PRIVACY POLICY
Effective Date: Jan 1st, 2023
Thank you for playing our games! This Privacy Policy describes:
- The ways we collect personal data about you and why we do so
- How we use your personal data, and
- The choices you have about your personal data.
This Privacy Policy applies to Tnkfactory’s games, store, sites
and related services, which we here collectively call the Service. We may
periodically update this Privacy Policy by posting a new version on Tnkfactory.com.
If we make any material changes, we will notify you as required under
applicable law, including by posting a notice in the Service prior to the
change becoming effective. Your continued use of the Service after the effective
date will be subject to the new Privacy Policy.
CONTACT US
If you have questions about data protection, or if you have any
requests for resolving issues with your personal data, we encourage you to
primarily contact us through the support features within each Tnkfactory game,
so we can reply to you more quickly. Alternatively, you may contact:
Personal information manager
Name: Choi Myeongjo
Position: CISO
Tel: +82-70-8837-0759
Email:
mjchoi@tnkfactory.com
THE DATA WE COLLECT
The categories of personal data we collect depend on the Services
you use, and the requirements of applicable law.
Data you provide us directly.
- Contact information (such as name and email address or phone numbers)
- Player name or tag and password
- Profile information (such as profile photo)
- Your messages and other content you submit when you use the Service (such as chat logs and player support tickets)
- Data you provide in connection with surveys, promotions, sweepstakes, competitions and other events
- Other data you choose to give us
Data we collect automatically.
- Data about your account and game progress, including in most cases an automatically created internal account ID
- Your IP address and mobile device identifiers (such as your device or advertising ID)
- Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
- Data we collect with cookies and similar technologies (see more below)
- Approximate location data (as derived from IP address)
- Data about your use of the Service, such as gameplay data, purchases made and your interactions with other players inside the Service
Data we collect from our partners.
We also use third-party partners, such as social networking sites,
data analytics providers and advertising networks to supplement information we
have about you, such as:
- Data we receive if you link a third-party tool with the Service (such as LINE, Facebook, WeChat or Kakao)
- Demographic data (such as to determine the coarse location of your IP address)
- Data to fight fraud (such as refund abuse in games or click fraud in advertising)
- Data from platforms that the games run on or data from payment service providers (such as payment verification data)
- Data for advertising and analytics purposes (such as surveys), so we can provide you a better Service
- Data that you have made available to us from a third party service (such as LINE, Facebook, WeChat or Kakao) via your privacy settings
WHY DO WE COLLECT YOUR DATA
We use your data for a variety of business purposes, such as:
To make the Service work.
To perform the contract, we process data necessary to
- Create accounts and allow you to play our games and use our Service
- Operate the Service
- Verify and confirm payments
- Provide and deliver products and services you request
- Send you Service-related communications
To make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
- Update and develop player profiles
- Develop and improve the Service and player experience
- Manage our relationship with you
- Provide social features as part of the Service
- Customize your Service experience
- Respond to your comments and questions and provide player support
- Provide you Tnkfactory offers in the Service as well as in other websites and services (including by email)
- Send you related information, such as updates, security alerts, and support messages
- Enable you to communicate with other players
To show personalized advertisements.
To show you personalized advertisements in the Service and elsewhere (including email) we have a legitimate interest to process necessary data to
- Track the content you access in connection with the Service and your online behavior
- Deliver, target and improve our advertising and the Service
For information on how to opt-out from personalized advertisements, see section 'Your Rights and Options' below.
To keep the Service safe and fair.
Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy;
Tnkfactory Terms of Service
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
- Analyze and monitor use of the Service and its social features
- Moderate chats either automatically or manually
- Take action against fraudulent or misbehaving players
To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
With your consent.
With your consent, we may process your data for additional purposes.
We may also collect and use your device identifiers to display and
personalize in-game ads as explained below. Where applicable, we may collect
your advertising identifier, IP address and device ID for these purposes. Under
applicable privacy laws, including the General Data Protection Regulation
(GDPR), we are required to ask your consent to do so.
This data is shared with your consent so that our ad partners can
deliver the right ad and optimize the ad content to make sure you don’t see the
same ad multiple times. We share your device identifiers with selected partners
for such ad delivery and personalization.
The partners operate the ad network and mediation platform, as
well as facilitate and participate in ad inventory bidding. The partners may
also use the device identifiers for fraud detection purposes based on their
legitimate interest. For more information, please check the partners’ privacy
policies.
- Google (Admob, Analytics) :
https://policies.google.com/privacy?hl=en
- Adcolony :
https://www.adcolony.com/privacy-policy/
- Facebook Ads :
https://www.facebook.com/about/privacy/
-Flurry :
https://policies.yahoo.com/us/en/yahoo/privacy/products/developer/index.htm
- InMobi :
http://inmobi.com/privacy-policy/
- Vungle :
https://vungle.com/privacy/
- Applovin :
https://www.applovin.com/privacy/
- Fyber :
https://www.digitalturbine.com/privacy-policy/
- Tapjoy :
https://www.tapjoy.com/legal/publishers/publisher-terms-of-service/
- Pangle :
https://www.pangleglobal.com/privacy
- Unity Ads :
https://unity.com/legal/privacy-policy
- ironSource :
https://www.is.com/privacy-policy/
WHO CAN SEE YOUR DATA
Apart from Tnkfactory, your data can be accessed by others in the following situations:
Other players and users.
Social features are a core component of our games. Other players
and users may, for example, see your profile data, in-game activities and read
the messages you have posted.
Our service providers.
Tnkfactory has vendors who help us to provide the Service. These
vendors process your data only at and according to Tnkfactory´s instructions to
provide the Service, and perform tasks such as hosting, player support,
advertising, analytics and fraud prevention.
