Touch Games

Privacy Policy

Touch Games respects the privacy of its online visitors and customers of its products and services and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and the Swiss and EU Privacy Shield Frameworks.

1. Definitions

Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information. Touch Games also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. Touch Games may share anonymous data, aggregated or not, with third parties.

Other capitalized terms in this Privacy Policy shall have the meanings defined in the Touch Games Subscriber Agreement.

2. Why Touch Games Collects and Processes Data

Touch Games collects and processes Personal Data for the following reasons:

a) where it is necessary for the performance of our agreement with you to provide a full-featured gaming service and deliver associated Content and Services;

b) where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);

c) where it is necessary for the purposes of the legitimate and legal interests of Touch Games or a third party (e.g. the interests of our other customers), except where such interests are overridden by your prevailing legitimate interests and rights; or

d) where you have given consent to it.

These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).

3. What Data We Collect and Process

3.1 Basic Account Data

When setting up an Account, Touch Games will collect your email address and country of residence. You are also required to choose a user name and a password. The provision of this information is necessary to register a Touch Games User Account. During setup of your account, the account is automatically assigned a number (the "Touch Games ID") that is later used to reference your user account without directly exposing Personally Identifying Information about you.

We do not require you to provide or use your real name for the setup of a Touch Games User Account.

3.2 Transaction and Payment Data

In order to make a transaction on Touch Games (e.g. to purchase Subscriptions for Content and Services or to fund your Touch Games Wallet), you may need to provide payment data to Touch Games to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Touch Games, which Touch Games will process and transmit to the payment service provider of your choice to enable the transaction and perform anti-fraud checks. Likewise, Touch Games will receive data from your payment service provider for the same reasons.

3.3 Other Data You Explicitly Submit

We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on Touch Games, e.g. in Touch Games Community Forums, chats, or when you provide feedback or other user generated content. This data includes:

-Information that you post, comment or follow in any of our Content and Services;

-Information sent through chat;

-Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;

?Information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.

3.4 Your Use of the Touch Games Client and Websites

We collect a variety of information through your general interaction with the websites, Content and Services offered by Touch Games.

Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.

Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.

3.5 Your Use of Games and other Subscriptions

In order to provide you with services, we need to collect, store and use various information about your activity in our Content and Services. "Content-Related Information" includes your Touch Games ID, as well as what is usually referred to as "game statistics". By game statistics we mean information about your games' preferences, progress in the games, playtime, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.

3.6 Tracking Data and Cookies

We use "Cookies", which are text files placed on your computer, to help us analyze how users use our services, and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different devices and our services, as well as to improve the services we are offering, to improve marketing, analytics or website functionality. The use of Cookies is standard on the internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser.

3.7 Information Required to Detect Violations

We collect certain data that is required for our detection, investigation and prevention of fraud, cheating and other violations of the SSA and applicable laws ("Violations"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on of such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations.

4. How Long We Store Data

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.

In particular:

-If you terminate your Touch Games User Account, your Personal Data will be marked for deletion except to the degree legal requirements or other prevailing legitimate purposes dictate a longer storage.

-In certain cases Personal Data cannot be completely deleted in order to ensure the consistency of the gameplay experience or the Touch Games Community Market. For instance, matches you have played that affect other players' matchmaking data and scores will not be deleted; rather, your connection to these matches will be permanently anonymized.

-Please note that Touch Games is required to retain certain transactional data under statutory commercial and tax law for a period of up to ten (10) years.

-If you withdraw your consent on which a processing of your Personal Data or of the Personal Data of your child is based, we will delete your Personal Data respectively the Personal Data of your child without undue delay to the extent that the collection and processing of the Personal Data was based on the withdrawn consent.

-If you exercise a right to object to the processing of your Personal Data, we will review your objection and delete your Personal Data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.