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PRIVACY POLICY FOR WEBSITES

(Last update May 25, 2018)

Your privacy is very important for us and we will always use your personal information only for the purposes as described in this Privacy Policy. As used in this Privacy Policy, "OUTFIT7", “we”, “us” or “our”, “ours” refers to Outfit7 Limited and all of its subsidiaries.  This Privacy Policy governs your use of http://outfit7.comhttp://talkingtomandfriends.comhttp://talking-ginger.com/ and any other websites and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By using the Websites, you specifically consent to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services and content.

INFORMATION WE COLLECT FROM YOU

When you visit our Websites, we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with promoting our apps and services, and for research or analysis.

1. Technical Information

We collect the data necessary for you to use the Websites and for us to maintain and analyze the functioning of the Websites and to personalize the content of our products.

We automatically obtain certain information about your computing device, including:

  • IP address; Country code;
  • Language; Locale (specific location where a given language is spoken);
  • Time zone;
  • Network status (WiFi, etc.), browser plug-in types and versions;
  • Technical device information (e.g. device model and name, operating system name and version, screen size, mobile phone carrier, Internet service provider);
  • Information we collect via cookies (which are small text files placed on your device). Cookies allow us to collect data, such as your device's model, operating system and screen size and other information about how you use our Services. For more information, please see “Our Use of Cookies and Related Technologies” Section of this Privacy Policy.

Although some of this information (such as IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US and EU) may treat information that uniquely identifies your device as personal information.

2. Website Usage Information

When you use the Websites, we collect additional information from you by using persistent identifiers that permit identification of your device.

The information we collect includes:

  • Website usage, including log information, that lets us know how you use the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
  • Characteristics obtained by your use, such as data about pages of our Websites that were viewed during your visit, any actions or movements within the Websites and movements to/from the website from/to another website, date and time, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

3. Classical Personal Information

When you request information using the Websites or contact us directly, we may collect personally identifiable information about you that you provide us such as your name and surname, email address and demographic information such as your year of birth. When you voluntarily submit your ideas, cooperate in our contests and/or surveys or otherwise register with OUTFIT7, we may collect additional personally identifiable information about you that you voluntarily submit, such as your telephone number, address, resume, job position, etc. We will use your contact information and other personal information only for the purpose for which you provided it to us. We will not share this data with third parties.

If you are applying for a job position with one of the companies within Outfit7 Group, your personal information will be processed in accordance with our Outfit7 Candidates Privacy Policy available at https://outfit7.com/candidates-privacy-policy/.

If you wish to delete your personal information that we received from you, please send an e-mail to privacy@outfit7.com and your personal information will be deleted from our database.

HOW WE USE YOUR INFORMATION

We use the information we collect from you for delivering our services and Websites and to operate our business.  We use it also for improving our services and Websites, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services, Apps and Websites, for providing customer support and for complying with our legal obligations.

We use your information for the following purposes: 

  • Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, understanding and analyzing trends in connection with usage of the Websites, administering the Websites, and customer communications.
  • Promoting our Apps and Services: when you use our Websites we may promote our Apps and other Services.
  • Analytics and research: Understanding and analyzing trends in connection with the usage of Website, auditing, learning about user behavior on the Websites (how often you use the Website, the events that occur on the Website, aggregated usage, performance data etc.).
  • Security: We use your information for enhancing the safety and security of our Websites, apps, products and services.
  • Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
  • Our legal obligations: We use your information when we are required to do so by law.

OUR USE OF COOKIES AND RELATED TECHNOLOGIES

We use cookies on our websites for conducting internal analysis about the usage of websites in order to make them more appealing. For information about cookies and related technologies, please visit “Outfit7 Cookie Policy” available at:http://outfit7.com/cookies/.

SURVEYS AND CONTESTS

We are conducting surveys and online contests in order to improve our services and you may freely decide whether you would like to take part in it or not.

From time to time we may conduct an e-mail survey or an online contest and collect classical personal information, demographic information, usage information and other materials that you voluntarily submit to us for the purposes of internal analysis, marketing and brand development. Participating in a survey or an online contest is completely voluntary. We will use the information to make our services more appealing to users. Collected information gathered via surveys shall be anonymized and aggregated. We may use your information gathered via contests for the purposes of performing the contest and to contact you as per such contest’s terms and conditions.

