Tornet Privacy Policy
Tornet, an entertainment company specializing in the publishing of mobile games and applications, is committed to safeguarding your privacy. This policy aims to provide you with a clear understanding of how and why we collect and process your data when you use our applications or visit our website. This privacy policy outlines the fundamental principles that govern our data collection and processing for two primary purposes: (i) the development, publication, and monetization of mobile games and applications ("Tornet"), and (ii) the operation of our corporate website ("Tornet").
Tornet Apps and Games
Why does Tornet collect data from its apps and games?
When you use Tornet Apps and Games, we gather information about you. This information, often
referred to as "personal data," can be collected automatically by Tornet when necessary or
voluntarily submitted by you. We utilize this data to provide you with the app or game you've
downloaded, ensure your safety, and for various purposes described below, including advertising,
as elaborated in the "More Details" section.
When you install and use Tornet Apps and Games, we may collect and process your data for various
legitimate purposes. The following explanations outline the reasons for data collection and the
legal bases upon which we rely for each case:
Tornet collects data:
- To provide you with the services you requested (e.g., enabling access to the next level once the first level is completed).
- Legal basis: Tornet's legitimate interest – this data processing is essential for the requested service.
- To conduct analytics and gain insights into user interactions with our products and services to enhance them, either directly or through third-party partners.
Legal basis for third-party analytics: Express consent. In countries where collecting user
consent is required by applicable laws, Tornet shares personal data collected through its apps
with third-party partners for analytics only when you express your consent through a pop-up
notice included in our apps.
Legal basis for first-party analytics: Legitimate interest. Tornet collects user data for its
internal analytics tools, solely for the purpose of Tornet's analytics, and does not share this
data with third parties.
To deliver personalized advertising that aligns with users' preferences and interests, allowing
Tornet to continue offering free services and products.
Legal basis: Express consent. In countries where user consent is necessary, Tornet processes or
shares personal data collected through its apps for personalized advertising after receiving
your consent through a pop-up notice in our apps.
For all data processing activities requiring user consent, you have the option to withdraw your
consent at any time via the "settings" page in our various applications. Please note that if you
withdraw your consent or decline to give it initially, you will still receive advertising, but
it may be less tailored to your interests.
What data does Tornet collect from its apps and games?
Tornet does not collect data that enables us to directly identify you. We only collect mobile identifiers and other technical information (with your consent if necessary) to recognize your device. For the purposes mentioned above, the data collected by Tornet is limited to:
- The apps you are using
- Your IP address
- Your Mobile Advertising ID (e.g., Apple IDFA or Google AAID, which are technical identifiers developed by mobile operating systems for advertising purposes and can be reset or erased via your device settings)
- Information about your device and its connection (e.g., user agent, connection type, timestamp, system language, device model, screen resolution, battery level, available storage space, time zone, OS)
- Data related to your activities within our applications and how you interact with them, as well as the advertising displayed in our applications (e.g., number of ads served, potential clicks).
In some of Tornet's Apps and Games, you may choose to log in to your account using a third-party service (such as Google or Apple) to enhance your experience. In such cases, we may securely store your email address (in hashed format) within our database for account recovery and customer support purposes only. We will not share your hashed email with any third parties.
With whom may your data be shared and why?
We do not sell your personal information. However, we may share it with third parties to deliver the best possible service. Rest assured that these third parties are held to the same standards of care as Tornet.
Security and Other Important Information Children's Data
Tornet never knowingly or intentionally collects any personal data from children under 16 years of age. If you are under 16, please refrain from using Tornet Apps and Games.
What Rights Do You Have?
Your personal information belongs to you, and we are committed to respecting your rights. You
can contact us at any time at tornetstudios@tornet.co to request a copy of your data, withdraw
your consent, or request the deletion of information we hold on your behalf.
Consent Withdrawal and Opt-Out of Sale of Information
You can change your consent status at any time through the Privacy Settings available in Tornet
mobile games and applications. Please note that while Tornet does not sell your personal
information, we may share it with third parties like analytics and advertising companies to
enhance and personalize your experience.
Adjusting your consent settings within Tornet apps and games allows you to block data collection
for these purposes, preventing the sharing of information with our analytics and/or advertising
partners.
Access Right
Upon request, Tornet will provide you with information about whether we hold any of your personal information. You can access or request the deletion of your personal information directly in Tornet mobile apps or by contacting Tornet's Data Protection Officer, as indicated in the "Contact" section below. We will respond to your request within a reasonable timeframe.
Rectification and Erasure
You have the right to request the rectification of inaccurate personal data concerning you and the completion of incomplete personal data. You may also request Tornet to erase your personal data when it is no longer necessary for us to retain such data. To erase or render your data inaccessible, you can either:
- Reset your mobile advertising identifier (IDFA on iOS, GAID on Android) or activate "Limit Ad Tracking" in your device's settings to make previously collected data non-linkable to you or your device, limiting further data collection if you enable the "Limit Ad Tracking" option.
- Contact Tornet's Data Protection Officer, as indicated in the "Contact" section below, to have the data previously collected by Tornet on you and/or your device permanently erased or anonymized.
Portability
Upon request, Tornet will provide you with the personal data you provided to us, and, if possible, we 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.
Contact
Email: tornetstudios@tornet.co
Tornet Company – 7th Floor, Erbil Media City Massif Road 44001 Erbil - IRAQ