TutoTOONS Privacy Policy

Last Revised: 2018 November 15th

TutoTOONS Limited ("TutoTOONS", "we") are committed to protecting your Personal Data. We offer services and games that can collect information from you and your children, so we have prepared a document called the Privacy Policy. In this Privacy Policy, we will explain what we do with the Personal Data that you provide to us or which we can collect from you in the provision of services to you.

This Privacy Policy is in compliance with the US Children's Online Privacy Protection Act (COPPA) and the European General Data Protection Regulation (GDPR).

Content

1. WHO WE ARE?

TutoTOONS Limited is a company with registered office in Scotland, Summit House, 4-5 Mitchell Street, Edinburgh, EH6 7BD, United Kingdom.

We are the Personal Data controllers responsible for your Personal Data. A Personal Data controller is the person who decides for what purposes Personal Data will be used.

Our contact details are as follows:

If you have questions about this Privacy Policy or wish to exercise your rights, contact us by email at [email protected].

2. WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

While you visit our website at www.tutotoons.com or you play TutoTOONS games ("Services" or "Games"), we may collect information about you ("Personal Data").

We care about your Personal Data protection, so we have developed this Privacy Policy.

By this Privacy Policy, we want to clearly and comprehensibly explain what data we collect, how we use, disclose and transfer it.

From time to time, we may change the terms of this Privacy Policy, so do not forget to read this Privacy Policy on a regular basis to understand how we use your Personal Data.

3. WHAT PERSONAL DATA WE COLLECT?

Note: You must update any mobile applications downloaded before 2018 May 25th

Personal Data refers to any information about a person which can identify that person.

We may collect, use, store and transfer various Personal Data we have grouped into these categories:

Contact Information. You can provide us with your Contact Information, such as your phone number and email when you contact us with a question or request.

If the child who lives in the USA and who is younger than 13 years old has contacted us through email, and we communicated with the child more than once, we will ask the child to provide us with the child's parent or guardian's email. Then we will send the parent or guardian a notice telling that his/her child has contacted us. If we do not obtain parental consent after a reasonable time from the date of the data collection, we will delete such data from our records.

Location Data.We do not collect data about your exact location (address) in any case. We can collect data about your location, i.e. city or country. We collect this data automatically when you use our Services or play our Games.

Technical Data.We may collect such information as your IP address, advertising ID, and other technologies on the devices that you use in our Services or play our Games. We can also collect non-personal Technical Data about the mobile operating system, mobile browser type, screen resolution, device vendor, language. We collect this data automatically when you use our Services or play our Games.

Usage Data.We can collect statistics on how you use our Services or play our Games. This information does not contain information that will help us identify you. We need this information so that we can provide you with the Services, improve their quality, adapt them to your needs.

We do not collect or store any financial data because processing of your financial data is done by your chosen payment service provider, such as iTunes, Google Play, etc.

We do not collect and do not intend to collect "special categories of data", such as any information about health, race, religion, political opinion or philosophical beliefs, sexual beliefs or orientation.

We do not collect any data that is not necessary for the provision of our services.

4. HOW WE COLLECT PERSONAL DATA?

We use several methods to collect Personal Data discussed further:

Personal Data is provided directly by you. You provide us with your data when you contact us by email, social networks or phone, ask to answer your question.

We collect Personal Data automatically.When you use our Services, e.g. visit our website, play our games, we can automatically collect technical information about your IP address, promotional identifiers, equipment, browsing actions and models you use, as well as statistics. We collect this Personal Data using cookies, automated event logs and other similar technologies.

We collect Personal Data from third parties. We may receive Personal Data about you from third-party sources, i.e. from another companies and persons (see section Our third party data controllers and processors).

5. HOW WE USE PERSONAL DATA?

We will only use your Personal Data as permitted by law. Usually, we will use your Personal Data in the following circumstances:

In order to fulfil our obligations when you use our website or our mobile applications, e.g. to ensure that the Services are provided, to improve the Services, to personalize the content you use, to respond to your requests and inquiries. Also, in order to fulfil our legal obligations, we may ask for the child's parent or guardian's email when we must obtain the consent of parents or guardians to use the child's Personal Data (email and name).

When it is necessary to fulfil our contractual obligations or safeguard our legitimate interests, we use your Personal Data, e.g. to provide you with contextual advertising, to analyse your behaviour using our Services, to ensure the security and integrity of our Services.

We may also use your Personal Data to enforce or defend our rights, protect your interests, prevent and/or detect fraud or deceptive behaviour.

We will not use your data to provide you with behavioural advertising, as well as re-marketing, profiling and automated decision making.

