Tortuga Privacy Policy for the EU
Last revised: 15 July 2020
Tortuga provides this Privacy Policy to inform you of our policies and procedures regarding the processing of Personal Data of users of the websites located at http://tortuga.games and http://tortugasocial.com (the “Sites“), including any services, features and content accessible or downloadable from the Sites, and any other Tortuga application, service or product licensed, downloaded or otherwise accessed by such users through third party websites or sources and collectively, the “Service”(each a “Service,” collectively, the “Services”).
We are committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes how we treat information that you provide to us or that we collect about you.
This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms of Service, which is accessible at Avaland unless otherwise defined in this Privacy Policy.
Information we collect
We collect information when you provide it to us, when you communicate with others, and when you use the Services. We also may collect information about you from other sources.Information you provide to us. When you register, contact us directly, or otherwise use the Services, you may choose to provide information to us, including:
- Contact information, including name, phone number, mailing address, and email address.
- User account information, including username, nickname, password, and profile picture.
- Demographic information, including your age, gender, and country.
- Contacts from your device address book and social media accounts.
- Payment information, which our payment processors collect when you make purchases.
- Correspondence you send to us.
Communications with others. When you communicate or share information with others through the Service, including by posting photos or communicating in written messages or on our social networking pages, we may access and store the contents of these communications and related information, unless such access and storage are prohibited by law. You consent to our recording, storage, and disclosure of such communications and information that you send or receive consistent with this Privacy Policy and the Terms of Service.
Use of the Services. We collect information when you use our Services, including your Internet protocol (“IP”) address and other identifiers that are assigned to your device and application when you access the Internet or use the Services, browser type, browser version, browser language setting, operating system, device name and type, MAC address and other device identifiers, information from your device (including information from and about your hard drive and other storage devices, central processing unit, random access memory, video card, and peripheral hardware, software and applications installed on your device), Internet service and mobile service provider, pages that you visit before and after using the Services, the date and time of your visit, download information, the links you click and areas you view within the Services, game metrics and usage data, and other standard server log information. We collect additional information when the Services crash or otherwise encounter a problem, including system and driver data. Consistent with your device permissions, we may collect or derive location information from your device’s GPS signal, Bluetooth connections, nearby WiFi networks, and similar device information. We also may derive location from your IP address.
Information we obtain from other sources. We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information from third-party social networking services when you or other users choose to connect with those services.
Links to our third-party partners privacy policies
How we use information
We may use, record, systematize, store, update or modify, retrieve, delete, or otherwise process your information for the following purposes, using manual or automated means: Our payment processors use payment information as necessary to complete transactions or as otherwise required by law.We also may use the information we collect to: · Provide the Services and deliver requested products and information, including technical support and responses to your questions or comments. · Deliver emails, push notifications, text messages, alerts, and other communications about our Services and the products of our third-party partners, consistent with your choices. · Customize and deliver the content and advertising you see when using the Services or third-party websites and services, consistent with your choices. · Link the different devices that you might use to analyze your use of the Services, customize advertising, and otherwise provide and improve the Services. · Analyze and address prohibited activities, including by assisting our efforts in policing users who may develop or use hacks or cheats to gain advantage over other users of the Services, and to otherwise enforce our Terms of Service. · Analyze, develop, and improve the Services and new products and services, including by conducting and delivering surveys, polls, and research. Tortuga’s legal bases to process information for these purposes include that the processing is necessary for: · Tortuga’s legitimate interests, including those described above and as necessary to provide the Services. · Compliance with Tortuga’s legal obligations. · The performance of the Terms of Service between Tortuga and the user. · Carrying out the obligations and exercising rights under applicable law. · Where applicable, on the basis of the consent of users which may subsequently be withdrawn at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. We rely on consent for certain advertising purposes, use of certain cookies, the collection of precise geolocation information, the combination of data across devices, and international transfers of personal information. For more information on how you can provide or withdraw your consent, see your choices.
When information is shared
We limit when we share the information we collect to the following circumstances:Within Tortuga. We share information across Tortuga’s affiliated companies.
Business Partners. We share information with third-party partners and service providers, including payment processing and gateway companies, platform services, game developers, game publishers, customer support services, cloud storage and hosting providers, social media companies (who may collect information when you use the Services or when you connect the Services to your social media accounts) and analytics and advertising companies, to help us provide and improve the Services and operate our business. For more information about these business partners, please contact us.
- Other Users. Your profile, including your username and the picture that you may provide, and information about your activities on the Services may be visible to other users of the Services or third-party sites and services. For example, your game results, scores, and profile information may be viewed by other users of the Services and, if you choose to link to social media sites like Facebook, viewed by users of such sites.
- Legal Purposes. We may provide your information to third parties when we believe that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may disclose your information in order to protect the rights or property of Tortuga, including enforcing our Terms of Service, and others, or when we believe that there is an emergency that poses a threat to the health or safety of you, another person, or the public.
- Corporate Transaction. If Tortuga is involved in a corporate transaction, such as a merger, acquisition by another company, asset sale, or in the unlikely event of bankruptcy, we may transfer your information to the successor organization in such transaction in accordance with applicable law.
- With Your Consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
When you use the Services or interact with emails from us, we and our third-party business partners may collect and store information about your use of our Services using cookies, pixel tags, local storage, advertising ID and similar technologies.
