Children’s Privacy Notice
Hello! This is where we keep our Privacy Policy.
We are devoted to creating fun mobile games that brighten up your day. We care about your safety online and want you to have the best time with our apps.
When you play our games, we do not collect any of your personal information, such data as your full name, address, email or phone number.
We may collect general information, for example, the country you live in, how much time you spend in our game, types of mobile devices you use and similar. This info is not associated with you, we are getting it as a big pile of impersonalised numbers. This information helps us better understand our audience and improve our games.
In our games, you may see ads. We have a dedicated ads quality team to sure that all ads are appropriate for children and that no personal information about your interactions with ads is collected.
The rest of this document is a detailed information about our privacy practices. If you have any questions about your privacy or this Privacy policy, you may always contact us at [email protected] for more information.
TULU GAMES PRIVACY POLICY
Last Revised: 6th of April, 2023
At Tulu, ("Tulu", "we") we take privacy seriously and this this Privacy policy is designed to share what information we collect and how we use it. This Privacy Policy is in compliance with the US Children's Online Privacy Protection Act (COPPA) and the European General Data Protection Regulation (GDPR). If you have questions about this Privacy Policy or wish to exercise your rights, please do not hesitate to contact us by email at [email protected].
Tulu Limited is a company with registered office in Jimei District, Xiamen City, Fujian Province. We are the Data Controller responsible for your Personal Data.
Our contact details:
Tulu LIMITED
Jimei District, Xiamen City, Fujian Province
Email: [email protected]
While you visit our website at www.gptwife.com or you play Tulu games ("Services" or "Games"), we may collect information about you ("Personal Data"). By this Privacy Policy, we want to clearly and comprehensively explain what data we collect, how we use, disclose and transfer it.
From time to time, we may change the terms of this Privacy Policy, so do not forget to read this Privacy Policy on a regular basis to understand how we use your Personal Data. If we make a material change to this policy, we will post a notice on our website prior to making the change. If we have your parent email address, we will contact you to let you know about the changes.
Note: You must update any mobile applications downloaded before 2018 May 25th
Personal data is any information that relates to an identifiable individual. When you you visit our website at www.gptwife.com or you play Tulu games ("Services" or "Games"), we may we may collect and process the following personal data about you:
Contact Information
You may provide us with your Contact Information, such as your phone number and email when you contact us with a question or request.
Note: If a child under the age of 13 years old in the USA or under the age of 16 years old in the EU has contacted us through email, and we need to communicate with the child more than once to resolve the query, we will ask the child to provide us with the child's parent or guardian's email. Then we will send the parent or guardian a notice telling that his/her child has contacted us. If we do not obtain parental consent after a reasonable time from the date of the data collection, we will delete such data from our records.
Location Data
We do not collect data about your exact location (address) in any case. We can collect data about your location, i.e. city or country. We collect this data automatically when you use our Services or play our Games.
Technical Data
We may collect such information as your IP address, advertising ID, and other technologies on the devices that you use in our Services or play our Games. We can also collect non-personal Technical Data about the mobile operating system, mobile browser type, screen resolution, device vendor, language. We collect this data automatically when you use our Services or play our Games.
Usage Data
We can collect statistics on how you use our Services or play our Games. This information does not contain information that will help us identify you. We need this information so that we can provide you with the Services, improve their quality, adapt them to your needs.
Please note, if you decide to purchase the Tulu games subscription, we may collect and use additional personal data as stated in section 7. Tulu Subscription.
We are not collecting or storing any of your financial data as management of any payments is done by the respective platform you are using to download our apps from, such as iTunes, Google play, Amazon or others.
We do not collect and do not intend to collect "special categories of data", such as any information about health, race, religion, political opinions or philosophical beliefs, sexual beliefs or orientation, as well as any data that is not necessary for the provision of our services.
We use several methods to collect Personal Data:
Personal Data is provided directly by you
You provide us with your data when you contact us by email, social networks or phone, ask to answer your question.
We collect Personal Data automatically
When you use our Services, e.g. visit our website, play our games, we can automatically collect technical information about your IP address, promotional identifiers, equipment, browsing actions and models you use, as well as statistics. We collect this Personal Data using cookies, automated event logs and other similar technologies.
