Teatime Games Inc. Privacy Policy

Last Updated: November 22st 2019

We are Teatime Games. We provide a mobile gaming platform and Games that allow you to connect and play with friends all over the world. To do this, we need information about you. This Privacy Policy will help you understand how we collect and use your information and what choices you have when you play our Games, use our Apps, use our Site, or otherwise provide information to Teatime Games (collectively, our “Services”). All terms not defined in this Privacy Policy will have the meanings set forth in our Terms of Service (https://www.teatime.games/legal/terms).

1. Personal Information We Collect

The categories of personal information we collect depend on whether you play our Games (“User”), develop games on our platform (“Developer”), or visit our website:

• User Account Information. When you sign up for an Account with our Services, you provide us with personal information. This may include your age, name, username, email, gender, the city where you are located, phone number and your profile picture. We may also collect information about Virtual Goods and Game Currency you purchase across different Games included in our Services.
• Developer Account Information. To create a developer account, you must provide your name, email, company website, country, and the type of game you’d like to create.
• Surveys.  We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information, which may include personal information.
• Registration for Sweepstakes or Contests.  We may run sweepstakes and contests.  Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law.  In some jurisdictions, we are required to publicly share information of winners.
  
  
• Facebook and Google Sign In. Teatime Games may allow you to register for an Account and use our Services with certain third-party social networking services such as Facebook or Google (each, an “SNS Account”). If you use our Services with an SNS Account, we will receive basic information tied to those accounts that you have made public, such as your unique user IDs or tokens that each company uses, profile picture, and contacts (if you choose to provide them).
  
  
• Video Chat. When you use our Services, Teatime Games may allow you to video chat with other users using the camera on your device. If you choose to use the video chat and related features, the audio and video of you and your surroundings will be captured by Teatime Games and other users will be able to see and hear you.
  
  
• Mask. When you set up an Account, Teatime Games may allow you to try on and wear a virtual helmet or other similar game wear known as a “Mask.” To do this, the Game detects where your face is in your “selfie camera” view mode to best fit your Gameface with your actual face. We only use this information to enable your use of the Mask feature. You may customize a version of your Mask to use as your profile picture, which may be visible to other users that are searching for games or searching for you.
  
  
• Social Features. Teatime Games may offer interactive features such as chat services, forums and social media pages. Teatime Games and other individuals who use our Services may collect the information you submit or make available through these features.
  
  
• Information from Your Use of the Services. We may collect certain information automatically when you use the Services. This information may include your high scores, and other details about your gameplay, Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, details about your browser or device, geo-location information, Internet service provider, pages or areas that you visit before and after using the Services, and other information about how you use the Services, such as the types of content you interact with and the frequency and duration of your activities. 
  
  
• Communications with Teatime Games. When you directly communicate with, provide Feedback, request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us, we may collect personal information such as your email address, phone number, mailing address, and other information contained in your message.
  
  
• Transactional Information. We and our service providers may process your Payment Information to facilitate a Transaction that you request.
  
  
• Information from Other Sources. We may obtain information about you from other sources, including through third-party services and App Providers to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your username, location, gender, age, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to Teatime Games and to enhance our ability to provide the Services.

2. Cookies, Pixel Tags/Web Beacons, and Analytics Information

We, as well as third-parties that provide content, interest based advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  
  
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
  
  
• Analytics. We may also use Google Analytics and other service providers to collect information regarding user behavior and user demographics on some of our Services, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s processing of data generated by your use of the Services by visiting http://tools.google.com/dlpage/gaoptout.

‍ Our uses of these Technologies fall into the following general categories:  

• Operationally Necessary.  This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  
  
• Performance Related.  We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  
  
• Functionality Related.  We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.  This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  
  
• Advertising or Targeting Related.  We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third- party sites.

3. Third-Party Websites and Software Development Kits

In using our Services, you may access links to websites and services that are owned or operated by third-parties (each, a "Third-Party Service"). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-Party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-Party Service that you access.

We use third-party software development kits (“SDKs”), such as Google Firebase, Firebase Analytics, Facebook Business Manager, Facebook Ads and AppsFlyer, as part of the functionality of our Services. Third-party SDKs may allow third-parties including advertisers to collect information about you to provide content that is more relevant to you. For more information, please contact us as set forth below.

