Last Revised: February 3, 2016
TabTale Ltd., its subsidiaries and its affiliates (“Company”, “we” or “TabTale”) respect the privacy of the users of their mobile applications (“User” or “you”) and are committed to protect the Users’ information. We believe that you have a right to know our practices regarding the information we may collect and use when you use our Apps (defined below).
1. Your consent (important, please read carefully!)
2. Offline Use
TabTale allows an offline use (without Internet connection and without GPS enablement) of some features of its Kids Apps. Offline use of Kids Apps will preclude the collection by TabTale and/or Third Parties of any information pertaining to you, as the legal guardian of a Kid, and/or your use (including, as applicable, information pertaining to your Kid and his/her use) of the Kids Apps.
3. Online Use
There are three types of data and information which may be collected from Users of our Kids Apps:
- 3.1 Non-personal Information: TabTale allows Third Parties to collect non-identifiable and anonymous information as detailed below (“Kids Non-personal Information”). To put it simply, with respect to such Kids Non-personal Information TabTale and the Third Parties are not aware of the identity of the User from whom Third Parties have collected the Kids Non-personal Information. Kids Non-personal Information collected by Third Parties may include the following technical information: type of operation system (e.g. Android, iOS, etc.), type of browser (e.g. Explorer, Firefox, Chrome, Safari, etc.), screen resolution (e.g. 800×600, 1024×768, etc.), language (e.g. English), device type (e.g. Galaxy, HTC, iPhone, etc.), geo-location – only general location may be collected. No street name or city/town name is collected.
The purpose for such collection: TabTale allows Third Parties collection of Non-personal Information for strict and limited purposes, namely, for the limited purpose of analysis to provide and improve the Kids Apps’ functionalities and performance.
- 3.2 Kids’ Persistent Device Identifier and No Other Kids personal identifiable information:
Third Parties may also collect a persistent device identifier from Kids, such as IP address unique device identifier, advertising identifier (when available on a device) etc. (“Kids’ Persistent Device Identifier”). TabTale does not collect and does not allow Third Parties to collect from Kids any personal information that may identify an individual (other than the Kids’ Persistent Device Identifier which is collected for the limited purpose of supporting the internal operations of the Apps) and any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that TabTale may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies.
TabTale does not allow any additional personally identifiable information to be linked to the Kids’ Persistent Device Identifier, even from other services.
The purpose for such collection: TabTale allows Kids’ Persistent Device Identifier to be collected strictly for internal operations of the Kids Apps including (without limitation) for serving Users of Kids Apps with advertisements as permitted under applicable laws and rules (for example, serving Users of the Kids Apps which are located in the United States with only “contextual advertisement”, which are advertisements that are served without connection to any behavioral elements).
- 3.3 Information gathered through the Kids Apps “Ask a Question” or “Support” type of a feature:
If a Kid e-mails a question to TabTale, using the “Ask a Question” or “Support” type of a feature which may be available within the Kids Apps, TabTale may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at TabTale’s discretion, not responding) to such question, TabTale will delete the Kid’s e-mail address.
How the Information about our Users of Kids Apps is being collected? The abovementioned Kids Non-personal Information and Kids’ Persistent Device Identifier are collected by Third Parties through the Users’ use of the Kids Apps, including, without limitation, through Third Parties’ SDK embedded in our Kids Apps. In addition, Kids Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Kids Apps, such as “cookies” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
4. Sharing Kids information with third parties
We may share the Kids’ Persistent Device Identifier only in the following cases:
- to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
- to detect, prevent, or otherwise address fraud, security or technical issues;
- to protect the rights, property, or personal safety of TabTale, its Users or the general public;
- when TabTale is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company;
- pursuant to the approval of a Kid’s legal guardian, in order to supply certain services such legal guardian or the User of the Kids Apps may have requested from the Company;
- to collect, hold and/or manage Kids’ Persistent Device Identifier through TabTale’s authorized Third Parties (including, as applicable, their affiliates, as necessary to provide us with the requested services) (for more information see a list of our Third Parties at: http://www.tabtale.com/3rdparties/), as reasonable for business purposes (and in accordance with the terms herein), which may be located in a country that does not have the same data protection laws as the User’s jurisdiction; and/or
- to let Third Parties, our partners or affiliates serve the Users of the Kids Apps with advertisements as permitted under applicable laws and rules.
For avoidance of doubt, TabTale may transfer and disclose Kids Non-personal Information to third parties at its discretion.
6. Additional Terms and Conditions
7. Which information may be collected from Users of our Crazy Labs Apps?
There are two types of data and information which may be collected from Users of our Crazy Labs Apps:
- 7.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or our third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). TabTale and Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to TabTale and/or Third Parties through use by Users of the Crazy Labs Apps. Non-personal Information which may be collected may include, for example, aggregate data, technical information, statistical information and behavioral information, and may contain, inter alia, device type, type and version of operating system, network provider, browser identifiers, type of browser, screen resolution, session information, User’s click stream on the Crazy Labs Apps, SDK version, API key, time spent playing, browser cookies, levels achieved, application version, in-app purchases, network status, local and time zone, clicks on advertisements Third Parties display on the Crazy Labs Apps, certain information about the advertisements reviewed by the User, the activities of the User in the Crazy Labs Apps (including without limitation any information relating to the User's activity in connection with the advertising displayed therein), what tools in the Crazy Labs Apps the User uses, etc.
