| PURPOSE FOR PROCESSING | DATA CATEGORY | LEGAL BASIS FOR PROCESSING | DATA CATEGORY - ANONYMISED OR ENCRYPTED |
|---|---|---|---|
| Creation and setting up of account, help you log in and to provide access to and deliver our Services | Phone number, User ID (which is automatically assigned on registration), gender, profile picture and any other information that the User chooses to share in the ‘Profile’ section of the Services (“Account Data”) | Processing is necessary for performance of a contract with the user (i.e., creation of an account) and take steps prior to entering a contract with Users. Without this information, we will not be able to provide Services which the Users have requested. It is in our legitimate interest to verify your identity or conduct appropriate checks for fraud prevention and detection before authenticating you and granting you access to the Services. Where required by applicable laws we will obtain your consent. Processing is necessary for compliance with our legal obligations. |
Encrypted |
| To maintain and improve the Services, manage, and analyse the functioning of the Services, conduct our business and for administrative purposes. We use this information to gauge market interest in different geographic regions to assist in product road-mapping, positioning and inform and tailor our Services and marketing. |
IP address (including approximate location and country), exact geolocation data (including longitude and latitude), mobile device identifier, device IDs such as IDFA and Android ID, advertising identifier (e.g. Google advertising ID) or other unique identifiers, data about your operating system, device model and device language, log data (e.g. network connection type, applications connected to the Services) (“Device Data”). | It is in our legitimate interest to maintain, improve and tailor our Services in order to provide you with the best possible Services. The processing is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy). Where required by applicable laws we will obtain your consent. |
Encrypted |
| Enabling you to redeem game coins earned on our Services. | Account Data Payment information such as your bank details, online payment service details such as PayPal or mobile payment service details such as Venmo, Stripe, etc (“Payment Data”) Email address which we are required to collect by our online/mobile payment service providers. We collect data when you play and engage with games on our Service, game achievements, statistics and information on bugs and malfunctions. Device Data (with precise geolocation) Session ID, information on how you access the Services (including time you launched the Services, any adverts that you viewed or clicked on including User click timestamp, the objects and links you clicked on and interacted with, scrolling information, frequency, what time, how long and from which device(s)), and your approximate location or the country from which you are accessing the Services (“Usage Data”) |
Processing is necessary for the performance of a contract with the User (i.e. providing you with the ability to redeem game coins). Processing is necessary for TORNO to enable you to redeem game coins and to prevent abuse of game coin system. You may object to providing your email address; however, this may mean that you will not be able to redeem game coins. Where required by applicable laws, we will rely on User consent. It is necessary to protect vital interest of Users for example by identifying and preventing addictive behaviour. It is in our legitimate interest to identify and prevent fraud and distinguishing between human and bots. Processing is necessary for compliance with our legal obligations, for example to comply with any accounting and business laws. |
Encrypted |
| Personalisation of ads and targeted advertising and to track the effectiveness of any advertising | Account Data Device Data Gameplay Data |
It is in our legitimate interest to track and measure the effectiveness of any advertising, delivering interest-based advertisements and to tailor our Services so it is more relevant to our Users. Where required by applicable laws we will obtain your consent. |
Anonymised |
| Personalisation of the Services, building User profiles, customising, adapting, and personalising Users’ viewing of the Services and content/game consumption experience. We use information about how you use and connect to our Services to tailor how we present our Services to you on your device. We use this information to monitor and measure the performance of our Services. |
Account Data Device Data Gameplay Data Usage Data |
It is in our legitimate interest to provide you with a Service personalized to your needs and tailor how we present our Services to the you and determine what products and Services may be of interest to you. The processing is necessary for our legitimate interests (for running our business, provision of administration and IT services and network security). Where required by applicable laws we will obtain your consent. |
Encrypted |
| Display gameplay statistics, your Display Name/Username, User ID on the leaderboard, high scores, win records, streaks, game coins earned and track game engagement and user preferences | We collect data when you play and engage with games on our Service, game achievements, statistics and information on bugs and malfunctions, gameplay content including user game scores, recordings of your gameplay and performance records (“Gameplay Data”) Account Data. Usage Data |
The processing is necessary for the performance of a contract with you. It is to protect the vital interest of Users by detecting bots and preventing fraud and cheating. Where required by applicable laws we will obtain your consent. |
Encrypted |
| Monitor and analyse usage and activity trends including in-app searches, including measuring the effectiveness of our Services and marketing campaigns | Account Data Device Data Gameplay Data Usage Data |
It is in our legitimate interest to monitor and analyse the use and effectiveness of our Services in order to improve our Services. It is to protect the vital interest of Users by detecting bots and preventing fraud and cheating. The processing is necessary for the performance of a contract. Where required by applicable laws we will obtain your consent. |
Anonymised |
| Sending promotional communications, surveys, planning our promotion strategy, participating in User testing. We use this information to develop existing products and create new products or otherwise improve our Services. |
Account Data Device Data Gameplay Data Usage Data |
It is in our legitimate interest to keep you updated on our existing and new Services by sending you relevant marketing communications and surveys, and by processing the data that we collect in this respect or via User testing. Where required by applicable laws we will obtain your consent. |
Encrypted |
| To send you push notifications, SMS alerts for OTP verification, and other types of notifications on your device | Account Data Device Data |
The processing is necessary for the performance of a contract with you. Where required by applicable laws we will obtain your consent. |
Encrypted |
| Customer service, including when contacting us in-app chat with us feature or through email. We use this information to develop existing products and create new products or otherwise improve our Services. |
Account Data Email address Device Data |
The processing is necessary for our legitimate interests, namely communicating with Users and responding to queries, complaints and concerns. The processing is necessary for our legitimate interests, namely to develop our products/Services. The processing is necessary for the performance of a contract. Where required by applicable laws we will obtain your consent. |
Encrypted |
| Security and fraud prevention | Account Data Device Data (including exact geolocation with longitude and latitude) Usage Data |
It is in our legitimate interest to keep our platform safe and secure and to protect our Services from fraud, and to protect your personal data and our systems from any security incidents or personal data breaches. Where required by applicable laws we will obtain your consent. |
Encrypted |
| Identification and Rectification of errors | Crash logs including information about usage and performance statistics, network speed, the time that certain features take to launch and errors or delays in using certain features. | It is in our legitimate interest to identify and fix errors in the Services to provide smooth Services to the Users. | Anonymised |
| We use all the personal data we collect to communicate with you, to monitor, operate, maintain and improve our technology and related services and business and to help us develop new products and services. | All personal information set out above | The processing is necessary for our legitimate interests, namely, to administer and improve our Services. | Encrypted |