We at TinyTap Ltd. (“TinyTap” “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our customers. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at http://tinytap.it/site/terms/ (the “Terms“). This Privacy Notice describes the types of information we collect from you or your Child when visiting our Platform and/or Site. This Privacy Notice also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information.
TinyTap Ltd. is the data controller in respect of certain processing activities outlined in this Privacy Notice. Our registered office is Gershon Shatz 41, Tel Aviv, Israel and our registration number 51-481451-6.
If you are a Group Leader, you may receive or have access to certain Personal Information (as defined below) of other users (including Reports). Similarly, if you are a Parent, you may receive certain Personal Information relating to your Child’s use of the Platform. In such capacity, you will be considered a co-controller of any Personal Information made available and/or provided and/or collected by you and your collection, processing and transfer of any Personal Information as a co-controller is subject to the Data Sharing Agreement, available at https://tinytap.it/site/data_sharing_agreement/.
“Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
- Personal Information We Collect. When you register, we collect Personal Information provided by you, such as your name and email address and any User Content you may upload to the Platform, if you register a Child (subject to Parental Consent as require under the Terms), such Child’s name and birth date. If you register through a third party, we may collect information from such third party account. Combining certain information, including information regarding your progress and/or participation in a Game and/or other Content available on the Platform may result in our collection of ‘special categories of data’ (as such term is defined in the Terms). We also (automatically) collect information about your use of the Platform and/or Site. If you contact us for questions or complaints, we will collect the information related to your inquiry.
- Basis for Processing Your Personal Information. Processing your Personal Information is necessary for the performance of the Terms and the provision of the Platform and Services to you. Processing for the purposes of developing and enhancing our products and services, for marketing purposes, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
- How We Use the Information We Collect. We use the information (including Personal Information) we collect mainly to administer and provide our Platform, Site and Services, contact you with administrative information, contact you with marketing offers (if you indicated your desire to receive them, to the extent required by applicable law), and improve the Platform and Site.
- Sharing the Personal Information We Collect. We may share the Personal Information we collect with our service providers and subcontractors who assist us in the operation of the Platform and Services and process the information on our behalf and under our instructions, as well as with any relevant Group Member.
- International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Information. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
- Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Information and obtain a copy of the Personal Information we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. Subject to applicable law, you may have the right to object to processing your personal data in certain circumstances, including for marketing purposes.
- We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
- We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Information, but they do not provide absolute information security.
- Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.
Information We Collect
We collect information from you when you choose or permit a Child to use our Platform, Services and/or when you visit or use our Site. In order to access certain services and content on our Platform, you will be required to register an account for yourself or on behalf of a Child and provide us with certain Personal Information. Registration of a Child is permitted only if you are such Child’s Parent or if you have obtained Parental Consent, in accordance with the Terms. We also collect Personal Information when you make use of the Platform and/or Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. If you use the Platform or Site by logging in through any third-party login service, we may also receive Personal Information about you as provided or available by such third-party login service. Please check such third-party’s policies in order to understand what information we receive.
Examples of the Personal Information that we collect from you may include your or a Child’s name, birth year, your email address and other information regarding your and/or the Child’s use of and activity on the Platform, preferred language and age group, device location, language settings, and device type, as well as certain user characteristics and preferences (such as whether a user is a teacher, Parent, Child, student or member of a particular class and/or School and/or Group). Such Personal Information may be collected by us through the Platform and/or Site.
Combining certain information, including information regarding your progress and/or participation in a Game and/or other Content available on the Platform may result in our collection of ‘special categories of data’ (as such term is defined in the Terms).
We also collect any materials including images, pictures, text, documents, audio recordings, comments, reviews, follows and likes, assignments, ratings, photo’s or other User Content, you may provide, including when uploading a Game to the Platform and/or Site.
In addition, when you use the Platform and/or Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, device ID, device language, as well as your browsing history and any information regarding your viewing and user history on our Platform or Site.
It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register you or your Child to the Platform and/or Services.
How We Use Your Personal Information
We and any of our trusted third-party subcontractors and service providers may use the Personal Information we collect from and about you for any of the following purposes: (1) to provide you with the Platform and Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, subject to your consent as may be required under applicable law, targeted offers on the Platform and/or Site, on other third-party sites or apps you may visit, or via e-mail; (5) to contact you with informational newsletters and promotional materials relating to our Platform or Services; (6) to review the usage and operations of our Platform, Services and/or Site; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Platform, Services and/or Site, and address any problems with the Platform, Services and/or Site;(9) to provide customer support; (10) collect information for machine learning algorithms that helps us present better recommendations to you and (11) gather and present your or your child’s games performance reports.
