As the controller, the HappyTurtleApps has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through its services. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
1. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
2. Information Collection and Distribution
Automatically Collected Information
We do not collect any user provided information, but we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the apps and games. Also, we collect the automatically given information provided by Facebook such as public profile, friends list and e-mail.
Do we collect precise real time location information of the device?
We do not collect precise information about the location of your mobile device.
Do third parties see and/or have access to information obtained by HappyTurtleApps?
Yes. We will share your information with third parties only in the ways that are described in this privacy statement.
We may disclose Automatically Collected Information:
- as required by law, such as to comply with a subpoena, or similar legal process;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.
- to advertisers and third party advertising networks and analytics companies as described in the section below
3. Automatic Data Collection and Advertising
We may work with analytics companies to help us understand how our apps and games are being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in our services which help us keep the applications free. Advertisers and advertising networks use some of the information collected by the our services, including, but not limited to, the unique identification ID of your mobile device and your mobile telephone number. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties can’t identify you personally. These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non- precise location information in order to help analyze and serve anonymous targeted advertising in our apps and elsewhere. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use.
We will pass the device-level data (e.g. if a device has clicked on a sports ad within our apps) and we may pass age & gender information to our advertising partners who may reuse such data for targeted advertising. We allow our partners to serve targeted third party advertisements or other content. They may attach the information gathered from your application to info gathered from other apps, websites, or via other services, and then build profiles and transfer the info to another provider. For instance, we may pass advertising IDs to Facebook and they match it with your Facebook ID, aggregate it and delete the initial identifier. By doing so, the other provider may receive or gather information about you and use the information for displaying targeted ads. Advertisers may choose their audience by location, demographics, likes, keywords, age & gender, interests, behaviors, connections and any other information Facebook receives or infers about users. We cooperate with several providers of IBA that are listed herein in the subsection “Advertising Companies”.
4. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
5. Rights of the data subject
HappyTurtleApps collects only anonymous information for the purposes of targeted advertising and tracking of user behavior within the game. Should the user wish to eliminate the right to access to this automatically collected information, he or she can turn off individual device tracking on his or her portable device.
6. Advertising Companies
If you’d like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled “Opt-out” below.
What are my opt-out rights?
There are multiple opt-out options for users of our apps and games:
Opt-out of all information collection by uninstalling the Application: You can stop all collection of information by our apps and games easily by uninstalling them. You may use the standard uninstall processes which may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at email@example.com.
Opt-out from the use of information to serve targeted advertising by advertisers and/or third party network advertisers: you may at any time opt-out from further allowing us to have access to your location data by:
Following the third party instructions directly:
For Google (AdMob) please visit https://www.google.com/ads/preferences/html/mobile-about.html;
Activating “Do Not Track Settings” in mobile phone
The providers of advertising services are bound to comply with “Do Not Track” settings in mobile phones, but we cannot provide any guarantees on their behalf. We provide no guarantees regarding the information provided prior to opting out. Some providers may have additional opt-out mechanisms implemented.
If you turn on “Opt Out of Interest-Based Ads” on your Android device, you can restore interest-based ads by turning the settings off. When you opt out, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won’t be based on your interests. Our advertising partners may continue to serve you ads based on other non-personal information, such as ads related to the content of the application you are using.
Your Android mobile device may provide a “Limit Ad Tracking” or “Opt Out of Interest-Based Advertising” setting. When you have opted out using this setting on a device, our partners will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.
You can find the setting for your mobile device by following the directions below, or contact your device provider.
The reason for switching from device IDs to Advertising Identifier is that advertisers are able to use this identifier only for advertising and for no other purpose, while users can choose to opt out of tracking via the settings of mobile phone. Advertising Identifier is an anonymous identifier for advertising purposes which enables users to reset their identifier or opt out of interest-based ads. The parties participating in advertising are obligated to follow users’ choice for opting out of tracking according to the app store guidelines.
For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:
Open your Google Settings app > Ads > Enable “Opt Out of Interest-Based Advertising”
7. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Whether our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, is to be based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
8. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
9. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact HappyTurtleApps. The company clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
10. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
11. Data Retention Policy, Managing Your Information
We will retain Automatically Collected information. If you’d like us to delete User Provided Data that you have provided via any of our services, please contact us at firstname.lastname@example.org and we will respond in a reasonable time.
We do not use our products to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at email@example.com. We will delete such information from our files within a reasonable time.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our services. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
15. Your Consent
16. Contact us
If you have any questions regarding privacy while using our products and services, or have questions about our practices, please contact us via email at firstname.lastname@example.org.