6. ON WHAT LEGAL BASIS WE USE PERSONAL DATA?

Generally, we collect and process your personal information only in order to fulfil our obligations to you, use it for legitimate interests and protect your rights (support for the internal operations), or if we have your consent to do so.

Below, we provide you with information on the purposes and grounds for usage of your Personal Data.

Activity Data type Legal basis for data processing
according to GDPR / COPPA
Manage and protect our website and our mobile applications Contact Data (a) Necessary for our legitimate interests (GDPR)
Technical Data (b) Necessary for support for the internal operations (COPPA)
Usage Data
Provide Services, improve Services, customize the Services for your individual needs Technical Data (a) Necessary for fulfilling our contractual obligations (GDPR)
Usage Data (b) Necessary for support for the internal operations (COPPA)
Submit contextual advertising to you, analyse your behaviour using our Services Technical Data a) Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR)
Usage Data b) Necessary for support for the internal operations (COPPA)
Reply to your applications, requests, notifications Contact Data a) Necessary for fulfilling our contractual obligations and for legitimate interests (GDPR)
(email, phone) b) If a single application or request is submitted by a child under the age of 13, who lives in USA, we collect such data according to the "one-time contact" exception (COPPA)

c)If the application or request is submitted by a child under the age of 13, who lives in USA, and we will have to communicate with him/her more than once, then we will inform the child's parents/guardians about the use of the child's Personal Data (Notice to a Parent of Operator's Intent to Communicate with the Child Multiple Times) (COPPA)
Get the child's parent's or guardian's consent Contact Data a) Necessary to comply with our legal obligations (GDPR)
(email) b) Exception to prior parental consent (COPPA)

We will use your Personal Data for the purposes for which we have collected them, unless we reasonably believe that we must use it for another purpose that is compatible with the original purpose.

Please note that where we must process Personal Data when required by law, we may process your Personal Data without your knowledge or consent.

7. WHAT ARE COOKIES?

When you use our services, we may use industry-wide technologies such as cookies and/or other technologies, hardware-based device identifiers, flash cookies, operating system-based identifiers and web beacons.

Cookies are small text files that we place in visitors’ computer browsers to store their preferences.

The cookies are created for each session, they do not include or collect any information about you other than your session key, and they are removed as soon as the session ends (usually done automatically by your web browser).

You can disable cookies on your device or set your device to alert you when cookies are being sent to your device.

If you do not accept, block or erase cookies, or change the settings, your online experience may be limited.

We may also use certain third-party cookies (e.g. Google Authentication). These are a different kind of cookie that is stored on your computer by third parties. This kind of cookie is only read (and is not altered by the Service) each time you use our Services. Third party cookies store only Usage Data, such as the different pages you have visited strictly within the Service (such the “About” page, the “Contact Us” page, the duration of your browsing session, etc.).

8. HOW CAN WE DISCLOSE YOUR PERSONAL DATA?

We may share your personal information with these persons:

(a) Companies of our group, third-party service providers and partners providing data processing services (e.g. to ensure the provision of our Services, to provide services or to improve our Services security), as well as to those who otherwise process Personal Data for the purposes specified in this Privacy Policy. Here is a list of our current service providers and partners (see section Our third party data controllers and processors).

b) To any competent law enforcement authority, regulatory authority, government agency, court, or other third party, if we consider that disclosure is necessary (i) in accordance with applicable laws or regulations, (ii) to exercise or to protect our rights, or (iii) to protect our or any other person's interests;

(c) A potential or actual buyer (and its representatives and advisers) involved in the purchase, merger or acquisition of a proposed or actual any part of our business, provided that we inform the buyer that it will have to use your Personal Data only for the purposes specified in this Privacy Policy;

(d) Any other person with your consent to disclose information.

9. OUR THIRD-PARTY DATA CONTROLLERS AND PROCESSORS

KIDOZ
KIDOZ is an advertising service provided by KIDOZ Ltd. KIDOZ uses Personal and Non-Personal Data only for internal purposes.

Personal Data collected: IP address, Advertising ID (Android), IDFA (Apple advertising ID).
Non-Personal Data collected: type of operating system, type of device, language preference, the time and date you access our Services, your actions within our Services (e.g., registration, pages viewed, etc.), approximate geo-location (Country).
Legal basis of processing: legitimate interests (support for internal operations).

Chartboost (Chartboost, Inc.)
Chartboost is an advertising service provided by Chartboost, Inc.

Personal Data collected: unique device identifier, IP address, and Media Access Control (MAC) address, or Android ID, Apple IDFA, Google Advertising ID (GAID)
Non-Personal Data collected: bundle ID, language ID, operating system version, device model, software developer kit (SDK) version, geolocation, website cookie information and usage data. When an end user accesses a video ad, Chartboost may collect start/boot-up information, amount played/session length information, memory on device used for video cache, videos cached on a device and complete view event.
Legal basis of processing: legitimate interests (support for internal operations).

