privacy policy

Last updated May 25, 2018

Tilting Point Media LLC and its affiliates (together, “Tilting Point”, “we” or “us”) may collect, store and use your personal information in connection with developing and providing to you its products, software applications (whether on third party sites or as applications on mobile devices), sites and other services (collectively, “Services”). At Tilting Point, we take your privacy seriously. We operate on the principle that your personal information belongs to you and only you can decide who you want to share it with and why. This is fundamental to the way we work and we’re committed to providing a secure environment for you to store your personal information and share it with others when you want to.

This privacy policy (“Privacy Policy”) explains how personal and other information is collected and used by us. Please read it carefully, as all of our Services are governed by this Privacy Policy. By using or accessing any Service you agree to and give consent to this collection, processing, transmission, retention and use of such information and data related to you. You may withdraw such consent at any time by letting us know via the applicable Service (e.g., using customer care tools in app) or by contacting us at privacy@tiltingpoint.com.At that time, you may also want to remove any cookies which have been placed on any device used to access the Services.  Your withdrawal of consent will not affect the lawfulness of any processing carried out by us prior to such withdrawal. You are not authorized to install, access or otherwise use the Services if you do not agree and consent to this Privacy Policy.

Users Outside the US

If you are located outside the United States, you acknowledge and consent to the processing of such data in the country in which it was collected as well as in other countries where it may be transferred, including the United States, where regulations regarding processing of personal information may be less stringent than regulations in your country.

Updates to this Privacy Policy

Any changes we may make to this Privacy Policy will be posted to this page. Your continued use of Services will signify your agreement to and acceptance of any changes to this Privacy Policy. Please bookmark and visit this page periodically to review the current Privacy Policy and to understand what information we gather and how we may use it. This Privacy Policy is governed by and forms a part of our Terms of Service.

data collection

Situations when you make personal information available to us may include, but are not limited to:

  1. by visiting our websites or using our software applications;
  2. registration for Services, sweepstakes, contests and special events;
  3. accessing Services using IDs from a third party service, such as an application marketplace, gaming service or social network service;
  4. subscribing to newsletters;
  5. requesting customer support or other direct communications with us; and
  6. otherwise through use of our Services where personal data is required for use and/or participation. Personal data we collect and/or process may include (but is not limited to): first name, last name, email address, user names, date of birth, age, gender, IP address, city, unique identifiers in cookies and third-party service IDs (e.g., Swrve, Facebook, Apple, Google).

Aggregated Information & Non-Identifying Information

We may collect aggregated, anonymized information via the Services that does not identify any single user or device. We may use that information to calculate statistics about our user community for the purpose of enhancing our Services or for security purposes. If you choose to provide a username within a Service, please do not provide as your username any information that identifies you in real life, such as your real name.

We may also collect and/or process other data not relating to you as an identified or identifiable person, including (but is not limited to): device IDs, third-party service IDs (e.g., Adjust), application usage data, operating system information, browser information, and network and online usage information. When a user accesses or uses a Service, we may collect technical information about the user’s device, such as the IP address that requested the display of the Service, the operating system type and the identifiers associated with the device.

For example, we may collect and share the advertising identifier associated with your device (such as the Apple IDFA and Android Advertising ID) with advertisers. An advertising identifier is an alphanumeric string that can be used to identify your device so that advertisers can serve relevant ads to you. We use the Apple IDFA only as permitted by Apple, and we use the Android Advertising ID only as permitted by Google. An advertising identifier is assigned, and ad tracking is turned on, by default on your mobile device. You may limit the use of or reset your advertising device ID using the privacy settings on your mobile device; in some cases you may need to reset the operating system to reset the advertising device ID. We do not associate any of your personal information with your advertising device ID without your consent (which may be given by you in our terms of use for a Service).

Certain non-identifying information would be considered a part of your personal information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-identifying information when they are taken alone or combined only with other non-identifying information (for example, your activity in a game).

SERVICE PROVIDERS

In the course of providing the Services, we may employ third party service providers and their technologies that use certain methods to collect personal and other information as a result of their integration with the Services to perform analytics, customer support and other services for us, such as ironSource, Swrve, Adjust and Helpshift. Collected data may be used and processed by us or on our behalf in accordance with this Privacy Policy, as well as the privacy policies of the applicable third parties. For more information about ironSource and its services please see ironsrc.com; for more information about Swrve and its services please see swrve.com; for more information about Adjust and its services, please see adjust.com; and for more information about Helpshift and its services, please see helpshift.com ironSource, Swrve, Adjust and Helpshift maintain their own respective privacy policies accessible from their sites.