Cookies are small files that are automatically generated when you visit a website and are stored on your device. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your device. Local storage is similar to a cookie except that it can store larger amounts of information and can be stored elsewhere on your device.
We use cookies and similar technologies (collectively, “cookies”) for the following functions and purposes: *Analytics and Research
We use analytics and research cookies to collect information about how visitors use our Services, including the total number of people that use our Services and the types of devices they use. We may use the information to compile reports of aggregated and de-identified information and to help make improvements to the Services.
Authentication
These cookies help us to identify our users so that when you are signed in, you can enjoy the Services and features fully. These cookies are essential and cannot be blocked if you wish to use the Services.
Service Features and Performance
We use feature-tracking cookies to collect information about how our Services are performing. We may use the information to compile reports and to help make improvements to the Services. Security and Service Integrity
We use security-based cookies to help ensure the security of our Services. We may use information obtained from security and service integrity cookies to, among other things, identify possible fraudulent or abusive activities, enforce our Terms of Service, and to protect the safety of our users. These cookies are essential and cannot be blocked if you wish to use the Services.
Advertising
We use advertising cookies or advertising ID to customize the advertising that is shown to you on the Services and on third-party websites and services. We allow third parties, including our analytics providers, advertising networks, and other advertising service providers, to collect information about your use of the Services across your applications and your different devices using cookies and similar technologies. These third parties may use this information to display advertisements on our Services and elsewhere online across different sites and services tailored to your interests, preferences, and characteristics. You can control the use and disclosure of the information for such purposes through Your Choices. YOU CONSENT TO THE USE OF NON-ESSENTIAL COOKIES AND OTHER TECHNOLOGICAL MEANS AS IDENTIFIED IN THIS PRIVACY POLICY WITHOUT PREJUDICE TO ANY RIGHTS YOU MAY HAVE UNDER APPLICABLE LAW TO LATER REFUSE OUR USE.
Your choices Tortuga provides you with a variety of choices to control the use and sharing of your information, including:
Email Communications. You may opt out of receiving commercial email messages from us by following the unsubscribe instructions provided in our emails. Please note that even if you have opted out of receiving commercial email messages, you may continue to receive messages related to your account, your transactions, and similar service-related messages.
Geolocation Information.
Your device may enable you to control the collection of your precise geolocation information, and whether this information is shared with third parties, through the settings on your device. Please note that you may need to adjust multiple settings, and not just your location permissions, to opt out of providing precise location information. If you opt out of providing precise geolocation information, we may continue to derive your approximate location from your IP address and other information we may collect. For more information, please review your device settings.
Cookies and Similar Technologies.
You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and similar technologies.Deleting the cookies in your browser may in some cases cancel your choices for interest-based advertising. If you choose to refuse, disable, or delete cookies and similar technologies, some of the functionality of the Services may no longer be available to you.Do Not Track Signals and Similar Mechanisms.
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Tortuga currently does not take action in response to these signals.
Interest-Based Advertising.
While it is not possible to turn off all advertising, you do have the ability to control whether you receive interest-based ads based on information collected or received about your online activities and interests over time and across unaffiliated sites and services and your different devices. If you are using a mobile app, you also may need to opt out of interest-based advertising on your mobile device or through the mobile application. For more information, check your device and mobile app settings. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.
Other Game and Device Permissions.
You may be able to adjust your privacy settings for push notifications, address book sharing, and other information or features within the Services or your device permissions. Please review the settings for the Services and your device for more information. To stop the collection of information by Tortuga, you can uninstall the game using the standard uninstall process available on your device or the app marketplace or network from which you installed the game.
Data Rights and Withdrawal of Consent
The laws in your country may provide you rights to request access to, correct, restrict, port, copy, or delete your information, request that we stop processing your information or delete your account, or withdraw or change the scope of your consent. If you withdraw your consent, we will stop processing your information for such purposes, but it will not affect the processing of information previously covered by your consent. Where technologically feasible and required by applicable law, we will port your information pursuant to your reasonable request. A request to withdraw consent, restrict or stop processing your information, or delete your account or information may result in your inability to access the Services or some of its features. To exercise your rights consistent with applicable law, please contact us.
Children
We do not knowingly collect personal information from children who are under the age of 13 (or the age otherwise defined under applicable law) without parental consent or unless permitted by applicable law.How we secure and how long we store information
We maintain reasonable and appropriate physical, electronic, organizational, and procedural safeguards to protect your information. While we take reasonable precautions against possible loss, misuse, or unauthorized access, no storage system or transmission of data over the Internet can be guaranteed to be secure. Data we collect will be retained only for so long as reasonably necessary for the purposes set out above, unless applicable law requires otherwise.You can easily delete your data at any time: just fill the form.
International data transfers
Information we collect may be transferred to countries outside your home country for the purposes set out in this Privacy Policy. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.Changes to this privacy policy
We may make changes to this Privacy Policy, in which case we will notify you before such changes take effect by posting the updated policy through the Services or otherwise in accordance with applicable law. Any changes to this Privacy Policy will take effect after a reasonable time period as specified in the notice of such changes.CONTACT US
If you have any questions, please send your inquiries in writing to Tortuga Ltd., 71 Revolutsionnaya Street, 440000 Penza, Russian Federation The laws in your country may permit you to lodge a complaint with the supervisory authority for data protection in your country if you believe that Tortuga’s processing of your information infringes applicable law.