interest rule"). i.to provide non-child users that have given us consent to share their advertising IDs with our ad network partners (as further specified under Sharing of Information) for the purpose of serving them with personalized advertisement in the App (behavioral advertising). Our processing for the above purpose is justified by our legitimate interests in providing advertisements and content of interest to you in accordance with Article 6(1)(f) of the GDPR. The disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR (see more below under Sharing of Information). Information from other sources -are being processed: j.to provide and deliver the products and services you request and send you related information; Our processing for the above purpose is necessary for the performance of a contract to which you are party in order to facilitate the delivery of requested products and services, see Section 6(1)(b) of the GDPR. Sharing of information We disclose information about you to the following categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR (see a description of the legal bases above): Furthermore, if you have given your consent in accordance with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising network companies for the purpose of them serving behavioral advertisements to you within the App. We use or may use the advertising network companies. k.to link or combine information we get from others to help understand your needs and provide you with better service; and l.to provide news and information about the App we think will be of interest to you; Our processing for the above purposes is justified by our legitimate interests in providing content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected. Your rights If you wish to use any of the rights described below, you may contact us at any time by emailing us.e process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR. Right to request access You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about: •the purposes of the processing •the categories of personal data concerned •the recipients or categories of recipient to whom the personal data have been or will be disclosed •the envisaged period for which the personal data will be stored Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets. The right to object You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use the App will cease automatically. Right to rectification and erasure You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR. Furthermore, you have the right to have your personal data erased where one of the following grounds applies, see Article 17 of the GDPR: •the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, •if you have withdrawn your consent and there are no other legal grounds for the processing, •if you have objected to the processing and there are no overriding legitimate grounds for the processing, •the personal data have to be erased for compliance with a legal obligation in Union or Member State law, •the personal data have been unlawfully processed or •the personal data have been collected in relation to the offer of information society services. Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. The right to restriction You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest The right to withdraw consent If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR. If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. lease note that if you withdraw your consent, your user license to use the App will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal. Changes to the Privacy Policy We may update this privacy statement to reflect changes in our information practices. We encourage you to periodically review this page for the latest information on our privacy practices. |