ToraCode, including its affiliates (“ToraCode”), collects, stores, and uses your personal information as a data controller in connection with and in order to provide and develop ToraCode’s products, mobile applications, services and websites (together “Services”) according to this privacy policy (“Privacy Policy”).
For questions and information about Privacy Policy and data subject’s rights, please contact us at info[a]toracode.net.
For information about our privacy practices related to data from children, please see “Special Note About Children’s Privacy” below.
All ToraCode Services are governed by this Privacy Policy and by using or accessing a Service You give consent to the processing, use and disclosure of your data. Please do not install or use the Services if you do not agree to this Privacy Policy.
ToraCode reserves the
right to modify this Privacy Policy. Your continued use of Services will
signify your acceptance of the changes to this Privacy Policy.
- How We Collect Your data
Likely situations when you make personal data available to ToraCode include, but are not limited to: (i) by using ToraCode’s mobile apps or visiting our websites, (ii) registration for Services, contests and special events; (iii) accessing Services using a third party ID, such as social networking sites or gaming services; (iv) subscribing to newsletters; (v) purchasing a product or services through ToraCode’s online stores or within the app (or “in-app purchase”); (vi) using “tell a friend,” “email this page,” or other similar features; (vii) requesting technical support; and (viii) otherwise through use of ToraCode Services where personal data is required for use and/or participation.
The data we process on you may include, but is not limited to: email address, device ID, IP-address, user names and passwords.
ToraCode
may supplement your data with data received from third parties in
connection with demographic, advertisement, market and other analytics
surveys or services.
- Ad Serving Technology
ToraCode reserves the right to use and disclose the collected, non-personal data for purposes of advertising by ToraCode or ToraCode’s partners and contractors.
ToraCode may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.
ToraCode or third parties operating the ad serving technology may use demographic and geo-location information (for more information regarding use of Location Data see below Section 3) as well as information logged from your hardware or device to ensure that relevant advertising is presented within the Service. ToraCode or third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, Device ID, MAC address, installed software, application usage data, hardware type, Operating System information, browser information, unique identifiers in browser cookies, Flash cookies, and HTML5 local storage, Internet and on-line usage information and in-game information.
The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.
ToraCode may display to you behaviorally targeted advertising. If you wish to “opt out” of certain targeted advertising, please visit http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all ToraCode’s advertising partners and certain behaviorally targeted advertising may still be displayed to you. If you want to be certain that no behaviorally targeted advertisements are displayed to you, please do not use or access the Services.
Some services may include the use of in-game advertisements or brand placement. Such ads or sponsorships will be noted as such within the services.
Additionally please
note that if you “opt out” it does not mean that you will no longer
receive advertising. It just means that the advertising you see
displayed will not be customized to you and your interests and may be
less relevant to you.
- Location Data
To the extent ToraCode makes location enabled Services available and you use such Services, ToraCode may collect and process your location data to provide location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations. The location data is processed and stored only for the duration that is required for the provision of the location related Services.
ToraCode may use, depending on the service (1)IP-based location based on the IP address presented by the end-user, (2) fine geo-location data based on coordinates obtained from a mobile device’s GPS radio, or (3) coarse, network-based geo-location data based on proximity of network towers or the location of WiFi networks.
Your fine, GPS-based geo-location
is not accessed without your consent. Notwithstanding ToraCode’s
partners who are providing location related parts of the Service,
ToraCode will not share your GPS geo-location with third parties without
your consent. To the extent ToraCode makes available GPS geo-location
to third parties in accordance with this Privacy Policy, it will be
provided anonymously.
- Analytics
ToraCode
uses your information to perform its own analytics and to enable
analytics provided by third parties. We use analytical information for
supporting business analysis and operations, business intelligence,
product development, improving products and services, personalizing
content, providing advertising, and making recommendations
- Friends
If you choose to use ToraCode’s “tell a friend” or a similar service about ToraCode Services or order a gift certificate for your friend, ToraCode may store your friend’s name and contact details that you provide to ToraCode.
Please note that certain features of the Services may
be able to connect to your social networking sites to obtain additional
information about you. In such cases, ToraCode may be able to collect
certain information from your social networking profile when your social
networking site permits it, and when you consent to allow your social
networking site to make that information available to ToraCode. This
information may include, but is not limited to, your name, profile
picture, gender, user ID, email address, your country, your language,
your time zone, the organizations and links on your profile page, the
names and profile pictures of your social networking site “friends” and
other information you have included in your social networking site
profile. ToraCode may associate and/or combine as well as use
information collected by ToraCode and/or obtained through such social
networking sites.
- Disclosure and Transfer of Personal Data
Personal data may be disclosed to third parties including third parties located outside the European Union or the European Economic Area in accordance with applicable legislation and this Privacy Policy.
