Toupeti Studio is a mobile gaming studio, part of the Voodoo Group, an international entertainment company specialized in the publishing of mobile games and applications.

The purpose of this policy is to provide you with all the important information and explanations about how and why some of your data may be collected and processed by Toupeti Studio when you use one of our applications.. This privacy policy governs and details the main principles that Toupeti Studio applies to the data we collect and process to:

(i) develop, publish and monetize mobile games and applications (“Toupeti Studio Apps and Games”)

This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.

Should you have any questions related to this policy or our practices around privacy and data protection in general, please don’t hesitate to contact Toupeti Studio as indicated in the contact section of this policy.

Toupeti Studio apps and games

Why does Toupeti Studio collect data from its apps and games?

When you install and use Toupeti Studio mobile applications, we can collect and process some of your data for different legitimate purposes.

You will find below explanations regarding the reasons why Toupeti Studio may collect data and the legal bases Toupeti Studio relies on in each case.

Toupeti Studio collects data:

• To provide you with the services you asked for
  (e.g., knowing that you completed the first level to allow access to the second one)

• Legal basis – such data processing is strictly necessary for the service(s) asked

• To run analytics and understand how users interact with our product and services in order to continuously improve it either directly or through third party partners
  (e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)

• Legal basis for third party analytics - Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, Toupeti Studio only shares personal data collected through Toupeti Studio apps with third party partners that provide Toupeti Studio with analytics services once you express your consent through the pop-up notice included in our apps.
• Legal basis for first party analytics – Legitimate interest. Toupeti Studio collects user data for the purpose of its own internal analytics tools. Data is used for the sole purpose of Toupeti Studio analytics tool and is not shared with any third parties. This data processing is based on the legitimate interest of Toupeti Studio.

• To serve advertising tailored to the preference and interests of our users
  and allow Toupeti Studio to continue to provide free services and products

• Legal basis – Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, Toupeti Studio only processes or shares personal data collected through Toupeti Studio apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page, when available,  in our various applications

Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

What data does Toupeti Studio collect from its apps and games?

For all the purposes listed above the data that Toupeti Studio collect is limited to:

• The apps you are using
• Your IP address
• Your Mobile Advertising ID (Apple IDFA or Google AAID - which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings)
• Technical information about the device you use and your connection (user agent, type of connection, timestamp)
• Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

With whom may your data be shared & why?

Toupeti Studio does not share your personal data with third parties without your prior consent in the countries where collecting users’ consent may be required by applicable laws and regulations.

When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

• Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.

Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

• AdColony - https://www.adcolony.com/privacy-policy/
• AppLovin - https://www.applovin.com/privacy/
• Chartboost - https://answers.chartboost.com/en-us/articles/200780269
• Facebook - https://www.facebook.com/about/privacy
• Fyber - https://www.fyber.com/privacy-policy/
• Google AdMob - https://policies.google.com/privacy?hl=en 
• InMobi - https://www.inmobi.com/privacy-policy/
• IronSource - https://developers.ironsrc.com/ironsour ce-mobile/air/ironsource-mobile-privacy-policy/
• Mintegral - https://www.mintegral.com/en/privacy/
• Mopub - https://www.mopub.com/en/legal/privacy
• Ogury - https://ogury.com/privacy-policy/
• Pangle - https://www.pangleglobal.com/privacy
• Snap - https://snap.com/en-US/privacy/privacy-center
• Tapjoy - https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy
• Unity Ads - https://unity3d.com/legal/privacy-policy
• Verizon Media - https://www.verizonmedia.com/policies/xw/ en/verizonmedia/privacy/intl/index.html
• Vungle - https://vungle.com/privacy/
• Analytics companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:

• Adjust - https://www.adjust.com/terms/privacy-policy/
• GameAnalytics - https://policies.google.com/privacy
• Google Analytics - https://policies.google.com/privacy
• Mixpanel - https://mixpanel.com/legal/privacy-policy/
• Singular - https://www.singular.net/privacy-policy/
• Tenjin - https://www.tenjin.io/privacy/

• Authorities: only to the extent we are obliged to by applicable laws and regulations.

Security and other important information

How long does Toupeti Studio keep your data?

Personal data collected, received and processed for the purposes described in this policy is not kept longer than necessary by Toupeti Studio.

Toupeti Studio does not retain user level data for more than 13 months except for the data collected for the purpose of its first-party analytics tool which can be stored up to 25 months based on the guidelines of our Supervisory Data Protection Authority.

Children data

Toupeti Studio never knowingly or willingly collect any personal data concerning children under 16 years of age.

International transfers

Some of the partners and processors referred to in this policy are located outside of the European Union.

In such case, we ensure that:

• the personal data is transferred to countries recognized as offering an equivalent level of protection or,
• For personal data transferred outside of countries recognized by the European Commission as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and notably the adoption of the standard contractual clauses of the European Commission.

What rights do you have?

Consent withdrawal and opt-out of sale of information

You can change your consent status at any time from the Privacy Settings available in Toupeti Studio mobile games and applications, whenever available.

Please note that if Toupeti Studio does not sell the personal information of its users, we may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services.

Adjusting your consent settings within Toupeti Studio apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

Access right

Upon request, Toupeti Studio, through the Voodoo Group, will provide you with information about whether we hold any of your personal information..

Rectification and erasure

Through the Voodoo Group, you may request Toupeti Studio the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request Toupeti Studio to erase without undue delay your personal data when it is no longer necessary for Toupeti Studio to retain such data.

In order for your data to be erased or rendered inaccessible you can either:

• reset your mobile advertising identifier (IDFA on iOS, GAAID on Android) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
• contact Toupeti Studio Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by Toupeti Studio on you and/or your device permanently erased or anonymized

Portability

Upon request, through the Voodoo Group, Toupeti Studio will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract.

Right to lodge a complaint

You may lodge a complaint with a Data Protection Authority. Toupeti Studio being a French company, our supervisory authority is in France: CNIL www.cnil.fr

Contact

toupetipeti@gmail.com

Toupeti Studio - 320, rue Saint-Honoré, 75001 Paris, France.