Last Revised: Oct 20, 2017
Cool Tweens, its subsidiaries and its affiliates (“Company” or “we”) respect the privacy of the users (including children) of their mobile applications (“User” or “you”) and are committed to protect the Users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our Apps (defined below).
1. Your consent (important, please read carefully!)
We do not knowingly collect any personal information from Kids other than as expressly specified in Sections 3.2 and 3.3 below.
We hereby prohibit any User under the age of 13 from actively and directly providing us with any personal information other than as specified in Section 3.3 below. If you are a legal guardian of a child under the age of 13 and you believe that your child has provided us with any personal information, please contact us at firstname.lastname@example.org and we will delete such information from our servers.
Cool Tweens may collect and maintain the information described in Section 3, directly or through certain products or services, solely for the purpose of supporting Cool Tweens’s internal operations as permitted under applicable laws and rules (as described in greater detail below).
2. Offline Use
Cool Tweens allows an offline use (without Internet connection and without GPS enablement) of some features of its Kids Apps. Offline use of Kids Apps will preclude the collection by Cool Tweens and/or Third Parties of any information pertaining to you, as the legal guardian of a Kid, and/or your use (including, as applicable, information pertaining to your Kid and his/her use) of the Kids Apps.
3. Online Use
There are three types of data and information which may be collected from Users of our Kids Apps:
3.1 Non-personal Information: Cool Tweens and its Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Kids Non-personal Information”). To put it simply, with respect to such Kids Non-personal Information, Cool Tweens and the Third Parties are not aware of the identity of the User from whom Kids Non-personal Information has been collected. Kids Non-personal Information collected by either Cool Tweens or Third Parties may include technical information such as: type of operating system (e.g. Android, iOS, etc.), type of browser (e.g. Explorer, Firefox, Chrome, Safari, etc.), screen resolution (e.g. 800×600, 1024×768, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ad units, sites or applications, and campaigns a User came from), language (e.g. English), device type (e.g. Galaxy, HTC, iPhone, etc.), data regarding User behavior within our Kids Apps (e.g. advertisements impressions, User’s response to advertisements (including advertisements viewed or clicked), User’s in-app purchases, User’s gameplay (e.g. level reached, frequency and time spent in the Kids App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, tools and in-app functionalities used, screens accessed, User retention, performance errors and problems, Kids Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific advertisement and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), other Cool Tweens Apps installed, User age-related information (meaning whether a User passes an age-gate, if included to prevent access to certain features to Users who do not pass the age-gate to protect Kids privacy), randomly generated User ID which may not be matched back to the User, and geo-location – only at a country level. It is hereby clarified that no street name or city/town name is collected.
3.2 Kids’ Persistent Device Identifier and No Other Kids personal identifiable information:
Cool Tweens and Third Parties may also passively collect a persistent device identifier from Kids, such as IP address unique device identifier, advertising identifier (when available on a device) etc. (“Kids’ Persistent Device Identifier”). Cool Tweens does not collect and does not permit Third Parties to collect from Kids any information that may personally identify an individual (e.g.name, address, e-mail) (other than the Kids’ Persistent Device Identifier which is collected for the limited purpose of supporting the internal operations of the Kids Apps) and any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that Cool Tweens may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies.
Cool Tweens does not link any additional personally identifiable information to the Kids’ Persistent Device Identifier, even from other services.
3.3 Information gathered through the Kids Apps “Ask a Question” or “Support” type of a feature:
If a Kid e-mails a question to Cool Tweens, using the “Ask a Question” or “Support” type of a feature which may be available within the Kids Apps, Cool Tweens may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at Cool Tweens’s discretion, not responding) to such question, Cool Tweens will delete the Kid’s e-mail address.
Purpose of the collection: The information abovementioned is collected and processed solely for the purpose of supporting Cool Tweens’s internal operations. This means the following:
- providing and improving Kids Apps as well as ensuring proper functioning of the Apps and services;
- maintaining or analyzing the functioning of the Kids Apps and services;
- authenticating Users (e.g. verifying the User's identity when interacts with advertisements or acquires in-app purchases);
- personalizing content and enhancing User experience;
- performing network communications;
- protecting the security or integrity of Users, Kids Apps and services;
- serving contextual advertisements;
- capping the frequency of advertising;
- ensuring legal or regulatory compliance;
- fulfilling a User’s request under Section 3.3.