- 7.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.
- Facebook Login feature: A User who wishes to enjoy certain features which may be available on our Apps may open an Account by using the “Log-in with Facebook” feature. Additionally, if a User uses the "Log in with Facebook" feature (which functionality is described in the TOU) then Facebook provides us with (i) access to certain information about such User as is stored in the User’s Facebook account, namely, the User's public profile (i.e., User's name, profile picture, email address, gender and other public information) and his/her list of friends and/or any other information which is detailed and displayed to the User in the notice which appears during the "Log in with Facebook" process. Please read carefully such notice in order to understand what information is available to TabTale via Facebook. We may collect your login information and other relevant information necessary to enable us to access your Facebook account (such as, Facebook User-ID, User access token) in order to collect and/or store, to the extent legally permissible, the aforesaid data contained within your Facebook account (or any part of it); and (ii) access to the information available in the Facebook Page Insights of the applicable Crazy Labs App. Please remember that the manner in which Facebook uses, stores and discloses your information is governed solely by its policies and TabTale shall have no liability or responsibility for the privacy practices or other actions of Facebook that may take place within the Crazy Labs Apps. If the User uses the "Log in with Facebook" feature, then such User agrees that we may share his/her name and/or profile picture and/or his/her game data (such as moves, progress in our games and scores) with respect to the applicable Crazy Labs Apps, with Users who have also used the "Log in with Facebook" feature in connection with the applicable Crazy Labs App or with the User's Facebook contacts. If you do not agree to these practices please do not use the “Log in with Facebook” feature in any of our Crazy Labs Apps.
- Opening an Account: When Users open an Account, they are required to provide their full name, e-mail address and to choose and confirm a password, birthday, gender, location (country). The User may be able (but is not required) to provide, the following details: links to other profiles of the User (e.g., Facebook page, Pinterest, YouTube, his/her own website, etc.). Please note that with respect to certain Apps, once User Generated Content created within an App is posted by a User within the App or in his/her Social Network or Platform, the details in his App profile will be visible to other Users of that App or Social Network or Platform users.
- User Generated Content: Personal Information which is being gathered consists of any personal details provided consciously and voluntarily by the User within the scope of their User Generated Content.
In addition, TabTale may collect, directly or through Third Parties, the following Personal Information:
- the User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;
- the User’s personal identifiers (such as, advertising identifiers (when available on a device), device identifiers, for example the IP address, carrier user ID, Unique Device Identifier (UDID), Media Access Control (MAC) address or social network ID). We note that TabTale may collect, use and provide access to the User's advertising identifier in accordance with the applicable platform provider's policies. We are also able to identify when a User installs a Crazy Labs App as a result of advertisements and/or campaigns that we launch on other services, including in Social Networks or Platforms (e.g. on Facebook or otherwise) and the source-ad which led to such installation and when a User views or clicks on such advertisements;
- information in connection with Users’ activities within the Crazy Labs Apps including his/her use of the services therein, including notifications, invite data, monetization events, accomplished stages, how long he/she spent in the game, etc.;
- geo location data from GPS-enabled device (to the extent that the User explicitly allowed it) provided by the devices’ interaction with the Crazy Labs Apps or association with your IP address. In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as, websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 20;
For avoidance of doubt, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
8. How the Information about Our Users is being collected?
There are three main methods:
- 8.1 Non-personal Information may be collected through your use of the Crazy Labs Apps. In other words, when you are using a Crazy Labs App TabTale and Third Parties are aware of it and may gather and collect, including without limitation, through such Third Parties’ SDK embedded in our Crazy Labs Apps, the information relating to such usage. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the Crazy Labs Apps, such as “cookies” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
- 8.2 Personal Information which you provide TabTale directly and/or through Third Parties via your installation and/or use of the Crazy Labs Apps or behavior with respect to advertisements thereof (such as your advertising identifier, persistent identifier and/or your geo location data), inter alia, through such Third Parties’ SDK embedded in our Crazy Labs Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the Crazy Labs Apps, such as “cookies” and local storage (see Section 19 below for further details with respect to Cookies and Local Storage).
- 8.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides TabTale through the Crazy Labs Apps “Ask a Question” type of feature, when he/she opens an Account or when he/she makes his/her User Generated Content available to others. In addition, we collect Personal information which you voluntarily provide when you use the "Log in with Facebook" feature (as further detailed above).
9. What are the Purposes of the Collection of Information?Non-personal Information is collected in order to:
- Use it for statistical, analytical and research purposes and for customization, development and improvement of our Crazy Labs Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on preferences shown by Users usage within the Crazy Labs Apps).
