Effective Date: December 29, 2021
As used in this Privacy Policy, “We”, “Us” or “Our”, refers to “Talefun”.
This Privacy Policy is part of and incorporated by reference into the
Terms of Service (the “Terms”) governing the use of all our
branded software applications (the “Application/s”), which may operate on any type of computing device (including
without limitation, a mobile device), and applies to your use of the
Applications and/or URL which may replace it or which may be added to the list
of websites published by us and linking to this Privacy Policy (the “Website/s”).
By agreeing to the Terms and/or using the Websites or the Applications,
you particularly agree to the collection, use and disclosure of your
information (including personal information) in accordance with this Privacy
Policy. We may collect and/or you may be asked to provide us with your
information (including personal information) any time you are in contact with
us or use the Applications or the Websites.
Please read this Privacy Policy in order to learn more about the data we
collect, what do we use it for and how we protect your privacy.
We reserve the right to update this Privacy Policy from time to time. We
will notify you (for example, by email or through our Application)
at least 30 days before we make changes to these Terms and Policy and give you
an opportunity to review them before they go into effect, unless changes are
required by law. Once any updated terms are in effect, you will be bound by
them if you continue to use our Application.
We hope that you will continue using our Application,
but if you do not agree to our updated terms, you can delete your account at
any time.
Collection of device and technical
information
We might collect the data necessary for you to use our app and for us to
maintain and analyze the functioning of the app and to personalize the content
of the app.
We automatically obtain certain information about your computing device,
including IP address; Country code; Time zone; session start/stop time; IDFVs,
Language; Network status (WiFi, etc.), browser
plug-in types and versions; platform, SDK version, timestamp; Technical device
information (e.g. device model and name, operating
system name and version, CPU information, storage size, screen size, firmware,
software API key identifier for application, Push notifications token. Although
some of this information (such as IDFA, IDFV, IP address) may uniquely identify
your device, this information does not identify you personally. Some
legislation (such as US) may treat information that uniquely identifies your
device as personal information.
Collection of classical personal
information
We may also collect personally identifiable information about you (such as
your name and surname, email address), as well as non-personally identifiable
information (such as age range and gender) that you provide us by using our Applications or contact us directly via email.
We will only use the contact information you provide to us (for example,
your name and email address) for the purpose for which you provided it to us.
We will not share this data with third parties.
If you wish to delete your contact information that we received upon your
specific email inquiry, please send an e-mail and your e-mail will be deleted
from our database.
When you use our Services, you may register an account with us to track
your progress and to sync your activity across devices. To register an account,
you may be asked to provide certain personal information to us, including your
name, email address, and password. You are solely responsible for ensuring your
account information is correct and up-to-date.
Information from Social Media Platforms
You may also choose to create an account with us using your Facebook or
Google account credentials. When you log in using your Facebook or Google
account, you authorize Facebook or Google to provide us with your personal
information such as your name, profile picture, email address, language preference,
and other information as listed in the authorization.
Information You Provide to Us
We collect personal information you provide to us when you use our
Services. For example, you may provide additional account information, such as
your language preferences. You may also provide information when participating
in surveys, sweepstakes, contests, or events, such as your contact information.
You are solely responsible for ensuring the information you provide to us is
correct and up-to-date.
When you use our features, we may collect information such as your
painting history on the app, paint artifacts, completed works, and purchase
history.
While accessing or using the Services, we may automatically collect
information about how you interact with the services. Such information may
include your Internet Protocol (“IP”) address, device identifier,
advertising identifier, MAC address, operating system, browser type, language
preferences, referring and exiting pages, crash data, location data, purchasing
activity, and other data regarding your activities on the Services. For more
information, see the section on Cookies and Similar Technologies (“Tracking Technologies”).
We collect the personal information you provide to us when you contact us
for customer service, to provide feedback, or to request information.
2. Purposes of Collecting, Processing
and/or Disclosing
• Detecting/Protecting against security events
• Internal analytics and reporting
• Customer service
• Operate our business and games
• Game mechanics or functionality
• Facilitate players’ social interactions
• Product development/improvement
• Maintaining and enhancing service
• Auditing consumer interaction & transactions
• Advertising
• Direct marketing
• Player acquisition
3.How We Use Your Information
We shall use your personal information for the following purposes:
We use your personal information to provide you with our mobile
application and any other Services you request. This may include processing
transactions, providing you with the requested features, syncing your painting
history across your devices logged into your account, customer service, etc.