We collect Personal Data from third parties
We may receive Personal Data about you from third-party sources, i.e. from other companies and persons (see section Our third-party data controllers and processors).
We will only use your Personal Data as permitted by law. Usually, we will use your Personal Data in the following circumstances:
Provide our services or
Pursue legitimate business interests related to providing our services to you
In order to fulfil our obligations when you use our website or our mobile applications, e.g. to ensure that the Services are provided, to improve the Services, to identify subscribers and manage subscriptions, to personalize the content you use, to respond to your requests and inquiries. Also, in order to fulfil our legal obligations, we may ask for the child's parent or guardian's email when we must obtain the consent of parents or guardians to use the child's Personal Data (email and name). When it is necessary to fulfil our contractual obligations or safeguard our legitimate interests, we use your Personal Data, e.g. to provide you with contextual advertising, to analyse your behaviour using our Services, to ensure the security and integrity of our Services.
Establish, exercise or defend legal claims
We may also use your Personal Data to enforce or defend our rights, protect your interests, prevent and/or detect fraud or deceptive behaviour.
We will not use your data to provide you with behavioural advertising, as well as remarketing, profiling and automated decision making.
Generally, we collect and process your personal information only in order to fulfil our obligations to you, use it for legitimate interests and protect your rights (support for the internal operations), or if we have your consent to do so. Below, we provide you with information on the purposes and grounds for usage of your Personal Data.
| Activity | Data type | Legal basis for data processingaccording to GDPR / COPPA |
|---|---|---|
| Manage and protect our website and our mobile applications |
Contact Data Technical Data Usage Data |
(a) Necessary for our legitimate interests (GDPR) (b) Necessary for support for the internal operations (COPPA) |
| Provide Services, improve Services, customize Services for your individual needs |
Technical Data Usage Data |
(a) Necessary for fulfilling our contractual obligations (GDPR) (b) Necessary for support for the internal operations (COPPA) |
| Identify games subscribers and manage games subscriptions (only if you get subscription plan) |
Contact Data Usage Data |
(a) Necessary for fulfilling our contractual obligations (GDPR) (b) Necessary for fulfilling our contractual obligations (GDPR) |
| Submit contextual advertising to you, analyse your behaviour using our Services |
Technical Data Usage Data |
a) Necessary for our legitimate interests and for fulfilling our contractual obligations (GDPR) b) Necessary for support for the internal operations (COPPA) |
| Reply to your applications, requests, notifications |
Contact Data Contact data such as email or phone number |
a) Necessary for fulfilling our contractual obligations and for legitimate interests (GDPR) If a child under the age of 13 years old in the USA or under the age of 16 years old in the EU has contacted us through email, and we need to communicate with the child more than once to resolve the query, we will ask the child to provide us with the child's parent or guardian's email. Then we will send the parent or guardian a notice telling us that his/her child has contacted us. If we do not obtain parental consent after a reasonable time from the date of the data collection, we will delete such data from our records. |
| Get the child's parent's or guardian's consent |
Contact Data (email) |
a) Necessary to comply with our legal obligations (GDPR) b) Exception to prior parental consent (COPPA) |
We will use your Personal Data for the purposes for which we have collected them, unless we reasonably believe that we must use it for another purpose that is compatible with the original
Please note that in cases where we must process Personal Data when required by law, we may process your Personal Data without your knowledge or consent.
If you would like to curated selection of Tulu games for your child that cherish creativity and help develop useful, we will need to identify you by creating a subscriber's account. In order to get access to Tulu games subscription, a child's parent or guardian is required to agree to our Terms of Use and Privacy Policy as well as login by choosing a preferable login method (platform you’re using to play our games, such as Google Play, Apple App Store, etc.).
Personal data we collect
If you decide to get a Tulu games subscription for your child, we may collect and use some of your personal data, such as chosen login method, email address, current subscription plan, billing, connected devices, unique ID, advertisement ID and device ID.
We are not collecting or storing any of your financial data as management of any payments is done by the respective platform you are using to download our apps from, such as iTunes, Google play, Amazon or others.
By creating your TULUclub account, you may agree to receive our newsletters or other emails promoting any special offer(s). You can always opt out from receiving special promotions or marketing correspondence from us by unsubscribing as noted in the respective email correspondence.