ToraCode may
use third parties to collect and process personal data on ToraCode’s
behalf and in according to ToraCode’s instructions. ToraCode is not
liable for the acts and omissions of these third parties, except as
provided by mandatory law.
- Data Retention and Correctness
ToraCode retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter ToraCode deletes all aforementioned data in its possession within a reasonable timeframe. ToraCode does not verify the correctness of personal data.
Please
note that some data may be further retained if necessary to resolve
disputes, enforce ToraCode user agreements, and comply with technical
and legal requirements and constraints related to the security,
integrity and operation of Services.
- Cookies, beacons and tracking
The Services may use “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, Operating System-based identifiers, clear GIFs and web beacons. ToraCode treats information collected by cookies and similar technologies as non-personal data.
Cookies: A “cookie” is a small file stored by your browser when told to do so by a website. Typically websites place a number of different cookies on an end-user’s machine. Some of the cookies are “1st Party,” from the website itself, and others are “3rd party,” belonging to advertising and analytics entities or social networks. ToraCode’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
Flash cookies & HTML5: ToraCode may also use Flash cookies (local shared objects) and HTML5 local storage. Flash cookies are small files similar to browser cookies, but which are not stored in the browser and can also be used to remember your settings, to personalize the look and feel of the Services, or for advertising and analytics. You may prevent Flash cookies from being stored by following the instructions provided by Adobe at http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
Web
Beacons and pixel tags: A “web beacon” or a “pixel tag” is an
electronic image (often not visible to the end-user) that allows
ToraCode to count users who have visited certain pages or viewed certain
advertisements. Additionally, e-mails and other electronic
communications ToraCode sends to you may contain pixel tags that enable
ToraCode to track your usage of the communication, including whether the
communication was opened and/or what links were followed, if any.
- Third Party Terms and Conditions
Please note that your access to and use of the Services may be subject to certain third party terms and conditions and ToraCode is not liable for any such third parties’ use of your personal data.
Certain Services that ToraCode may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID, or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from ToraCode.
ToraCode may
disclose your personal data to third parties in connection with a
corporate merger, consolidation, restructuring, the sale of
substantially all of ToraCode’s stock and/or assets or other corporate
change, including, without limitation, during the course of any due
diligence process provided, however, that this Privacy Policy shall
continue to govern such personal data.
- Safeguards
ToraCode
follows generally accepted industry standards and maintains reasonable
safeguards to attempt to ensure the security, integrity and privacy of
the information in ToraCode’s possession.
- Other
You may choose to disclose data about yourself in the course of contributing user generated content to the Services.
Any data that you disclose in any of these forums, blogs, chats or the like will become public information, and there is no expectation of privacy or confidentiality with respect to that data.
ToraCode may store
and/or transfer your personal data to its affiliates and partners in and
outside of EU/EEA member states and the United States in accordance
with mandatory legislation and this Privacy Policy.
- Special Note about Children’s Privacy
ToraCode does not knowingly collect personal information from children under 13 years of age. If ToraCode learns that ToraCode has inadvertently gathered personal data from children under 13 years of age, ToraCode will take reasonable measures to promptly delete such personal data from ToraCode’s records.
ToraCode understands the need to provide extra privacy protections to users who are children. To that end, features and services such as social networking plug-ins, behaviorally targeted advertising, and collection of data for the purpose of building user profiles are not available to users under 13. ToraCode also does not allow our third party partners who engage in such practices to access personally identifiable data from users under 13.
ToraCode and its partners do collect non-personally identifiable data from children. This includes, for example, collection of IP-based geolocation data to ensure that the product, service or features served comply with applicable laws of that nation.
ToraCode and its partners also collect data to assess general information about the use of products, such as the number of visitors to our sites and services and which sections of a site or service are popular. ToraCode also uses this data to provide contextually-relevant advertising to users, to prevent users from seeing the same ad repeatedly, and to allow users to personalize their experience on the site or service (for example, to save a high score in a game). ToraCode and its partners may also use cookies, pixels, hardware-based identifiers, Operating System-based identifiers, and software-set identifiers, to manage and measure the performance of advertising.
Please note that ToraCode’s partners may have their
own policies related to tracking technologies for analytics and
ad-serving purposes. While
ToraCode requires that companies comply
with ToraCode’s privacy policy before ToraCode allows those companies to
access our sites and services, ToraCode does not actually control
third-party data collection and use. ToraCode encourages parents to
review the list of operators below and to become familiar with those
parties policies and practices.
If you have additional questions
about ToraCode’s Privacy Practices related to children under the age of
13, please contact us at [email protected].
- Further information
ToraCode makes good faith efforts to enable you to review, update or correct your personal data in ToraCode’s possession.
ToraCode will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.