To Personalize Your Experience
We may process your information to personalize the Services for you. For
example, we use your language preferences and country location to display the
correct language and time zone in the Services. We also use certain information
about your device (such as operating system version and screen resolution
information) to optimize the display of pictures on your screen.
We will use your information (such as contact information) to send you
communications about your account, requested transactions, and changes in our
policies. Please note that you may not opt out of such communications, which
are necessary to keep you informed about important updates about your account
and the Services.
To Conduct Analytics and Other Internal
Purposes
We may use your personal information to conduct analytics. This can be
used for quality control, internal auditing, and to measure how our mobile
application and ad campaigns are performing.
To Ensure Security of our Services
While we are offering services, it is used for the purposes of identity
verification, customer service, security protection, fraud monitoring,
archiving and backups, ensuring the security of the products and services that
we provide to you.
To Conduct Research and Development
We may process your personal information to improve our existing Services
and help us design new ones. When we do so, we may implement security measures
and safeguards to protect the privacy of your personal information. For
example, we may institute technical safeguards or administrative safeguards,
such as restricting access to personal information to only those who need
access to conduct the research and development functions.
We use your personal information for our marketing activities. For
example, we may conduct targeted marketing and send you information about our
and our partners’
products, events, and market studies that may be of interest to you.
To Maintain Legal and Regulatory
Compliance
Our Services are subject to certain laws and regulations which may require
us to process your personal information. For example, we process your personal
information to pay our taxes, to fulfill our business obligations, and to
manage risk as required under applicable law.
4. Sharing of Your Information
We may share your personal information in the following circumstances.
We are multinational organization, with cross-border legal entities and
management structures. We may share your personal information within our
corporate organization to facilitate the Services; however, we will require
that your personal information still be handled in the manner describe herein.
We may use third parties to perform certain functions on our behalf to
provide you with the Services such as:
to process payments and complete transactions you request, such as
payments for our subscription service, which is processed by Apple (App Store)
or Google (Google Play Store);
to process and store data, including your personal information;
to provide security for our Services; and
to conduct market research.
We have agreements with third-party service providers in place to ensure
they use adequate safeguards when processing your personal information.
Merger, Acquisition, or Other Business
Transaction
We may disclose and transfer your personal information to a subsequent
owner, co-owner, or operator or the Services, or in connection with a merger,
acquisition, consolidation, restructuring, or the sale of substantially all our
interests and/or assets (i.e., a bankruptcy proceeding). We shall require the
subsequent owner, co-owner, or operator in possession of your personal
information to continue to be subject to this Privacy Policy; otherwise, we
shall request that they obtain the necessary consent from you.
We may disclose your personal information if it is reasonably necessary
to:
Comply with a valid legal process (e.g., subpoenas, warrants, court
orders, etc.);
Comply with valid requests or investigations by public authorities;
Comply with applicable laws or regulations;
Enforce our policies, agreements, and terms, whether in litigation, other
disputes, or otherwise;
Protect our legitimate interests, including legal interests;
Protect the security or integrity of the Services; or
Protect the rights, property, or safety of you, other users, employees,
partners and affiliates, or other natural persons.
We will, at our discretion, provide you with advance notice if we are
compelled to disclose your personal information to law enforcement, public
authorities, or other governmental entities, unless we are prohibited from
doing so by governmental entities or the law.
We may transfer your personal information for other reasons after
obtaining your consent.
5. How to Exercise Your Rights
You may access, amend and delete information provided by you when using
our Applications, or contact us at contact@talefun.com. The scope and the way in which you
access, amend or delete your personal information depend on the service you
use.
You may opt-out of receiving promotional communications, such as marketing
emails we send you, at any time. If you wish to do so, please e-mail us
at contact@talefun.com. You can turn off
push notifications by visiting the “options” or “settings” page within the
relevant games.
You can opt-out of interest-based advertising on mobile applications by
checking the privacy settings of your Android or iOS device and selecting
“limit ad tracking” (Apple iOS) or “opt-out of interest based
ads” (Android). For personalized in-game offers opt-out, you can use the
options provided in the game settings.
If for any reason you are concerned with the way we are using your
personal information, or would like to correct or request that we delete such
personal information, please contact us using the information in the “Contact
Us” section below. We will respond to your request as promptly as possible.