- Measure traffic and usage on the Crazy Labs Apps.
- Promote our Apps.
- Personalize and enhance the Users experience while using the Crazy Labs Apps.
- Improve the Crazy Labs Apps.
- Provide the Users with personalized content and information, including customized advertisements, interest-based advertisements, targeted advertisements, etc.
- Enable certain ad serving features, such as, frequency capping, etc.
- Enable certain functionalities available within the Apps, for example in-app purchases.
- Ensure proper functioning of the Apps and services, respond to questions or requests which were provided using the “Ask a Question” feature.
- Enable the User to use the Game Center Features, the Social Features and the features which are available while using the "Log in with Facebook" feature.
- Provide Users with updated information regarding our products and services, including without limitations with respect to competitions which we may hold from time to time.
- To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User's participation.
- Authentication purposes including to verify the User's identity when he/she signs in to the App or his/her Account; verify clicks and/or installs, verifying User's identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.
- Measure reach and effectiveness of advertisements campaigns, to offer targeted advertising, to personalize experience by showing advertisements for products and services that are more likely to appeal to the User (i.e. behavioral advertising).
- Send push notifications to the User's device after the User has agreed to accept push notifications from TabTale or Third Parties. Users can deactivate push notification by changing the settings within the App and/or changing the notification settings in accordance with the instructions of the operating system running on the Users’ device. Users may also opt out by clicking the "unsubscribe" option contained in the message.
10. Sharing Information with Third PartiesWe may share Personal Information only in the following cases:
- to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
- to detect, prevent, or otherwise address fraud, security or technical issues;
- to respond to claims that any content published on the Crazy Labs Apps violates any right of a third-party;
- to protect the rights, property, or personal safety of the Company, its Users or the general public;
- when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company;
- pursuant to your explicit approval prior to the disclosure;
- to let our carefully selected Third Parties, partners and affiliates serve you with advertisements, support or services; or
- to collect, hold and/or manage your Personal Information through TabTale’s authorized Third Parties (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction.
- as part of a competition, receiving rewards or otherwise interact with our social media channels;
Please note that some of the Crazy Labs Apps include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.
In addition, TabTale may, at its discretion, advertise other TabTale Apps within the Crazy Labs Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random TabTale Apps.
12. Using Kamcord and Everyplay Features
13. Using Game Center Features and Social Features
Our Crazy Lab Apps may enable using certain Game Center Features and may include Social Features (defined in our TOU). The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”).
By using the Social Features and/or the Game Center Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby understand and agree that when you share content via Social Networks or Platforms that your content may become public and any person may re-post-it.
14. Using a feature which enables purchase of Merchandise
15. Additional Terms and Conditions
16. Third Party Providers
17. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. TabTale does not exercise control of such third parties and is not responsible for their privacy practices and their use of the Users’ personal information. You hereby consent to the collection and use of your Personal Information by such third parties in accordance with their privacy policies.
18. Links to Third Party sites
19. Cookies & Local Storage
20. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifier or limiting ad tracking setting. If you are using Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent that such options exist) may not cease all tracking activities by TabTale’s third parties' service providers.
21. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. We will take steps reasonably necessary to ensure the protection of your Personal Information.
22. Direct Marketing
You hereby agree that we may use the contact details you provided us to inform you regarding competitions we may hold, our new products and/or services, and to send to you other material. You may withdraw your consent by changing the settings within the App, and/or by clicking the ‘unsubscribe’ option or alternatively following the instructions for removing yourself from the mailing list which are contained in the message which was sent to you.
23. California Privacy Rights
To the extent applicable, California Civil Code Section 1798.83 permits our Users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request please send an email to email@example.com. TabTale is only required to respond to one request per user each calendar year.
24. Deletion and Modifications of Information
You or, as applicable, your legal guardian, may request, by sending us an email to firstname.lastname@example.org, the following:
- to receive access to, amend, and/or delete your Personal Information and/or, as applicable, Kids’ Persistent Device Identifier, that we may hold, and/or that we cease collection or use of your Personal Information; and/or
- that we request Third Parties who collected through the Apps the User’s Personal Information and/or, as applicable, the Kids’ Persistent Device Identifier, to do the same. TabTale will use reasonable efforts to ensure that such Third Parties do so.
We note that some of these actions may be done directly through the settings of your Account.
After you have stopped using the Apps and/or following the termination of your Account, we will retain User’s Personal Information, and, as applicable, Kids’ Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfill the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, to enforce these Terms and our agreements and/or to enable Users to reinstate their Account, all as permitted under applicable privacy laws.
Personal Information that a User has shared using our Crazy Labs Apps via any Social Network or third party Platform cannot be amended or deleted by TabTale, where such information is in the control of that Social Network or third party Platform. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps. Aggregate and/or anonymous information may remain on our servers indefinitely.
Security of your information is very important to us. We take reasonable measures to maintain the security and integrity of our Apps and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. TABTALE SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED DISCLOSURE OR ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, ALTERATION, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.
27. Got any Questions?