How and why we use this data
We will use this data only to authenticate a user and manage the user’s subscription (e.g. to determine on how many devices subscription has been activated). We process your personal data ourselves, therefore personal information is not disclosed to any third party.
Please note that you have the right to cancel your subscription anytime, however your personal data collected before subscription cancellation will be stored for a period of three years in order to comply with our legal obligations and protect our legal interests.
When you use our services, we may use industry-wide technologies such as cookies and/or other technologies, hardware-based device identifiers, flash cookies, operating system-based identifiers and web beacons.
Cookies are small text files that we place in visitors’ computer browsers to store their preferences. The cookies are created for each session, they do not include or collect any information about you other than your session key, and they are removed as soon as the session ends (usually done automatically by your web browser).
You can disable cookies on your device or set your device to alert you when cookies are being sent to your device.
If you do not accept, block or erase cookies, or change the settings, your online experience may be limited.
We may also use certain third-party cookies (e.g. Google Authentication). These are different kinds of cookies that are stored on your computer by third parties. This kind of cookie is only read (and is not altered by the Service) each time you use our Services. Third party cookies store only Usage Data, such as the different pages you have visited strictly within the Service (such the “About” page, the “Contact Us” page, the duration of your browsing session, etc.).
We may share your personal information with a few selected third parties, such as:
- Companies of our group, third-party service providers and other partners (e.g. to ensure the provision of our Services, to provide services or to improve our Services security), as well as to those who otherwise process Personal Data for the purposes specified in this Privacy Policy. Here is a list of our current service providers and partners (see section Our third-party data controllers and processors).
- To any competent law enforcement authority, regulatory authority, government agency, court, or other third party, if we consider that disclosure is necessary (i) in accordance with applicable laws or regulations, (ii) to exercise or to protect our rights, or (iii) to protect our or any other person's interests;
- A potential or actual buyer (and its representatives and advisers) involved in the purchase, merger or acquisition of a proposed or actual any part of our business, provided that we inform the buyer that it will have to use your Personal Data only for the purposes specified in this Privacy Policy;
- Any other person with your consent to disclose information.
KIDOZ
KIDOZ is an advertising service provided by KIDOZ Ltd. KIDOZ uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Processing location: USA
Privacy policy: https://kidoz.net/website-and-kidoz-sdk-privacy-policy
Address: KIDOZ, PO BOX 8517, Poleg Industrial park, Netanya, Israel
Phone: +972-9-7716444
Contact: [email protected]
Chartboost (Chartboost, Inc.)
Chartboost is an advertising service provided by Chartboost, Inc. Chartboost uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: USA
Privacy policy: https://answers.chartboost.com/en-us/articles/200780269
Address: 85 2nd Street, Suite 100, San Francisco, CA 94105, US
Contact: [email protected]
SuperAwesome Trading Ltd
SuperAwesome is a contextual advertising service provided by SuperAwesome Trading Ltd. SuperAwesome uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: UK
Privacy policy: https://www.superawesome.tv/privacy-policy
Address: Trading Ltd, 22 Long Acre, London WC2E 9LY, United Kingdom
Contact: [email protected]
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google Analytics uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: USA
Privacy policy: https://policies.google.com/privacy?hl=en
Address: 1600 Amphitheatre Pkwy, Mountain View, California 94043, US
Phone: +1-650-253-0000
AdMob by Google (Google Inc.)
AdMob is a mobile advertising platform which allows developers to monetize their app(s) by displaying in-app ads from other advertisers. AdMob allows to set TFUA (Tag for Users under the Age of Consent in Europe) on ad requests. All ad requests that include TFUA disables ads personalization for users under the age of consent and collection of data by third party partners. Admob uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: US
Privacy policy: https://policies.google.com/privacy?hl=en
Address: 1600 Amphitheatre Pkwy, Mountain View, California 94043, US
Contact: https://support.google.com/policies/troubleshooter/7575787?visit_id=636888632405295138-51672301&hl=en&rd=2
ironSource Mobile Ltd.