In some cases, we may not be able to delete your personal information and
will retain and use our information as long as necessary to comply with our
legal obligations, resolve disputes, and/or enforce our agreements.
6.Tracking Technologies
What are cookies and tracking
technologies?
Cookies are small data files, typically of letters and numbers, that are
placed by a web server on your device. We and companies we work with may use
cookies and similar technologies, including pixel tags, web beacons, mobile
analytics features, and mobile identifiers (collectively, “tracking technologies”) to collect information for many reasons, such as to keep you
logged in to your account, remember your preferences and settings, analyze
usage of our Services, measure the performance of our Services and advertising
campaigns, and ensure security on our Services. Some of the functions performed
by tracking technologies are strictly necessary for us to be able to offer you
our Services, while others provide us with valuable insight about how we can
improve or market our Services.
What types of tracking technologies do we use?
We use the types of tracking technologies described below on our Services:
Types of Tracking Technologies and Its
Description
Strictly Necessary
Some of the tracking technologies we use are necessary to provide our
Services to you. For example, they help you: navigate from page to page; stay
logged into your account; and support and enable security features. Without
such tracking technologies, some of our Services cannot be provided to you.
Functional
Functional tracking technologies collect information about how you use our
Services, provide you with certain functions on our Services, and remember your
preferences.
Analytics, Performance and Research
These tracking technologies help us understand how well our Services are
doing. They collect information about your use and interaction with our
Services so that we can continue to improve and expand our Services.
Marketing
Marketing tracking technologies allow us to collect information about your
interactions with our marketing activities, such as parts of our website and
our emails. They help us measure performance of our Services and advertising
campaigns.
How to manage tracking technologies
We use third-party tracking technologies that allow us to automatically
collect information through our Services that can recognize your device both
when it visits our Services and when it visits other websites or mobile apps.
We encourage you to check the websites of any third-party tracking technologies
providers for more information about how they use the information they collect.
Below we describe how you can manage tracking technologies on our
Services:
Through Your Browser/Mobile Settings
You can enable, disable or delete tracking technologies via your browser
settings. To do this, follow the instructions provided by your browser, usually
located within the “Help”, “Tools” or “Edit” settings
of your browser or mobile device. Please be aware that if you set disable
tracking technologies on your browser, you may not be able to access secure
areas of the Services and parts of the Services may also not work properly
(e.g., preferences, referral links).
Many browser manufacturers provide helpful information about cookie
management, including, but not limited to:
Google Chrome
Internet Explorer
Mozilla Firefox
Safari (Desktop) or Safari (Mobile)
Android Browser
Opera
If you use a different browser than those listed above, please refer to
your specific browser’s documentation or check out http://www.allaboutcookies.org/browsers/index.html to learn more
about different browsers. You can also find out more information about how to
change your browser cookie settings at www.allaboutcookies.org.
You may be able to control or limit mobile tracking technologies in your
mobile device settings. Please follow the instructions provided by your mobile
device, usually located in “Settings” of your mobile device.
Many mobile device manufacturers provide helpful information about how to do
this:
Apple https://www.apple.com/legal/privacy/en-ww/
Google/Android https://policies.google.com/privacy
Through Third Parties
You may also check the third party’s website below for information about
how they use tracking technologies to collect and use your information, and how
you may be able to opt out of tracking.