HOW WE SHARE YOUR INFORMATION

We cannot provide all services necessary for the successful operation of the Website by ourselves. We must therefore share collected information with third parties, including analytics providers, and other third party service providers that support the Website, including Third Party Social Networks (collectively referred to as “Partners”). We may share information that can be used to personally identify your device (e.g. IP address) for the purposes of delivering our services, displaying adsvertisements, promoting our apps and services and conducting analysis and research.  We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

  • Third party analytics providers: For some Websites we use third party web analysis service Google Analytics from Google Inc. (“Google”) for the purposes of delivering our services, conducting analysis and research. Google Analytics uses so-called “cookies”. The information generated by the cookie about your use of this website (including your IP address) will be sent to a Google server in the US and stored there. Google will use this information to analyze your use of our Website in order to compile reports about website activities for us and to perform other services connected with the use of the Website. Google will also send this information to third parties where applicable, if this is required by law or if third parties process these data on behalf of Google. Google will not connect your IP address with other data from Google. You can prevent cookies from being installed by setting up your browser software accordingly; please note, however, that in this case you might not be able to use all of the functions of this Website to their full extent. To get more information about how your data is being collected and processed you can visit the site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. Google has the right to process the data in accordance with their privacy policy (http://www.google.com/intl/en/policies/privacy/#nosharing). We can aggregate the data for benchmarking feature. Please see section “Opt-Out Of Analytics”.
  • Our cloud service providers: We store information we collect from you on servers provided by our third party cloud service providers such as Google Cloud Platform;
  • Our video gallery providers: For some Websites we use YouTube embedded video gallery in order to display our video content. YouTube may in accordance with their privacy policy display contextual advertising in its video gallery.

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Website. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

For detailed information about information collection and the usage practices of our partners please see the “Cookie” section of this Privacy Policy. For any additional questions about third party information collection please refer to privacy@outfit7.com.

THIRD PARTY SOCIAL NETWORKS

The Websites may include social media features, such as like, follow and share buttons, provided by third party social networks such as Facebook, YouTube, LinkedIn, Twitter and VKontakte (“Social Media Features”). These Social Media Features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the Social Media Feature to function properly. Social Media Features are generally hosted by a third party, but may also be hosted directly on our Websites. Your interactions with these Social Media Features are governed by the privacy policy of the third party social media network providing it. For additional questions you can contact us at privacy@outfit7.com.

HOW OUR PARTNERS MAY USE YOUR INFORMATION

We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us. They adhere to this Privacy Policy, but in some cases we must use their privacy policies.

We strive to commit our Partners to using the information solely for the purposes as stated above. If they use information that might be considered as personal information, they should use it solely for the purposes of providing the service to us or for contextual advertising, but for any other purposes they should use the information solely on anonymized and aggregated basis. Notwithstanding the above, we cannot guarantee that our Partners will adhere to the contractual obligations or acceptable business practices.

In addition, Partners may use their own tracking technologies (including and without limitation: cookies, Web beacons, HTTP cache, and local shared objects) to compile anonymous information about visitors to the Websites. Partners may share anonymous information that they collect with their clients. We strive to ensure that this information is only disclosed to such third parties in an anonymized and aggregated manner.

Our Partner’s information gathering practices, including their policies regarding the use of cookies, Web beacons, and other tracking technologies, are governed by their own privacy policies, not this one. We strive to adhere to the generally accepted industry practices regarding the collection and the usage of information by our Partners and to limit their usage to the services they provide for us.

THIRD PARTY TERMS AND CONDITIONS

Please note that your access to and ability to use and interact with the Websites may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services, statistics services providers and payment providers.

Our Websites may contain links to third party websites, products, or services. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party’s privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

CHILDREN’S PRIVACY

We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under 13 or under the age of digital consent according to EEA data protection legislation, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than persistent identifier of a child under the age of 13 or under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@outfit7.com.

We recognize the importance of safeguarding children's personal information collected online. The only personal information we collect on Websites are persistent identifiers (such as IP address and cookies). Such persistent identifiers are used and shared with third parties solely for providing support for the internal operations meaning to deliver and optimize our Websites, place contextual advertisement (solely through embedded video gallery), to authenticate users of or personalize the content on our Websites and Apps, to maintain or analyze the functioning of the Websites and Apps, personalize the content of the Websites and Apps, to perform network communications to protect the security or integrity of the user or the Websites and Apps, to ensure legal or regulatory compliance.

