TRIGGER TEAM PRIVACY POLICY
Last updated: May 3, 2018 This privacy statement describes information gathering and dissemination practices. By accessing and/or using our mobile apps, products and services (collectively, the “Services”), you accept this privacy statement and agree to the terms, conditions and notices contained or referenced herein. We may modify this privacy statement from time to time. When posting changes to this privacy statement, we will revise the “last updated” date at the top of this page.
COLLECTED INFORMATION AND ITS USE
Personally Identifiable Information
We may collect personally identifiable information from you in a variety of ways, including, but not limited to, when you visit, register on our Services, and in connection with other activities, services, features or resources we make available on our Services. We will collect personally identifiable information from you only if you voluntarily agree to submit such information to us. We may collect and use personally identifiable information for the following purposes: to uniquely identify you as a user in our Services, to provide you with services, to improve customer service, provide user and other support, including to our third party partners, carry out other purposes that are disclosed to you and to which you consent. The Services may share collected location and Wi-Fi, Bluetooth data for online advertising, attribution and research allowing advertisers to infer interests and serve advertisements to you based on your Services activity and location data.
Non-Personally Identifiable Information
We and our Third Parties (as this term is defined below) may collect the following technical information relating to you, your device: device state and locale; device information (type of device, status, its capability, OS version, IDFA, Android Advertiser ID or other type of advertising identifier, mobile network type, network connections and access, signal strength relating to Wi-Fi, Bluetooth functionality, temperature, battery level and similar technical data); usage information (your in-game activity, information about your use of features, functions or notifications on the device); Google service configuration; date and time stamp information on engagement with the Services; latitude and longitude of the mobile device when the interaction with the Services occurred; the ID of the sensor belonging to the Services that the mobile device interacted with and the corresponding information associated with that ID; the name and version of the mobile application through which the interaction with the Services occurred; the duration of an interaction with the Services; hashed and anonymized email; the way you use the Services in the different menus and functions used and other technical, non-personally information about you, your device. Such information may be used by us and Third Parties to personalize your experience, improve customer service, provide support and to deliver targeted advertising and promotional offers to you based on your activity and location data as further specified below. We may use the geo-location data to surface the appropriate country/language-based version of our Services to you. In addition, we may collect and share precise location information, through methods such as mobile “SDKs”. This non-personally identifiable location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties, for purposes related to advertising, attribution (e.g., measuring ad performance) analytics and research.
Aggregated, Anonymous Information
We may collect and share with third parties the aggregated, anonymized information received via our Services that do not identify any single user.
Cookies and other tracking tools
Our Services may contain third party tracking tools from our Third Parties, examples of which include cookies, mobile device identifiers, mobile analytics software, APIs, SDKs. We may also feature advertisements served by Third Parties that deliver cookies and other technologies, such as mobile device identifiers, mobile analytics software, APIs, SDKs, to your device so the content you access and advertisements you see can be tracked. Since the Third Parties associate your device with a number, they will be able to recognize your device each time they send you an advertisement. Additionally the technologies may contain attribution and research tools that helps to count the ad impressions and prevent the same advertising content to be shown to you frequently. We and Third Parties may use cookies and other technologies, such as mobile device identifiers, mobile analytics software, APIs, SDKs, to enhance your experience with Services, improve the quality of our Services, tailoring recommendations to your interests and making the Services easier to use. Also Third Parties may use these technologies to access and collect your information, such as mobile device identifier, IMEI, IP address, geo-location information, for the purpose of providing their services under their respective privacy policies as further described below. These technologies enable us and Third Parties to learn the Service access frequency, provide you with customized content or offerings, such as personalized advertisements within Services about goods and services of interest to you. We and Third Parties may also use cookies and other technologies to control, manage and measure the performance and display of third party advertisements within our Services, and our advertisements on third party applications. This helps us and Third Parties provide more relevant advertising to you.
SHARING INFORMATION
Affiliates
We may share any of your information with our parent, subsidiary and other affiliated companies (each an "Affiliate") and as described below. To the extent that these Affiliates have access to your information, they will give such information at least the same level of protection and treat it at least as protectively as they give to treat information they obtain from their other users. Our Affiliates will follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.
Third Parties
We may disclose any of your information to respond to law enforcement requests, or where required by applicable laws, court orders, or government regulations, or to protect against misuse or unauthorized use of our Services, or to protect the personal safety or property of our users or the public. We may also disclose any of your information to third party business partners, stores and service providers who perform services for us (all collectively, the “Third Parties”), such as billing processing, collecting, storing and analyzing data, providing search results and links, and providing advertising and marketing assistance. Those Third Parties have access to your information as necessary to perform their functions. These Third Parties may use your information to operate and improve their services, carry out other purposes that are disclosed to you and to which you consent, make predictions about your interests or preferences, provide you with advertisements tailored to your apparent interests, and send you any notifications, collect data about the placement, views and clicks of their advertisements. In addition, Third Parties that serve advertisements within our Services, as well as third party links to or from our Services, and third party marketplace may separately collect information about you.