The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.
How the Information about our Users of Kids Apps is being collected? The abovementioned Kids Non-personal Information and Kids’ Persistent Device Identifier are collected either by Cool Tweens or by Third Parties through the Users’ use of the Kids Apps, including, without limitation, through Third Parties’ SDK embedded in our Kids Apps. In addition, Kids Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Kids Apps, such as “cookies-like technology” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
Cool Tweens does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Kids.
4. Sharing Kids information with third parties
We may share the Kids’ Persistent Device Identifier only in limited cases, including the following:
- to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
- to detect, prevent, or otherwise address fraud, security or technical issues;
- to protect the rights, property, or personal safety of Cool Tweens, its Users, suppliers, licensors, and/or licensees, or the general public;
- when Cool Tweens is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
- pursuant to the approval of a Kid’s legal guardian, in order to supply certain services that such legal guardian or the User of the Kids Apps may have requested from the Company;
For avoidance of doubt, Cool Tweens may transfer and disclose Kids Non-personal Information to third parties at its discretion.
In addition, Cool Tweens may, at its discretion, advertise other Cool Tweens Apps within the Kids Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random Cool Tweens Apps.
6. Additional Terms and Conditions
7. Which information may be collected from Users of our Apps for Everyone?
There are two types of data and information which may be collected from Users of our Apps for Everyone:
7.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or our third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). Cool Tweens and Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to Cool Tweens and/or Third Parties through use by Users of the Apps for Everyone. Non-personal Information which may be collected may include, for example, aggregate data, technical information, statistical information and behavioral information, and may contain, inter alia, device type, type and version of operating system, network provider, browser identifiers, type of browser, screen resolution, session information, User’s click stream on the Apps for Everyone, SDK version, API key, time spent playing, browser cookies, levels achieved, application version, in-app purchases and data regarding receipt validation, network status, local and time zone, clicks on advertisements Third Parties display on the Apps for Everyone, certain information about the advertisements reviewed by the User, the activities of the User in the Apps for Everyone (including without limitation any information relating to the User's activity in connection with the advertising displayed therein), what tools in the Apps for Everyone the User uses, etc., as well as the categories of data mentioned in Section 3.1 above.
7.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.
- Facebook Login feature: A User who wishes to enjoy certain features which may be available on our Apps may open an Account by using the “Log-in with Facebook” feature. Additionally, if a User uses the "Log in with Facebook" feature (which functionality is described in the TOU) then Facebook provides us with access to (i) certain information about such User as is stored in the User’s Facebook account, namely, the User's public profile (i.e., User's name, profile picture, email address, gender and other public information) and his/her list of friends and/or any other information which is detailed and displayed to the User in the notice which appears during the "Log in with Facebook" process. Please read carefully such notice in order to understand what information is available to Cool Tweens via Facebook and (ii) information available in the Facebook Page Insights of the applicable App for Everyone. We may collect and/or process the identifier number of the User’s Facebook account Facebook access token, User’s Facebook profile name, a link to the User’s Facebook profile picture, User’s e-mail and the User’s Facebook friends who installed the applicable App for Everyone, to the extent legally permissible. Please remember that the manner in which Facebook uses, stores and discloses your information is governed solely by its policies and Cool Tweens shall have no liability or responsibility for the privacy practices or other actions of Facebook that may take place within the Apps for Everyone. If the User uses the "Log in with Facebook" feature, then such User agrees that we may share his/her name and/or profile picture and/or his/her game data (such as moves, progress in our games and scores) with respect to the applicable Apps for Everyone, with Users who have also used the "Log in with Facebook" feature in connection with the applicable App for Everyone or with the User's Facebook contacts. If you do not agree to these practices please do not use the “Log in with Facebook” feature in any of our Apps for Everyone.