SuperAwesome (SuperAwesome Ltd)
SuperAwesome is a contextual advertising service provided by SuperAwesome Trading Ltd.

Personal Data collected: none.

Non-Personal Data collected: operating system version, browser version, approximate location (determined by a truncated IP), connection strength, language setting, advertising metrics which do not rely on PII; clicks, impressions, VAST events (quartiles).

Legal basis of processing: legitimate interest.

 

Flurry, Inc.
Flurry Inc. is an analytics service provided by Oath (Americas) Inc.

Personal Data collected: IP address, mobile device and advertising identifiers, location data and unique identifiers.
Non-Personal Data collected: operating system type and version, mobile network information, device settings, and software data.  The frequency and duration of user’s activities etc.
Legal basis of processing: legitimate interests (support for internal operations).

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”).

Personal Data collected: IP address, unique identifiers
Non-Personal Data collected: browser type and settings, device type and settings, operating system, mobile network information including operator name and phone number and application version number, the interaction of apps, browsers and devices with Google services.
Legal basis of processing: legitimate interests (support for internal operations).

AdMob by Google (Google Inc.)
AdMob is mobile advertising platform which allows developers to monetize their app(s) by displaying in-app ads from other advertisers.

Personal Data collected:IP address, unique identifiers.
Non-Personal Data collected: browser type and settings, device type and settings, operating system, mobile network information including operator name and phone number and application version number, the interaction of apps, browsers and devices with Google services.
Legal basis of processing: legitimate interests (support for internal operations).

AdMob allows to set TFUA (Tag For Users under the Age of Consent in Europe) on ad requests. All ad requests that include TFUA disables ads personalization for users under the age of consent and collection of data by third party partners.

10. HOW WE PROTECT YOUR PERSONAL INFORMATION?

We have implemented security measures to ensure that your Personal Data is not lost, used or accessed without authorization, altered or disclosed. We restrict access to your Personal Data to those employees, representatives and other third parties who need to know your details. They will process your Personal Data in accordance with our instructions and will be subject to the confidentiality obligation.

We have put in place procedures to combat any alleged breach of Personal Data security and we will inform you and all authorities of the breaches that we are required to notify about.

11. HOW LONG WILL WE USE YOUR PERSONAL DATA?

We will only store your Personal Data to the extent required by the purposes of this Privacy Policy and to meet any legal, accounting or reporting requirements.

In order to determine the appropriate period of Personal Data storage, we will assess the amount, nature and sensitivity of Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve these objectives by other means and applicable legal requirements.

You can request to delete your data by emailing us at: [email protected].

12. WHERE WE STORE AND HOW WE TRANSFER YOUR DATA?

Your data is stored on rented and properly protected servers in Lithuania operated by company called “Interneto vizija” UAB (see their Privacy Policy).

However, your Personal Data may be transferred and processed in a country other than where you live. Personal Data protection in these countries may be different from the one in which you live.

Our service providers and partners operate globally. This means that when we collect your Personal Data, we can process it in any other country. Nevertheless, we will ensure that appropriate measures are taken to protect your Personal Data as provided for in this Privacy Policy.

This means that all our service providers and partners must process their Personal Data in such a way as to comply with the European Union's General Data Protection Regulation and other legislation.

13. WHAT RIGHTS DO YOU HAVE?

You have these Personal Data protection rights:

  • You have the right to request access to your Personal Data. This allows you to obtain a copy of your Personal Data.
  • You have the right to request the change of Personal Data that we have about you. This allows you to correct any incomplete or inaccurate data that we have.
  • You have the right to request the deletion of your Personal DataThis allows you to request that we erase or remove your Personal Data.
  • You have the right to restrict or suppress processing  of your Personal Data where you have a particular reason for wanting restriction. This means that you can limit the way that we use your data in certain circumstances.
  • You have the right to object to processing of your Personal Data where we are relying on legal basis of legitimate interests. This allows you to ask to stop processing your Personal Data in certain circumstances.
  • You have the right to cancel the consent to process your Personal Data at any time when we process your data because you have given the consent
  • You have the right to appeal our actions to the Personal Data protection authority regarding the collection and use of Personal Data. For more information, contact your local data protection authority.

If you want to exercise all of the abovementioned rights, contact us at [email protected].

14. HOW TO CONTACT US?

You can contact us at any time with any of your Personal Data protection issues at:

We will respond to all your requests within the shortest possible time.