Google Firebase Analytics: To conduct usage and advertising analytics
https://policies.google.com/privacy?hl=en-US
Facebook Analytics: To conduct usage and advertising analytics
https://www.facebook.com/policy.php
https://www.facebook.com/policies/cookies
Appsflyer: To conduct usage and advertising analytics
https://www.appsflyer.com/privacy-policy/
AdMob
https://support.google.com/ads/answer/2662922
https://support.google.com/admob/answer/9012903
Max
Adx
https://support.google.com/ads/answer/2662922
Adcolony
https://www.adcolony.com/privacy-policy/
AppLovin
https://www.applovin.com/privacy
Chartboost
https://answers.chartboost.com/en-us/articles/200780269
OpenX
http://openx.com/legal/privacypolicy/interestbasedadvertising/
Display.io
https://www.display.io/en/privacypolicy/
Facebook
https://www.facebook.com/help/568137493302217
https://www.facebook.com/about/privacy/update?ref=old_policy
Flurry
https://www.oath.com/en-gb/my-data/
PubMatic
https://pubmatic.com/legal/opt-out/#IBA
Fyber
https://www.fyber.com/legal/privacy-policy/
Apple
https://support.apple.com/en-us/HT202074
Google (Ad Words)
https://support.google.com/ads/answer/2662922?hl=en;
Google
https://policies.google.com/privacy
Inneractive
http://inner-active.com/privacy-policy/
Mopub
https://www.mopub.com/legal/privacy/
Mintegral (Mobvista)
https://www.mintegral.com/en/privacy/#yourDataRights
AerServ
https://www.aerserv.com/third-party-opt-out/
Unity
https://unity3d.com/legal/privacy-policy
Smaato
https://www.smaato.com/privacy/#section4
Ironsource
https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Vungle
Tapjoy
https://dev.tapjoy.com/faq/tapjoy-privacy-policy/
Pangle
https://partner.oceanengine.com/privacy
Appsflyer
https://www.appsflyer.com/services-privacy-policy
https://www.appsflyer.com/terms-of-use/
PubMatic
https://pubmatic.com/legal/opt-out/#IBA
AdAction
https://www.networkadvertising.org/mobile-choices
Twitter
https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
We are included with third party advertising for their products and
services. We and our partners use your information to improve advertising and
targeting to measure the relevant third-party ads to show in our games.
Information we may have about you such as: ad identifiers and other non-personal
information collected from your device, how you interact with our game and
Services the game play information, your age, country or region, and gender,
and other information collected from third parties with legal right to share it
with us are used to make sure that you only see ads from us that might be of
interest to you.
Non-personal identifiers and other information collected from your device
when you play our games or use our Services are shared with advertising
partners in order to technically deliver the ads to your device. Such
information may be combined with collected information of our advertising
partners own to serve you with more relevant ads and to enhance the accuracy of
their targeting. For more information we recommend for you to scan through our
partners’
privacy policies on their websites.
We use ad identifiers that are non-permanent, non-personal identifiers
such as the Android and/or Apple’s ID for advertising associated with your device, and
similar technologies such as tracking pixels within ads to provide
interest-based advertising. These technologies enable us and our third-party
advertising partners to recognize you and your device, allow our Services to
interact with a third-party social network or platform and help our payment
processors to work it out your payment instructions.
How to reset your preferences for
advertising
You may reset your ad identifier being used for interest-based advertising
by changing the settings of your device usually found under “privacy” or “ads”. You can
also opt-out from your information being collected if you live in the USA,
Europe or Canada by visiting http://www.aboutads.info/choices/ (for US
users), http://www.youronlinechoices.com/ (for European
users) or http://youradchoices.ca/choices (for Canadian
users). The full use of our Services may not available if you choose to adjust
your preferences.
We may offer social sharing features and other integrated tools enabling
share actions you take in the apps with other media. You must be over the
minimum age limit prescribed by the legislation in the individual jurisdictions
to use such social sharing features which may, depending on the settings you
set with the entity, share information with your friends or the public.
Our Services has social features from the following providers, for more
information about the processing driven by the third parties regarding social
sharing features, please visit the privacy policies of the entities found here:
• Facebook: https://www.facebook.com/about/privacy/
• Game Center: https://www.apple.com/legal/privacy/en-ww/
• Google Play Games: https://www.google.com/policies/privacy/
We take the security of personal information seriously. We adopt standard
practices in the internet industry to protect your personal information from
unauthorized access, disclosure, use, alteration, and corruption or loss. We
shall take all reasonable and feasible measures to protect your personal
information. We shall do everything possible to take appropriate technical
measures to ensure the accuracy and timely update of the personal information
collected about you.
Please understand that due to the nature of the internet industry, it is
impossible to ensure that systems are 100% secure. You should understand that
the systems may encounter issues due to the factors beyond our control, such as
malicious actors. Although the security of your personal information is our
highest priority, there will always be a risk that your Personal Information
gets compromised. We also depend on you to keep your account information and
other personal information secure by keeping your password confidential and
taking precautions to keep others from accessing your account.
In general, we keep your information for as long as necessary to achieve
the purposes stated in this Policy or to comply with the applicable law.
We recognize that retention requirements can vary between jurisdictions,
but we generally apply the retention periods described below.
We will retain information associated with your account as long as your
account remains active or as necessary to provide you with the requested
services.
