Privacy Policy

Last Updated: [15/3/2024]

Thank you for choosing to be part of our community. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices regarding your personal information, please contact us at [tornetstudios@tornet.co].

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile games and applications (the "Services").

By accessing or using our Services, you consent to the practices described in this Privacy Policy.

What information is collected by us and how do we use it:

Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information We has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy. When you access or use our Services, we may generally collect the personal information described below.

1) Information You Directly and Voluntarily Provide to Us

When you access or use our Services, you may provide the following information to us:

a) Customer Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.

b) Contact Information: When you sign up to create an account with some of our Apps, you will be required to provide an email address, phone number or other contact information as part of the registration process. Alternatively, you can use your Facebook Account or other third party social network accounts (together, “Social Media Account”) to register for the Services.

c) Social Media Account Information: When you sign up with a Social Media Account, you will be asked to choose which information you would like to share with us, such as your email address, birthday, friends list, or public profile information. When you decide to use a Social Media Account to sign up for our Services, we only require the collection of the email address associated with your Social Media Account; all other information provided by you is voluntary.

d) Your Content: When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device’s camera and microphone. You voluntarily provide this information to us.

2) Information Automatically Collected Through the Services

We automatically collect information about you when you use the Services, such as:

a) Device Information: If you access the Services through a mobile device, we may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device’s advertising ID, other unique identifiers and other information related to device setting.

b) Cookies & Similar Tracking Information: We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.

You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services.

3) Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.

We use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.

1) To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.

2) To provide customer service. We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.

3) To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to

a) actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services;

b) investigate, prevent, or mitigate violations of our terms and policies;

c) enforce our agreements with third parties and partners;

d) collect fees based on your use of our Services.

We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.

4) To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.

5) For security purposes. We process your personal information to

a) improve and enforce our security measures; combat spam, malware, malicious activities or security risks;

b) monitor and verify your identity so that unauthorized users do not access your account with us.

We cannot ensure the security of our Services if we do not process your personal information for security purposes.

6) To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and/or to manage risk as required under applicable law.

7) To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook, Google etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services.

8) To conduct research and development. We process information about the way you use and interact with our Services to

a) help us improve our Services; build new Services;

b) build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services.

9) To engage in marketing activities. We may process your contact information or information about your interactions on our Services.

a) send you marketing communications; deliver targeted marketing;

b) inform you about events, webinars, or other materials, including those of our partners; and, keep you up with our relevant products and Services.

Transactional communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends’ contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can choose to step out of our marketing activities at any time.

2. How We Share Your Information

We may share your personal information with third parties in the following circumstances:

1) Employees, Third-Party Processors and Third-Party Service Providers. We may disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.

2) response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policy.

To the extent permitted by law, we will disclose your personal information if:

a) required to do so by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other competent public authorities;

b) we believe that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or

c) we believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.

3) Business Transfers or Bankruptcy. In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this Privacy Policy. However, any personal information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

4) Our Affiliates. Based on your consent, we may share some or all of your contact information with our, parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us.

5) Third-Party Business Partners. Based on your consent, we may work with and share some of your information with our third-party advertising partners to provide you with advertisements or other tailored content. We may share information related to users of our service with affiliates or unaffiliated third parties on a de-identified, aggregate basis. While this information will not identify you personally, in some instances these parties may be able to combine these aggregated, de-identified information with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally.

3. How We Protect Your Information

We are committed to ensuring the security of your personal information. We have technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service providers handling personal information also maintain appropriate technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us. However, we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections. Maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use our Services.

If you think there has been unauthorized access to or use of your account, please contact us

4. How We Store Your Information

We will try to limit the storage of your personal information to the time necessary to serve the purpose(s) for which your personal information was processed, to enforce our agreement, policies or terms, to resolve disputes, or as otherwise required or permitted by law.

1) Marketing. We store information used for marketing purposes indefinitely until you unsubscribe. Once you unsubscribe from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request.

2) Your Interactions and Content on Our Services. We may store any information about your interactions on our Services or any content created, posted or shared by you on our Services (e.g., pictures, comments, support tickets, and other content) indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.

5. Children

We do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law. Children are not permitted to use our Services unless they provide us with consent from their parent or guardian. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us.

7. Amendments to this Policy

We may periodically make changes to this Policy as we update or expand our Services. We will notify you of any material changes to this Privacy Policy by notifying you via the email we have on file for you, or by means of a notice on our Services in advance of the effective date of the changes. If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect. If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.

Furthermore, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.