When using the persistent identifiers we will not contact users under the age of 13 or under the age of digital consent according to EEA data protection legislation, display behavioral advertising to them, nor do any user tracking or profiling. For the detailed information about disclosure to third parties please see section “How do we share your information” of this Privacy Policy. For any additional questions about third party information disclosure please contact us via privacy@outfit7.com.

In an instance that a child submits a personal information to us, we will retain such information only so long as reasonably necessary to fulfill the activity request, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

PRIVO-CERT™ SAFE HARBOR CERTIFICATION PROGRAM

OUTFIT7 is a Member of the PRIVO-Cert™ Privacy Assurance Program (“the Program”). As a participating member in the Program, OUTFIT7's Talking Tom and Friends and other characters applications and websites adhere to the strict information collection, use and disclosure requirements set forth by the Program. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. PRIVO aims to help parents and their children exercise control over personal information while exploring the Internet. The PRIVO certification seal posted on this page indicates that OUTFIT7 has established COPPA compliant privacy practices in its Talking Tom and Friends and other characters applications and websites 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 privacy@outfit7.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

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OPT-OUT OF ANALYTICS

You are always free to opt out from the future collection of your personal information by us and Google Analytics in accordance with this Privacy Policy for analytics purposes by following instructions available on this link https://tools.google.com/dlpage/gaoptout.

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it, i.e. you have a right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to privacy@outfit7.com.

Your rights include:

  • Right to object. In some cases you have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by stopping with the use of our Websites and services.
  • Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for. Where we are not able to provide you with information that you have asked for, we will explain to you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity.
  • Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via privacy@outfit7.com and we will correct it as soon as we can.
  • Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us via privacy@outfit7.com. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymised form.
  • Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via privacy@outfit7.com.
  • Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
  • Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.

We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

GENERAL

Your privacy and security of your information is important to us and we always pay special attention to ensure that we process your information lawfully, including but not limited in accordance with one of the legal bases set out under EEA data protection laws that apply to EEA users. We have appointed data protection officer in accordance with EEA data protection laws, ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, to help us ensure compliance with such laws. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners as for the purposes described above in “How We Share Your Information” Section, which may include a transfer of your personal information outside of the European Economic Area (the “EEA”). Please check http://outfit7.com/privacy/ regularly for changes to our Privacy Policy.

LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under EEA data protection law.

The legal bases that we rely upon are the following:

  • Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support and to process your information in relation to online contests.
  • Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when use our Websites and services, to make sure your information is secure and to provide to you our services free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics and research, for our own promotion purposes and contextual advertising purposes in embedded video gallery.
  • Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for you consent before conducting any surveys.
  • Legal Obligation. This covers information that is processed by us to comply with a legal obligation.

SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

INTERNATIONAL TRANSFER

We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across boarder and from your country to other countries around the world. Please note, that not all of these countries have the same data protection laws as your own country, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

We will transfer your personal information outside EEA only when the transfer is based on one of the following safeguards:

  • To a country with adequate data protection. We will transfer your personal information outside EEA to a country that ensures an adequate level of protection in accordance with EEA data protection legislation.
  • Based on standard contractual clauses. We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via privacy@outfit7.com).
  • Based on an approved certification mechanism. We will transfer your personal information to our Partner outside EEA, if our Partner is certified by an approved certification mechanism pursuant to EEA data protection legislation. For instance, to our partner that is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at www.privacyshield.gov).

RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services.

  • For EU Countries

We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission. Cookies, and provision of value-added services information (including traffic information used for these purposes) is stored as long as the same is necessary for the provision of these activities, or up to the time when a user opts out from such use in accordance with this Privacy Policy and the “Opt Out of Analytics” and “Your Rights” section herein. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

  • For US and rest of the world

We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the information and the applicable legislation, but we always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our services.

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at http://outfit7.com/privacy/.

For previous versions of this Privacy Policy please contact us via privacy@outfit7.com.

CONTACT US

If you have questions or concerns about OUTFIT7’s Privacy Policy, please contact us through one of the following ways:

  1. for privacy questions and exercising your rights via our privacy email: privacy@outfit7.com;
  2. our data protection officer: ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg;
  3. for general information please feel free to contact us via our customer service page: http://outfit7.com/contact/.

For information collected under this Privacy Policy that is subject to EEA data protection laws, the data controller is Outfit7 Limited, a company registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London EC3M 6BN, United Kingdom, with business address at Agiou Georgiou, 4607 Pissouri, Cyprus.

OUTFIT7 PRIVACY POLICY FOR WEBSITES, last updated May 25, 2018