4. How We Use Your Information

We only use your personal information where we have a legal basis to do so, including:

To Fulfil our Contract with You and Provide the Services or Information You Request, including to:

• Manage your Account and other information;
• Respond to questions, comments, and other requests;
• Provide access to certain functionalities and features of the Services;
• Provide customer or technical support;
• Verify or maintain the quality or safety of a service or device; 
• Process your financial information and other payment methods for products or Services purchased; and 
• Allow you to register for promotions, contests, and other events.

Administrative Purposes pursuant to our legitimate interest, including to:

• Measure interest in the Services;
• Develop, improve, upgrade, enhance, or create new products and Services;
• Ensure internal quality control;
• Communicate with you for various purposes;
• Verify your identity;
• Debug, identify and repair errors that impair existing intended functionality;
• Detect security incidents, prevent malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
• Enforce our Terms; and
• Comply with our legal obligations, protect your vital interest, or as may be required for the public good.

Provide you with additional content or services, including:

• To tailor and deliver content and advertisements; and
• For other purposes which you consent or otherwise agree to.

‍Use De-identified and Aggregated Information.  We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

5. Information We Share

We do not sell or disclose your personal information with third parties, except as provided below. For a list of the categories of personal information we have sold or disclosed about consumers for a business purpose in the past 12 months, you may contact us as set forth below. We may share your information as described in this Privacy Policy:

• Information Shared with Our Service Providers. We may share any information with our service providers. These service providers help us: (i) operate, improve and maintain our Services; (ii) perform content moderation and analytics; (iii) tailor and deliver advertising to you; (iv) provide technical and customer support; and (v) process payments. These service providers may only use your data to provide Services to us.
  
  
• Information Shared with Other Users. When you play our Games, use video chat, or use other social features, certain personal information including User Content may be shared with other users. This personal information may include your in-Game profile (such as your username, details about your Teatime Games profile, your profile picture), your Gameface, and any audio or images of you or your surroundings that your camera captures during a video chat. Please be aware that Teatime Games has little or no control over how individuals may use the information you share.

• Information shared with Developers. Developers of games published on the Teatime platform may receive information about you (such as your gameplay activity) when you play their games. 
  
  
• Information Disclosed for Our Protection and the Protection of Others. We cooperate with government, law enforcement officials, and private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third-party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.
  
  
• Advertising Partners.  Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information we have collected about you (such as your hashed email address, such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may contact us as set forth below.
  
  
• Information Disclosed in Connection with Business Transactions. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

6. International Data Transfers

You agree that all information collected via or by Teatime Games may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected, and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.

7. Your Privacy Choices

General.

You have the right to object to and opt-out of certain uses of your personal information. Where you have consented to our processing your personal information, you may withdraw that consent at any time by contacting us as set forth below. Note that we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.

(a) Email Communications.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt-out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

(b) Mobile devices.

Teatime Games may send you push notifications through our mobile applications with game updates, high scores and other notices. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Teatime Games may also collect location-based information with your consent if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

(c) “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

(d) Cookies, Interest-Based Advertising, and Analytics.

If you would like to opt out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of interest-based advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

8. Individual Rights

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your portable personal information, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information, including the opting out of the sale of your personal information to third parties, if applicable; (v) seek correction of inaccurate, untrue or incomplete personal information; and (vi) request erasure of personal information held about you by Teatime Games, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

To protect your privacy, Teatime Games will take steps to verify your identity before fulfilling your request.

9. Data Retention

Teatime Games retains your personal information pursuant to this Privacy Policy for as long as we need to provide the Services to you and fulfill the purposes for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Teatime Games will delete your Mask information within three years after your last interaction with us.

10. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

‍By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

11. Children’s Information

The Services are not directed to individuals under the age of 13, or in certain jurisdictions, under 16 (“Children” or a “Child”), and Teatime Games does not knowingly collect personal information from children. 

If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with Personal Information, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

13. Supervisory Authority

If you are located in the European Economic Area or UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

14. Updates to This Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

15. Questions or Comments

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

Headquarters:

Teatime Games, Inc.

Attn: DPO

470 Ramona Street

Palo Alto, CA 94301

United States of America

Office:

Teatime Games

Laugavegur 26

101 Reykjavík

Iceland

Email: support@teatime.games