- Opening an Account: When Users open an Account, they are required to provide their full name, e-mail address and to choose and confirm a password, birthday, gender, location (country). The User may be able (but is not required) to provide, the following details: links to other profiles of the User (e.g., Facebook page, Pinterest, YouTube, his/her own website, etc.). Please note that with respect to certain Apps, once User Generated Content created within an App is posted by a User within the App or in his/her Social Network or Platform, the details in his App profile will be visible to other Users of that App or Social Network or Platform users.
In addition, Cool Tweens may collect and/or process, directly or through Third Parties, the following Personal Information:
- the User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;
- the User’s personal identifiers (such as, advertising identifiers (when available on a device), device identifiers, for example the IP address, carrier user ID, Media Access Control (MAC) address or social network ID). We note that Cool Tweens may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies. We are also able to identify when a User installs an App for Everyone as a result of advertisements and/or campaigns that we launch on other services, including in Social Networks or Platforms (e.g. on Facebook or otherwise) and the source-ad which led to such installation and when a User views or clicks on such advertisements;
- information in connection with User’s activities within the Apps for Everyone including use of the services therein, including notifications, invite data, monetization events, game progress, accomplished stages, how long User spent in the game, inventory items, currency, etc.;
- geo location data from GPS-enabled device (to the extent that the User explicitly allowed it) provided by the devices’ interaction with the Apps for Everyone or association with your IP address. In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as, websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 20; and/or
- identifier numbers of User’s account on Google Play Games or Apple Game Center, if enabled by the User in Apps for Everyone.
For avoidance of doubt, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
Cool Tweens does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Users.
8. How the Information about Our Users is being collected?
There are three main methods:
8.1 Non-personal Information may be collected through your use of the Apps for Everyone. In other words, when you are using an App for Everyone, Cool Tweens and Third Parties are aware of it and may gather and collect, including without limitation, through such Third Parties’ SDK embedded in our Apps for Everyone, the information relating to such usage. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the Apps for Everyone, such as “cookies” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
8.2 Personal Information which you provide Cool Tweens directly and/or through Third Parties via your installation and/or use of the Apps for Everyone or behavior with respect to advertisements thereof (such as your advertising identifier, persistent identifier and/or your geo location data), inter alia, through such Third Parties’ SDK embedded in our Apps for Everyone. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the Apps for Everyone, such as “cookies” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
8.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides Cool Tweens through the Apps for Everyone “Ask a Question” type of feature, when he/she opens an Account or when he/she makes his/her User Generated Content available to others. In addition, we collect Personal information which you voluntarily provide when you use the "Log in with Facebook" feature (as further detailed above).
9. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
Use it for statistical, analytical and research purposes and for customization, development and improvement of our Apps for Everyone (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on preferences shown by Users usage within the Apps for Everyone).
Measure traffic and usage on the Apps for Everyone.
Promote our Apps.
Personal Information is collected in order to:
Personalize and enhance the Users experience while using the Apps for Everyone.
Improve the Apps for Everyone.
Provide the Users with personalized content and information, including customized advertisements, interest-based advertisements, targeted advertisements, etc.
Enable certain ad serving features, such as, frequency capping, etc.
Enable certain functionalities available within the Apps, for example in-app purchases.
Ensure proper functioning of the Apps and services, respond to questions or requests which were provided using the “Ask a Question” feature.
Enable the User to use the Game Center Features, the Social Features and the features which are available while using the "Log in with Facebook" feature.
Provide Users with updated information regarding our products and services, including without limitations with respect to competitions which we may hold from time to time.
To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User's participation.
Authentication purposes including to verify the User's identity when he/she signs in to the App or his/her Account; verify clicks and/or installs, verifying User's identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.
Measure reach and effectiveness of advertisements campaigns, to offer targeted advertising, to personalize experience by showing advertisements for products and services that are more likely to appeal to the User (i.e. behavioral advertising).
Send push notifications to the User's device after the User has agreed to accept push notifications from Cool Tweens or Third Parties. Users can deactivate push notification by changing the settings within the App and/or changing the notification settings in accordance with the instructions of the operating system running on the Users’ device. Users may also opt out by clicking the "unsubscribe" option contained in the message.
Any other purpose explained at the time collection.