Information collected from tracking
technologies:
We generally retain such information for as long as necessary for usage
analytics, the establishment or defense of legal claims, audit, or fraud and/or
crime prevention purposes.
Any contact information you provide to us for marketing purposes, such as
your name, email address, and phone number, is retained on an ongoing basis
until you unsubscribe from our marketing communications. If you unsubscribe, we
will add your contact information to our do-not-contact list to respect your
unsubscribe request.
Our Services are not intended for use by children under the age of sixteen
(16). We will not knowingly collect personal information directly from children
under the age of sixteen (16) without parental consent. If you are under the
age of sixteen (16), please do not provide us with information of any kind
whatsoever. We encourage parents and guardians to spend time with their
children online and to be familiar with the websites they visit. If you have
reason to believe that we may have accidentally received information from a child
under the age of sixteen (16), please contact us immediately.
To use and play our Services you must be over a certain age depending on
where you live. For the full list of age restrictions by country, please see
below. We do not knowingly collect personal information from or direct or
target interest-based advertising to anyone under the ages set out below. We
also do not knowingly allow such persons to use our Services, if in any way
such personal data have been processed under the age set out below, please
contact us so we can delete that information as quickly as possible.
Please see below listed with age you must be to play and use our games and
Services depending on which country you are in while using our games and
Services. Please do not play our games or use our Services if you are under the
relevant age.
Some Internet browsers - like Internet Explorer, Firefox, and Safari -
include the ability to transmit “Do Not Track” (“DNT”) signals. Since uniform standards for
DNT signals have not been adopted, we currently do not process or respond to
DNT signals on our Services.
13.Special Notice to Individuals in the
European Economic Area, United Kingdom, and Switzerland (GDPR)
This section only applies to individuals located in the European Economic
Area (“EEA”), United Kingdom (“UK”), or Switzerland (collectively, the “Designated
Countries”) at the time their personal information was
collected.
We may ask you to identify which country you are in when you use or access
some of the Services, or we may rely on your IP address to identify which
country you are located in. When we rely on your IP address, we cannot apply
the terms of this section to any individual that masks or otherwise hides their
location information from us so as not to appear located in the Designated
Countries. If any terms in this section conflict with other terms contained in
this Policy, the terms in this section shall apply to individuals in the
Designated Countries.
14.California Privacy Rights (CCPA)
If you live in California, you can ask us for a list of third parties we
share your Personal Information with for marketing purposes.
California law permits California residents to ask us for a notice that
identifies the categories of personal information that we share with our
affiliates and/or third parties for marketing purposes, and that provides
contact information for such affiliates and/or third parties. If you are a
California resident and would like a copy of this notice, please submit a
written request to us with your name, account information, and proof of
California residence with the subject line “My California Privacy Rights” by email.
General Data Protection Law (GDPL)
The General Data Protection Law (GDPL), also referred to as LGPD in
Portuguese (Lei Geral de Proteção
de Dados Pessoais) is a Federal Law in Brazil that
comprehensively regulates data protection.
We enable compliance
with the GDPL mechanisms and data protection measures when we process personal
data. If you have any questions regarding GDPL compliance please contact us by
email.
We periodically review our compliance with this Privacy Policy. When we
receive formal written complaints regarding privacy issues, it is our policy to
contact the complaining user regarding his or her concerns. We will cooperate
with the appropriate regulatory authorities, including local data protection
authorities, to resolve any complaints regarding the transfer of personal data
that cannot be resolved between us and an individual.
16.Changes to this Privacy Policy
We may amend this Privacy Policy from time to time. Any changes will be
placed here and the amended version will supersede this version of our Privacy
Policy. Use of information we collect is subject to the Privacy Policy in
effect at the time such information is collected. We will take reasonable steps
to draw your attention to any changes in our Privacy Policy. However, to be on
the safe side, we suggest that you read this document each time you use the
website to ensure that it still meets with your approval.
We will notify you (for example, by email or through our Application) at least 30 days before we make changes to
these terms and give you an opportunity to review them before they go into
effect, unless changes are required by law. Once any updated terms are in
effect, you will be bound by them if you continue to use our Application.
We hope that you will continue using our Application,
but if you do not agree to our updated terms, you can delete your account at any
time.
For any questions regarding our Privacy Policy or our privacy practices,
please contact us at contact@talefun.com