Except as otherwise expressly described in this privacy statement, this document only addresses and applies to the use and disclosure of information we collect from you. We do not have access to, or control over, the technologies that Third Parties may use to collect information about your interests, and the data collection and disclosure practices of these Third Parties are not covered by this privacy statement. You should review those Third Parties privacy policies to understand the way your information may be collected and handled by such Third Parties.
In return for some of the premium features of the Services, you may choose to be a peer on the Luminati network. By doing so you agree to have read and accepted the terms of service of the Luminati SDK SLA. You may opt out of the network from settings.
Tutela Technologies Ltd. collects data relating to your use of our apps, other apps and your device, in a pseudonymized manner, that may include (a combination of) Personal Data elements, such as:
Location
Wireless network performance, usage, and identifiers, and
other permission-based user information.
Pseudonymous data is shared with wireless service providers and other third parties who use it to analyze aggregate consumer mobile trends and improve your wireless networks. Outside of GDPR participating countries, mobile advertiser ID may be shared for network marketing and advertising purposes in accordance with the Digital Advertising Alliance principles. No data is stored by Tutela for longer than 12 months.
For further information about Tutela’s data practices, including technical and organisational measures to ensure that personal data are not attributed to an identifiable natural person, please see the Privacy Charter. To opt out of data sharing with Tutela, please utilize the opt-out measures provided in the privacy statement, contact data.protection.officer@tutela.com, or contact us at kukuwe4ka.fm@gmail.com.
SECURITY
To safeguard the confidentiality and security of your information, we may use industry standard practices and technologies including but not limited to firewalls, encrypted transmission and data encryption of information. Unfortunately, no data transmission over the Internet can be guaranteed secure. As a result, while we strive to protect your information, we cannot guarantee the security of any information you transmit to us or from our Services, and you use these Services at your own risk.
To help us improve our service we collect the following information on an anonymous basis: Operating System, Date & time, Latitude, Longitude, Accuracy (GPS), SSID (network), BSSID (network), Internal MAC address (network), Bundle ID, Device Model, Device Manufacturer, Carrier Code (Android only), Carrier Name, Sim Code, Country, and Locale. In addition to helping us to measure the usage of our app this anonymous information is shared with third parties for their business purposes, including the creation of reports, market research and trend analysis. One of these third parties is Huq, data shared does not contain information from which users can be identified and we will not provide additional information to such third parties that enables such third parties to identify you. You can find a full description of our data collection and use practices in our Privacy and Security Policy here [•]. You can find a full description of Huq and what it does with the information collected via our app here: https://huq.io
INFORMATION RELATING TO CHILDREN
Our Services are designed to avoid the collection and use of "personal information" (as this term is defined in the Children’s Online Privacy Protection Act ("COPPA") from children under 13 other than for support of internal operations. We do not knowingly collect personal information from children. If we later obtain knowledge that a user of our Services is below 13, we will take steps to remove that child’s personal information from our systems. If you are under 13, you may not register for an account or otherwise provide any personal information to us. We encourage Parents and Legal Guardians to regularly participate and control their children’s online activities.
If a Parent or Legal Guardian believes that his or her child under 13 has submitted personal information to us, he or she may request us to review, delete or stop the collection of the personally identifiable information of his or her child. Parent or Legal Guardian may do so by contacting us via email using the address information provided below in this statement.
OPT-OUT MECHANISM
You can always control what information you choose to share with us on the Services. To do so you should review the settings on your device. In particular, you can change your settings in your mobile device as follows:
For iOS (Apple) devices:
Instructions on how to control location settings can be found here: https://support.apple.com/en-us/HT207092;
Instructions on how to limit add tracking can be found here: https://support.apple.com/en-us/HT202074 ;
For other privacy-related settings on iOS please go to Settings from your mobile device’s home screen and select “Privacy”.
For Android (Google) devices:
Instructions on how to control device location settings can be found here: https://support.google.com/nexus/answer/6179507?hl=en&ref_topic=6179522
Instructions on how to limit ad tracking on Android devices can be found here: https://support.google.com/nexus/answer/3118621?hl=en .
If you do not want Google Analytics to collect and use information about your use of the Services, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).
The Digital Advertising Alliance (DAA), Network Advertising Initiative (NAI) and European Interactive Digital Advertising Alliance (EDAA) offer consumer choice programs that allow individuals to opt-out of certain interest-based advertising. Please see the following links for more information:
CONTACT US
If you have any questions about this privacy statement, please contact us at kukuwe4ka.fm@gmail.com.