By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and Services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout, for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy : https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
We may use your Personal Information as required or permitted by any applicable law.
Disclosure of Information
We may share your information, including Personal Information, as follows:
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Information we collect from and/or about you, to our trusted service providers, business partners, affiliates and subcontractors, who may use such information to: (1) help us provide you with the Platform, Services and/or Site; and (2) aid in their understanding of how users are using our Platform, Services and/or Site.
Disclosure to Group Leaders
If you are a Group Member, we may disclose information (including Personal Information) regarding your activity on the Platform and/or Site to the Group Leaders, as well as to any third-party to whom you request we provide such information. If you are a Child, we will disclose or give access to your Personal Information to your Parent, and if we have received Parental Consent, to a Group Leader.
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Information). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
We may transfer our databases containing your Personal Information if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Information, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at firstname.lastname@example.org.
Other Uses or Transfer of Your Information
We allow you to use our Platform and/or Site in connection with third-party services, sites, and/or mobile applications. If you use our Platform and/or Site with or through such third-parties, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third-parties outside of our Platform and Site, their own terms and privacy policies will govern your use of those services.
How We Protect Information
We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
How to Access and Limit Our Use of Certain Information
You have certain rights in relation to the Personal Information that we hold about you, as detailed below. We reserve the right to ask for reasonable evidence to verify your identity before we provide any information and/or comply with any of your requests, as detailed below:
- Right of Access and Data Portability. You have a right to know what Personal Information we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Information to another party. If you or wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to Correct Personal Information. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Information and/or that we suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Information. In certain circumstances you have a right to have Personal Information that we hold about you deleted. Should you wish to have any Personal Information about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Information provided to us within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Information. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Information, you should also delete our mobile application from your mobile devices and terminate your account with us and clear our cookies from any device where you have used our Platform and/or Site. We may retain certain Personal Information (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
- Account Deactivation. You may deactivate your account through our website and/or mobile application or by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
- Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If you do, please update your account settings on our website, available at https://www.tinytap.it/account/settings/notifications/, or notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
- Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Information including for the purpose of direct marketing.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
We retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
- A “session cookie” is temporary and will remain on your device until you leave the Platform or Site.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
|Type of Cookie||Why We Use These Cookies|
|Necessary||These cookies are necessary in order to allow the Site, Platform and Services work correctly. They enable you to access the site, move around, and access different services, applications, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.|
|Functionality||These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) and help us personalize your experience and offer you enhanced functionality and content.|
|Security||These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.|
|Performance||These cookies can help us collect information to help us understand how you use our Site and/or Platform, such as whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Services.|
|Analytics||These cookies help us learn more about which features are popular with our users and how our Services can be improved.|
|Advertising||These cookies are placed in order to delivery content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites.|
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.
Third Party Cookies
We use the following third-party cookies:
- Facebook analytics and ads retargeting (Advertising and Analytics)
- Hot-Jar analytics (analytics)
- TinyTap Session ID and age and language preferences (Security, Functionality, Necessary)
- Google Analytics (Analytics)
- Google Tag Manager (Analytics)
- Google Ad Remarketing (Advertising)
- Stripe Authentication and tracking (Security)
- Pinterest (Advertising and Analytics)
- Tweeter (Advertising and Analytics)
- Bing (Advertising and Analytics)
Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Platform and/or Services. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at email@example.com. You will also be given the opportunity to unsubscribe from commercial messages and service-related communications in any such e-mail or message we send, as well as through your account settings on the Platform at https://www.tinytap.it/account/settings/notifications/ .
We collect personally-identifiable information from children under the age of sixteen (16) only subject to Parental Consent. In the event that you become aware that an individual under the age of sixteen (16) has enrolled without Parental Consent, please advise us immediately.
When creating a sub account, you shall be asked to accept the terms of this Privacy Notice on your behalf or on behalf of your / a Child (for the avoidance of doubt, if you are not a Parent and you accept the Privacy Notice on behalf of a Child, you represent and warrant that you have obtained consent from the Child’s Parent to accept this Privacy Notice on the Parent’s behalf. If you do not agree with the terms hereof, please do not use or permit your Child to use the Platform and/or Site. We may update this Privacy Notice from time to time – in which case, we shall notify you of such changes. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
Comments and Questions
- Notice to California Residents: Your California Privacy RightsIf you are a California resident, you have the right to receive: a) information identifying all third party companies to which we may have disclosed, within the past year, personal information pertaining to you for those companies’ direct marketing purposes; and b) a description of the categories of personal information disclosed. To obtain such information, please email your request to firstname.lastname@example.org.
We do not respond to Do Not Track signals at this time.
Last updated: May 2018