Privacy Policy

Miguel Campillos (Torito Games) does not collect or process any data from your device or activity.

The mails collected via the subscription form are only used to inform you about game releases or major updates and are not shared with third parties.

If you want your mail removed from the mailing list, you can use the regular contact form to request it.

Torito Games partners with Chartboost for the advertising and monetization of games published in Google Play.

Chartboost will:

- Collect data from your device and behavior to display targeted ads (for example display of ads based on the game genre you are playing).

- This data is transfer to Chartboost in the US under the EU/US Privacy and Swiss-U.S. Shield Framework

- You can find regarding your rights on the data subject and how to manage them in section 9 of their Privacy Policy reproduced below, as in their Privacy Policy page.

- You have the right to withdraw your consent at any time

- You have the right to lodge a complaint with a supervisor authority

Further on this regard you can read below the Chartboost Privacy Policy or access this link to their own Privacy Policy page.

CHARTBOOST PRIVACY POLICY

updated July 16, 2019

OVERVIEW

This privacy policy (“Privacy Policy”) explains how information (both customer and end user information) is collected and utilized by Chartboost, Inc. and its subsidiaries and affiliated companies (“Chartboost”, “our”, or “we”). This Privacy Policy applies to the websites provided by Chartboost, including without limitation, www.Chartboost.com (the “Sites”) and Chartboost’s online services (“Online Services”). Our Online Services allow publishers of mobile applications to show ads on their applications, and advertisers to reach audiences that may be interested in their products or services. Although “You”, “your”, or “customer” refers to our customers and not to the end users of our customers’ services, we recognize the rights of end users and encourage end users to read this Privacy Policy to learn how we may process their personal data (Section 2) and what choices and rights they have (Sections 8 and 9). End users who have any concerns about this Privacy Policy may send an email to privacy@chartboost.com and we will try to address their concern. Any customer who does not agree to the contents of this Privacy Policy, should not provide us with any information and should not use the Online Services.

1. COLLECTION AND USE OF INFORMATION ABOUT YOU

Our primary goals in collecting and using information are to provide and improve the Online Services and the Sites, to administer and assist you with your Online Services account, and to provide you with a better experience with the Online Services. Information about you and your end users will be stored and processed by us in the United States. For more information about the transfer of your data to the United States, please refer to Section 5. The legal basis for the processing of your personal data is the performance of the agreement between you and Chartboost Inc, or, if you work for a customer, the legitimate interests Chartboost has in processing your data in order to provide the Online Services to your employer. In some instances, we may also rely on consent you have given for specific forms of processing. Registration: During the registration process on our Sites, you may be asked for certain information, which may include your name, your email address, the company for which you work, your country, and a password. This registration information is used to validate customers when they visit the Sites. It may also be used to send you additional promotional information about our services. You can opt out of receiving promotional emails at any time by using the link provided for this purpose in each email. If you were entered in a Chartboost promotion in connection with your registration, we will also use your name and email address to contact you if you have won a prize in that promotion, and will ask you for the address at which you would like to receive your prize. We store all data associated with your account, including your contact information, your applications and your campaigns. Contact/Content: On the Sites we may offer online forms to enable you to contact us. We may also offer you the opportunity to request specific content, like newsletters and whitepapers we publish. When we request your contact details (such as your name and email address), we may ask for your consent to use these to keep you informed about our Online Services in the future. Cookies and Beacons: A “cookie” is a small text file that contains a string of alphanumeric characters. There are two types of cookies that may be used at our Sites: persistent cookies and session cookies. A persistent cookie gets entered by your Web browser into the “Cookies” folder on your computer and remains in this “Cookies” folder after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Sites. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut off your computer. The Sites or the emails we send may also use Web beacons (also called “clear GIFs” or “pixel tags”) in conjunction with cookies. Web beacons are small strings of code that are placed in a Web page. If you have arrived at the Sites by clicking on a banner ad for one of our products or services, a session cookie may be used. This cookie will contain an identification number for the ad that you clicked on, or will contain an identification number for the Sites that you were visiting when you clicked on the banner ad. This session cookie helps Chartboost determine which of our ads attract the most visitors. If, after you arrive at our Sites, you choose to request further information from us about our products and services, the information that you provide in that request will be linked to the information in the session cookie. This also helps Chartboost measure the effectiveness of our advertising. Because this is a session cookie, it will disappear once you have closed your browser. Our Sites may use persistent cookies, Web beacons and information collected in our log files (such as Internet Protocol Address, referring URLs, etc.) about your activity at the Sites to better understand how the Sites are used, resolve technical problems, and enhance your experience at the Sites. We may use a third-party email technology to send emails that you have agreed to receive. Web beacons are used in those email messages to measure the effectiveness of our advertising. In addition, Chartboost may serve ads on the Sites using our own ad serving technology. In doing so, one of our ad servers will place or read a unique ad-serving cookie on your computer and will use information about your browser and your activity at the Sites. The ad serving cookie is a persistent cookie. We may also allow third parties to place cookies on our Sites to track your use of the site to enable us to analyze the traffic of our marketing pages. Examples of such providers of analytics services may include Google Analytics.