10. Sharing Information with Third Parties
We may share Personal Information only in the following cases:
10.1 to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
10.3 to detect, prevent, or otherwise address fraud, security or technical issues;
10.4 to respond to claims that any content published on the Apps for Everyone violates any right of a third-party;
10.5 to protect the rights, property, or personal safety of the Company, its Users, suppliers, licensors, and/or licensees, or the general public;
10.6 when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned;
10.7 pursuant to your explicit approval prior to the disclosure;
10.8 as part of a competition, receiving rewards or otherwise interact with our social media channels.
For avoidance of doubt, Cool Tweens may transfer and disclose Non-personal Information to third parties at its discretion.
Please note that some of the Apps for Everyone include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.
In addition, Cool Tweens may, at its discretion, advertise other Cool Tweens Apps within the Apps for Everyone. Such advertisements are not directed towards specific Users but are rather broadly posted onto random Cool Tweens Apps.
12. Using Game Center Features and Social Features
Our Apps for Everyone may enable using certain Game Center Features and may include Social Features (defined in our TOU). The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”).
By using the Social Features and/or the Game Center Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby understand and agree that when you share content via Social Networks or Platforms that your content may become public and any person may re-post-it.
13. Using a feature which enables purchase of Merchandise
14. Additional Terms and Conditions
15. Third Party Providers
16. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. Cool Tweens does not exercise control of such third parties and is not responsible for their privacy practices and their use of the Users’ personal information. You hereby consent to the collection and use of your Personal Information by such third parties in accordance with their privacy policies.
17. Links to Third Party sites
18. Cookies & Local Storage
19. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifier or limiting ad tracking setting. If you are using Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent that such options exist) may not cease all tracking activities by Cool Tweens’s third parties' service providers.
If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such third parties and follow the instructions specified therein, including without limitation, if you wish to opt out from Flurry Analytics tracking and personalized advertisements/recommendations from Flurry, please use the following link: https://www.flurry.com/user-opt-out.html. If you wish to opt out of certain Unity Technologies ApS' personalized advertisements, please view Unity's policies at: https://unity3d.com/legal/cookie-policy#cookies. We also note that Users can opt-out of the Google Analytics Advertising Features, including through ads settings, ad settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out) by going to the User's Google account settings on the User’s device and changing the User's preferences in accordance with the instructions of the device’s manufacturer and the operating system running on your device.
20. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
21. Direct Marketing
You hereby agree that we may use the contact details you provided us to inform you regarding competitions we may hold, our new products and/or services, and to send to you other material. You may withdraw your consent by changing the settings within the App, and/or by clicking the ‘unsubscribe’ option or alternatively following the instructions for removing yourself from the mailing list which are contained in the message which was sent to you.
22. California Privacy Rights
To the extent applicable, (i) California Civil Code Section 1798.83 may permit our Users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request please send an email to email@example.com. Cool Tweens is only required to respond to one request per user each calendar year; and (ii) if you are a California resident under the age of 18 and a User, California Business and Professions Code Section 22581 may permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.
Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
23. Deletion and Modifications of Information
You or, as applicable, your legal guardian, may request, by sending us an email to firstname.lastname@example.org, the following:
to receive access to, amend, and/or delete your Personal Information and/or, as applicable, Kids’ Persistent Device Identifier, that we may hold, and/or that we cease collection or use of your Personal Information; and/or
that we request Third Parties who collected through the Apps the User’s Personal Information and/or, as applicable, the Kids’ Persistent Device Identifier, to do the same. Cool Tweens will use reasonable efforts to ensure that such Third Parties do so.
We note that some of these actions may be done directly through the settings of your Account.
After you have stopped using the Apps and/or following the termination of your Account, we will retain User’s Personal Information, and, as applicable, Kids’ Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfill the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, to enforce these Terms and our agreements and/or to enable Users to reinstate their Account, all as permitted under applicable privacy laws.
Personal Information that a User has shared using our Apps for Everyone via any Social Network or third party Platform cannot be amended or deleted by Cool Tweens, where such information is in the control of that Social Network or third party Platform. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps. Aggregate and/or anonymous information may remain on our servers indefinitely.
Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. Cool Tweens SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.
26. Got any Questions?