CHILD PRIVACY POLICY

Last Updated: August 11, 2024

This Children’s Privacy Policy (“Policy”) explains how Tilting Point Media LLC (referred to as “Tilting Point”, “we”, “us”, or “our” in this Policy) collects, stores, uses, or otherwise processes personal information of children that use our Services (as defined below), and what rights they (or their parent) have if we are processing their personal information. 

In this Policy, when we refer to “children” or “child,” we mean users of the Services who tell us that they are under the age of 16, and when we refer to a “parent” we mean parents and legal guardians.

This Policy governs our practices relating to children in connection with the following online games or applications (the “Services”):

• SpongeBob: Krusty Cook-Off
• SpongeBob Adventures: In a Jam
• Oregon Trail: Boom Town
• Avatar: Realms Collide
• Languinis

For more information about Tilting Point’s general privacy practices, please visit our general audience Privacy Policy.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

Tilting Point Media LLC is a member of the PRIVO Kids Privacy Assured COPPA safe harbor certification Program (“Program”). The Program certification applies to the digital properties listed on the certification page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to supporting online services to safeguard children’s personal information collected online. The PRIVO COPPA safe harbor certification Seal posted on this page indicates the apps listed have established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +16467955733 or privacy@tiltingpoint.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

HOW WE COLLECT AND USE PERSONAL INFORMATION

When a user tells us they are under the age of 16 on the Services, we will collect and use only limited personal information in accordance with the U.S. Children’s Online Privacy Protection Act. We collect the following persistent identifiers automatically when children interact with the Services and use that information to support internal operations:

• IP address
• IDFV
• GAID

The information that is being collected also includes usage information and technical information transmitted by your device, your actions within our Services, and geo-location at a country level.  Supported internal operations may include maintaining or analyzing the functioning of the Services, performing network communications, authenticating users, personalizing content, serving contextual ads or frequency capping, protecting security and integrity, and for legal or regulatory compliance. If a child provides us with their online contact information, we may also use their information to respond to the child’s request.

We will not condition a child’s participation in an activity within the Services on the child disclosing more personal information than is reasonably necessary for that activity.  

HOW WE DISCLOSE PERSONAL INFORMATION

We may share children’s personal information with the following third parties to achieve the purposes described in this Policy:

• other companies in the Tilting Point group (which includes our parents and subsidiaries) or our Services related affiliates, for example where they help us develop or operate the Services;
• persons or companies outside of the Tilting Point group that provide services to us and process data on our behalf when providing those services (for example, providers of hosting services, analytics services, services that add functionality to the Services, or other services that help us develop and operate our Services);
• prospective or actual buyers or investors (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
• competent courts of law or other government authorities where disclosure is necessary as a matter of applicable law or regulation,
• any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests, or
• otherwise with parental consent.

The following service providers collect or maintain the personal information described in How We Collect and Use Personal Information from children through the Services:

• Amazon Web Services – Database storage and content delivery
• Amplitude – Analytics
  
• Dev to Dev – Analytics in The Oregon Trail only
• Google AdMob – Ad network
• Google Firebase Crashlytics – Bug and crash reporting
• IronSource – Ad network mediation
• LeanPlum – Content optimization
• PlayFab – Backend player database
• Unity Ads – Ad network
• Whale App – Analytics in SpongeBob Adventures only

These service providers do not disclose or use your personal information except to support the Services described at the top of this page. The service providers retain personal information only as long as necessary to provide the Services. Questions about any provider’s privacy practices and the use of children’s information may be directed to Tilting Point by contacting privacy@tiltingpoint.com.

PARENTAL CONTROLS AND CHOICES

Parents of children who use the Services can email us at privacy@tiltingpoint.com if they wish to:

• review their child’s personal information, request that it be deleted, or refuse to allow any further collection or use of their child’s personal information; or
• ask any other questions about this Policy or how we handle their child’s information.

Depending on the applicable law in your jurisdiction, you may have additional rights in respect of your personal information. If you have any questions about what rights and choices apply in your jurisdiction, please contact us.

DATA SECURITY

We have adopted measures to provide the data collected a level of security appropriate for the degree of risk involved with the data processing activities described in this Policy. These measures are designed to protect the data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ vary depending on the sensitivity of the data, but typically include, for example, encryption, pseudonymization of identifying data where feasible, physical and technological controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents.

CHANGES

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. If we make material changes to the personal information we collect or how we use it, we will notify you if we have your contact details.

CONTACTING US

If you have questions regarding this Policy or our practices relating to children, you can reach us by email at privacy@tiltingpoint.com. You can also reach us by mail at Tilting Point Media LLC, 521 Fifth Avenue Floor 17 New York, NY 10175, USA, and at +16467955733.