ironSource Mobile Ltd. is a network that helps app us to serve ads on our apps, a mediation platform. ironSouce uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: US
Privacy policy: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Address: 121 Menachem Begin Rd., Tel Aviv, Israel
Contact: [email protected]
Liftoff
Liftoff is an ad network providing a technology platform for clients that want to advertise and/or monetize their applications, games, and other products. Liftoff uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: USA
Privacy policy: https://liftoff.io/privacy-policy/https://vungle.com/privacy/#section-1
Address: Clover House, 147-149 Farringdon Road, London, England, EC1R 3AB
Contact: [email protected]
Unity Technologies ApS. and Unity Analytics (Unity Technologies)
Unity Ads is an advertising service provided by Unity Technologies ApS. Unity Ads uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Privacy policy: https://unity3d.com/legal/privacy-policy
Address: Unity Technologies Finland OY, Kaivokatu 8 B, 00100 Helsinki, Finland
Contact: [email protected]
Firebase by Google (Google Inc.)
Firebase is a mobile analytics platform which allows developers to analyse crash reporting and retention. Firebase uses Personal and Non-Personal Data only for internal purposes.
Legal basis of processing: legitimate interests (support for internal operations).
Place of processing: US
Privacy policy: https://policies.google.com/privacy?hl=en
Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, US
Contact: https://firebase.google.com/support/troubleshooter/contact/
Singular
Singular is a marketing, attribution and automation services provider. Singular offers the ability to administer, measure and monitor their mobile advertising activities.
Legal basis of processing: legitimate interests (support for internal operations).
Privacy policy: https://www.singular.net/privacy-policy
Address: 181 South Park Street Suite, Apt 2 San Francisco, CA 94107, United States
Contact: [email protected]
PANGLE
Pangle is a global ad network under ByteDance, which enables effective mobile app monetization and ad performance. Powered by intelligent advertising technology, Pangle leverages interactive and high performing video ad formats to drive real business results.
Pangle may be implemented in some Tulu games on Apple App Store in the China market only.
Legal basis of processing: legitimate interests (support for internal operations).
Privacy policy: https://www.pangleglobal.com/privacy
Address: 1 Raffles Quay, #26-10 ,Singapore 048583
Contact: [email protected]
InMobi
Inmobi runs a marketing platform solution which provides advertising and monetization services/products.
Privacy policy: https://www.inmobi.com/privacy-policy
Address: Embassy Tech Square, Kadubeesanahalli Village Outer Ring Road, Varthur Hobli, Bangalore 560103, India
Contact: [email protected]
Mintegral
Mintegral is an AI-driven, programmatic, and interactive advertising platform.
Legal basis of processing: legitimate interests (support for internal operations).
Privacy policy: https://www.mintegral.com/en/privacy#privacy-policy-of-the-mintegral-services
Address: RM 701A 7/F, OFFICE PLUS, Prince Edward, 794-802 Nathan road, KL, Hong Kong, Hong Kong
We have implemented security measures to ensure that your Personal Data is not lost, used or accessed without authorization, altered or disclosed. We restrict access to your Personal Data to those employees, representatives and other third parties who need to know your details. They will process your Personal Data in accordance with our instructions and will be subject to the confidentiality obligation.
We have put in place procedures to combat any alleged breach of Personal Data security and we will inform you and all authorities of the breaches that we are required to notify about.
We work with ad networks Chartboost, AdMob (Google), KIDOZ and SuperAwesome to serve ads in our apps. These networks are restricted from tracking users and serving behavioural ads. We also work with IronSource, Vungle, Applovin, InMobi and AdColony. These networks are part of the Google Play certified ad network program. These networks are restricted from tracking users and serving behavioural ads. For more information about this program please visit the Google Play website: https://play.google.com/about/monetization-ads/ad-network/.
- KIDOZ Privacy Policy: http://kidoz.net/website-and-kidoz-sdk-privacy-policy
- Chartboost Privacy Policy: https://answers.chartboost.com/en-us/articles/200780269
- Super Awesome Privacy Policy: https://www.superawesome.tv/privacy-policy
- AdMob (Google) Privacy Policy: https://policies.google.com/privacy?hl=en
- IronSource Privacy Policy: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
- Liftoff Privacy Policy: https://liftoff.io/privacy-policy/
- Applovin Privacy Policy: https://www.applovin.com/privacy/
- InMobi Privacy Policy: https://www.inmobi.com/privacy-policy
- Google Analytics Privacy Policy: https://policies.google.com/privacy
- Unity Analytics Privacy Policy: https://unity3d.com/legal/privacy-policy
- Firebase Privacy Policy: https://firebase.google.com/support/privacy
- Singular Privacy Policy: https://www.singular.net/coppa-privacy-notice/
We work with analytics provider Google Analytics to help us understand your use of the apps. The restricted feature set is used.