USE OF INFORMATION

We use the collected data to provide the Services as well as conduct related analytics regarding the use of Services, such as user behavior with respect to our Services, the number of users of our Services and which sections of a Service are popular. We use this information for supporting our business operations, which include product development, improving products and services, personalizing relevant content, measuring marketing campaign performance, processing transactions, customer support and communications, protecting the rights of Tilting Point and its partners and users and complying with applicable laws and regulations as well as our Terms of Service and this Privacy Policy. In the course of providing the Services, personal and non-identifying information related to you and specific software applications may be shared with third parties, including third party developer(s) and service providers specifically involved with their development and operations, and when we believe in good faith it is necessary to comply with the law, enforce or apply our Terms of Service or other agreements, or protect the rights, property, or safety of Tilting Point and our partners, employees, users, or others.

We may associate information about you we collect through one part of our Services and use it in connection with other parts of our Services. We may also obtain information from other sources and associate that with other information we collect through our Services. For example, if you create or log into your account through a social network service site or otherwise authorize us to access your social network data in connection with accessing one of our Services, we may have access to certain information from that social network, such as your name, account information and friends lists, in accordance with the rules prescribed by such social network, and this information may be associated with other information we have collected separately.

We may use personal contact information you have made available to us through your use of Services such as email address, to send you communications that we believe are relevant to your use of such Services, as well as other Services which we offer. If you receive commercial emails from us, you may unsubscribe by following instructions contained within the email or by contacting us at privacy@tiltingpoint.com. Even after you opt-out from receiving commercial or promotional emails from us, however, you will continue to receive administrative messages from us regarding Services that you are using.

DATA RETENTION

We may retain and store collected data for any periods necessary to perform Services and fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. As a general matter, we delete the personal data of a user six months after s/he ceases using our Services. Please note that some data may be used and further retained if necessary to resolve disputes, enforce user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

THIRD PARTY TERMS

While we may use third parties to collect and process personal and other data on our behalf and according to our instructions in the course of providing the Services, we do not actually control third-party data collection and use. You acknowledge and agree that your access to and use of the Services may be subject to terms and conditions of third parties, whether or not they are acting on our behalf or independently of the Services. These third parties include mobile device manufacturers, operating system and browser developers, social network services, analytics providers, companies delivering advertisements in or for our Services, and online and mobile network communications providers, any of whom may utilize cookies and other technologies for analytics, monitoring and other purposes, including for other products and services you may be receiving from them. Please refer to the privacy policies and terms and conditions applied by such third parties.

In addition, if you leave our websites or software applications and go to another website or software application, the third party associated with such site or app may also collect personal and other data from you. We have no control over, do not review, and do not assume any responsibility for, these external websites or apps or their content, policies or terms.

PUBLIC DISCLOSURE BY YOU

You may choose to disclose data about yourself in the course of contributing user generated content, if applicable, to the Services or on social networks. Any data that you disclose in any forums, blogs, chats or the like that are part of the Services will become public information, and there is no expectation of privacy or confidentiality with respect to that data.

OUR USE OF LOCAL STORAGE

Local Storage is a small database located inside your device. We may use local storage and/or similar technologies for a number of purpose, including player authentication, fraud prevention and remembering of preference/settings. This technology helps us provide a better experience when interacting with our Services and to improve your player experience.

CHANGING OR DELETING YOUR INFORMATION

We think it is important that you are able to control your personal information.

You have the right to ask us not to process your personal information for marketing purposes.  You can exercise your right to prevent such processing at any time by contacting us via the applicable Service (e.g., using customer care tools in app) or at privacy@tiltingpoint.com.

The law gives you the right to request a copy of the personal information we hold about you.  We first require you to prove your identity with additional pieces of approved identification.  We will supply, correct or delete personal information about you on our files.  In addition, you may request rectification or erasure of personal information as well as the restriction of processing of your personal information. We will comply with your requests in accordance with the applicable law.

If you wish to complain about the processing of your personal information then please contact us first, but if we do not satisfactorily deal with your complaint, then you may contact the applicable regulator or Information Commissioner.

If you want to stop using the Services, you may do so.  If you do, you may also want to remove any cookies that we have placed on any device used to access the Services.

BUSINESS TRANSFERS

As Tilting Point continues to grow, we might sell or buy certain subsidiaries and/or business units. In such transactions, customer information is generally one of the transferred assets. Also, in the unlikely event that Tilting Point or substantially all of its assets are acquired, customer information would in most cases be one of the transferred assets.

CHILDREN UNDER 13 YEARS OF AGE

We do not knowingly collect personal information from children under 13 years of age. If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will take reasonable measures to promptly delete such information from our records.

SECURITY

All information you provide to us is stored on servers owned and operated by Amazon Web Services, Inc.  More information on this provider is available at https://aws.amazon.com.

CONTACT INFORMATION

For questions and information about this Privacy Policy, please contact us at privacy@tiltingpoint.com.