Other companies and public authorities.
In order to verify payments (with payment providers such as
Paypal) and combat fraud and illegal activity, we may process and disclose data
with other companies and organizations and provide it to public authorities in
response to lawful requests.
We may also disclose your data based on your consent, to comply
with the law or to protect the rights, property or safety of us, our players or
others.
Advertising and Social Media partners.
The Service includes features from our partners, such as social
media interaction tools, functionalities through application programming
interfaces (APIs) or software development kits (SDKs) and in-game advertising.
These partners may access your data and operate under their own privacy
policies. We encourage you to check their privacy policies to learn more about
their data processing practices.
These partners may access data regarding your activities and your
device (such as your IP address, mobile identifiers, page(s) visited, location,
time of day). We may also combine and share data we have collected about you
with third-party advertising partners. These advertising partners may use this
data (and similar data collected from other services) for purposes of
delivering targeted advertisements to you when you visit third-party services
within their networks. These partners may operate under their own privacy
policies. This practice is commonly referred to as “interest-based advertising”
or “online behavioral advertising.” If you prefer not to share your personal
data with third-party advertising partners, you may follow the instructions in
“Your Rights and Options” below.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and your data can therefore be
transferred to anywhere in the world. Because different countries may have
different data protection laws than your own country, we take steps to ensure
adequate safeguards are in place to protect your data as explained in this
Privacy Policy. Adequate safeguards that we may use include standard
contractual clauses approved by EU Commission and other lawful safeguards.
YOUR RIGHTS AND OPTIONS
Opt out of marketing emails and other direct marketing.
You may opt out of receiving promotional communications, such as
marketing emails from us by following the instructions in such communications,
or by changing your in-game settings. The updated settings may not be effective
immediately.
Push Notifications
We may send you push notifications through our mobile
applications. You may at any time opt-out from receiving these types of
communications by changing the settings on your mobile device.
Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile
applications by checking the privacy settings of your Android or iOS device and
turning off “Allow Apps to Request to Track” or selecting "Limit Ad
Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android).
For more information,
You can also opt out from personalized in-game offers through the
options provided in the game settings (where applicable).
Access the personal data we hold about you.
If you request, we will provide you a copy of your personal data
in an electronic format.
Your other rights.
You also have the right to correct your data, have your data
deleted, object how we use or share your data, and restrict how we use or share
your data. You can always withdraw your consent.
We will respond to all requests within a reasonable timeframe. If
you have an unresolved privacy or data use concern that we have not addressed
satisfactorily, you may also contact your local data protection authority
within the European Economic Area, Switzerland or UK for unresolved complaints.
If you wish to exercise any of your data subject rights described
above, please use the support options described in “Contact Us” above. We will
respond to all requests in accordance with applicable laws. To protect your
privacy, we may also take additional steps to verify your identity before
fulfilling your request, such as by requesting you provide us a purchase
receipt or other account information, asking you to link your email address
with your game account (for example through Tnkfactory ID), or asking you to
answer questions regarding your activities on our Services. Once you have
verified your identity, you may also designate an authorized agent to exercise
your rights on your behalf by providing the agent’s contact information to our
customer support staff, as required by applicable law.
You have the right not to receive discriminatory treatment as a
result of your exercise of these rights.
COOKIES AND SIMILAR TECHNOLOGIES
Like most online services, we and our partners use cookies and
similar technologies to provide and personalize the Service, analyse use,
target advertisements and prevent fraud. Cookies and similar technologies allow
us and our partners to store their preferences and track your activities within
the Service. Note that our partners may operate under their own privacy
policies.
We and our partners collect and store information about users'
interactions with unaffiliated websites and applications that use our
technologies, including cookies and similar tracking technologies. This allows
us to infer the presence of a common user or household behind multiple devices
or browsers, for instance, and then link those browsers and devices into a
device graph. We do so in order to
- detect and prevent fraud;
- allow users to use the Service on one device and pick up seamlessly where they left off on another device;
- analytics, personalization and attribution;
- limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or
- provide personalized advertising on each device that is inferred from the browsing patterns on all of the devices.
HOW DO WE PROTECT YOUR DATA
Security Safeguards.
In order to help ensure a secure and safe player experience, we
are continuously developing and implementing administrative, technical and
physical security measures to protect your data from unauthorized access or
against loss, misuse or alteration.
Data retention.
We retain your data for as long as your account is active or as
needed to provide you the Service. We may for example periodically de-identify
unused game accounts, and we may regularly review and de-identify unnecessary
data.
Note that if you ask us to remove your personal data, we will retain your data
as necessary for our legitimate business interests, such as to comply with our
legal obligations, resolve disputes, and enforce our agreements.
CHILDREN
Protecting children’s privacy online is very important to us.
Generally, our Services are not directed to children under 13 (or other age as
required by local law), and the Services do not knowingly collect personal data
from children, except as described in the following paragraph.
For games that are not directed at children but nonetheless may
appeal to them, we take additional steps to limit access to these Services
based on the player’s age. For these Services, when a player indicates they are
under 13 (or the applicable age in their territory), we will limit their access
to certain features, such as social media and chat features, as well as certain
types of notification alerts. We also limit the processing of personal data to
only what is necessary to support the internal operations of our Services.
Please note that for some of our Services we may use a higher age
limit (such as 16) than described in the above two paragraphs. We do this to
provide a safe game experience for our players and to protect Young Players.
If you are a parent or guardian and wish to review personal data
collected from your child, or have that information modified or deleted, you
may contact us as described above. If we become aware that a child has provided
us with personal data contrary to the above, we will delete any personal data
we have collected, unless we have a legal obligation to keep it, and terminate
the child’s account and/or revert them to the underage experience, as
applicable.