Our apps are built with Unity and use the Unity In-App Purchases service which requires Unity Analytics to run. Unity Analytics does not share user data.
We use Firebase analytics and attribution to track installs, in-app purchases and the number of ads watched. Firebase does not collect any personal information to provide us with this information.
We use Singular as an attribution service provider to help us maximize the effectiveness of our ad campaigns. Singular does not share any personal information with any other third parties.
For further information on these providers see section 10 above.
Links
We may include links to third parties from the website or services. Tulu isn’t responsible for these companies and because we have a link doesn’t mean we endorse them. Your use of our services may be subject to the terms and conditions and privacy policies of other services that we don’t control such as mobile app stores, mobile software platforms or payment processors. Please be sure to check their privacy policies if you decide to visit them.
If you or your child would like to review or delete information, please contact us at:
Tulu LIMITED
Jimei District, Xiamen City, Fujian Province
Email: [email protected]
For more information on your rights, please see Section 15 of this Privacy policy.
Party Popteenies and Candylocks are trademarks of Spin Master Ltd., used under license. © Spin Master Ltd. All rights reserved.
We will only store your Personal Data to the extent required by the purposes of this Privacy Policy and to meet any legal, accounting or reporting requirements.
In order to determine the appropriate period of Personal Data storage, we will assess the amount, nature and sensitivity of Personal Data, the potential risk of harm resulting from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve these objectives by other means and applicable legal requirements.
Please note that you may request to delete your data by emailing us at: [email protected].
Your data is stored on rented and properly protected servers based in Lithuania, operated by “Interneto vizija”, UAB (see their Privacy Policy).
Our service providers and partners operate globally. This means that when we collect your Personal Data, we can process it in any other country. Nevertheless, we will ensure that appropriate measures are taken to protect your Personal Data as described in this Privacy Policy: this means that all our service providers and partners must process their Personal Data in such a way as to comply with the European Union's General Data Protection Regulation and other applicable laws.
You have these Personal Data protection rights:
- You have the right to request access to your Personal Data. This allows you to obtain a copy of your Personal Data.
- You have the right to request the change of Personal Data that we have about you. This allows you to correct any incomplete or inaccurate data that we have.
- You have the right to request the deletion of your Personal Data. This allows you to request that we erase or remove your Personal Data.
- You have the right to restrict or suppress processing of your Personal Data where you have a particular reason for wanting restriction. This means that you can limit the way that we use your data in certain circumstances.
- You have the right to object to processing of your Personal Data where we are relying on legal basis of legitimate interests. This allows you to ask to stop processing your Personal Data in certain circumstances.
- You have the right to cancel the consent to process your Personal Data at any time when we process your data because you have given the consent.
- You have the right to appeal our actions to the Personal Data protection authority regarding the collection and use of Personal Data. For more information, contact your local data protection authority.
If you want to exercise all of the abovementioned rights, contact us at [email protected].
You can contact us at any time with any of your Personal Data protection issues at:
Tulu LIMITED
Jimei District, Xiamen City, Fujian Province
Email: [email protected]
We will respond to all your requests within the shortest possible time.
- You have the right to request access to your Personal Data. This allows you to obtain a copy of your Personal Data.
- You have the right to request the change of Personal Data that we have about you. This allows you to correct any incomplete or inaccurate data that we have.
- You have the right to request the deletion of your Personal Data. This allows you to request that we erase or remove your Personal Data.
- You have the right to restrict or suppress processing of your Personal Data where you have a particular reason for wanting restriction. This means that you can limit the way that we use your data in certain circumstances.
- You have the right to object to processing of your Personal Data where we are relying on legal basis of legitimate interests. This allows you to ask to stop processing your Personal Data in certain circumstances.
- You have the right to cancel the consent to process your Personal Data at any time when we process your data because you have given the consent.
- You have the right to appeal our actions to the Personal Data protection authority regarding the collection and use of Personal Data. For more information, contact your local data protection authority.
If you want to exercise all of the abovementioned rights, contact us at [email protected].