2. COLLECTION AND USE OF INFORMATION ABOUT YOUR END USERS

Online Services: When an ad is served through our Online Services, we may collect the following from your end users’ devices: bundle ID, language ID, operating system version, device model, software developer kit (SDK) version, unique device identifier, IP address, and Media Access Control (MAC) address. In addition, when an end user accesses a video ad, we may collect additional stats about videos and video playback such as: start/boot-up information, amount played/session length information, memory on device used for our video cache, videos cached on a device and complete view event. We identify an end user’s device using Chartboost’s internal device ID, which is linked to an end user’s Apple IDFA, Google Advertising ID (GAID), or Android ID, as applicable. If you use Chartboost’s Post-Install Tools, which include Post-Install Analytics, Publisher Segmentation and Retargeting, we may access and collect data such as the following: when an end user launches the app, how long the end user plays the app, and in-app events. We may use this information to provide you with an end user’s usage data, advertising campaign optimizations, and user re-targeting based on a user’s usage patterns. We also receive information about end users from advertisers or advertising services companies such as mobile device identifiers, geolocation, IP addresses, website cookie information and usage data. We combine the information we collect about end users with additional demographic, geolocation and interest-based segment data, along with cookie information, from third-party providers. The additional information we access and collect may determine the nature of the ad that the end user sees. The legal basis for the processing of personal data of your end users is the consent that you have obtained from the end users on behalf of Chartboost based on you obligation to do so as set out in the Terms & Conditions. If you do not want to expose your end users to behaviorally targeted advertising campaigns, you can choose to opt out of behavioral targeting by following the relevant instructions as set out on the Sites.

3. INFORMATION SHARING OR DISCLOSURE

In the event that we contract with a third party to provide some part of the Online Service or to assist us in analyzing our services or information collected about you and/or your end users, Chartboost may provide your information and/or your end users’ information to such third party, or such third party may collect information from you or the end users on our behalf. We may share your information and end user information with third parties with whom we have a strategic relationship, such as advertisers, demand side platforms, measurement/attribution companies, and advertising services companies. The information shared with these third parties may be used, among other things, for industry analysis, tracking ad conversions, cross-device matching, behavioral advertising or demographic profiling. We may also provide your information and end users’ information to our business partners or other trusted entities for the purpose of providing you with information on goods and services we believe will be of interest to you, provided that you have given your consent to this. We may be required to disclose information about you or end users in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and will disclose such information about you or end users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Chartboost or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. In addition, we may disclose information to third parties in connection with a corporate re-organization, bankruptcy, liquidation, merger or amalgamation, or the sale of all or substantially all of our assets. We may share information for other purposes if you direct us to do so or you consent to such sharing. Finally, we may share aggregate or anonymous information about you or end users with advertisers, publishers, business partners, sponsors, and other third parties. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Chartboost is potentially liable for such transfers.

4. PRIVACY PRACTICES OF CUSTOMERS AND THIRD PARTIES

In our Terms & Conditions, we require Chartboost customers to post a privacy policy, to obtain all required end user consents, and to comply with all applicable laws and self-regulatory guidelines, but we are not responsible for your privacy practices. To assist you in your compliance with your obligations under applicable law, our Privacy Policy contains information on the way Chartboost processes end user personal data. In particular, information given to the end users who are based in the EU or Switzerland at the time their consent is asked, should include the following:

the collection of their data by Chartboost as described in this Privacy Policy, including a link to this Privacy Policy;
that their data will be collected by Chartboost to show ads on your applications, including ads which are based on behavioral targeting (for example: ads for games which are similar to those which they have installed and played before);
the transfer of their data to Chartboost in the US under the EU/US Privacy and Swiss-U.S. Shield Framework;
their rights as data subjects, as described in Section 9;
their right to withdraw consent at any time;
their right to lodge a complaint with a supervisory authority.

End users should review your privacy policies. We also do not control and are not responsible for the privacy practices of any other third party, and any website or service that links to or from our Sites or the Online Services. This Privacy Policy applies solely to information collected by Chartboost.

5. TRANSFER ON THE BASIS OF THE EU/US-PRIVACY SHIELD FRAMEWORK

Chartboost has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles for the collection and processing of personal data from our customers and end users in the European Union [and Switzerland]. To learn more about the Privacy Shield program please visit www.privacyshield.gov. We are subject to the investigatory and enforcement powers of the FTC. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In compliance with the Privacy Shield Principles, Chartboost commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Chartboost at privacy@chartboost.com . Chartboost has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact Kathleen Pierz, JAMS Practice Development Manager, Global on 212.607.2771. You can also submit a form on https://www.jamsadr.com/eu-us-privacy-shield/. The services of are provided at no cost to you. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles. Because Chartboost complies with the Privacy Shield Principles, it is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission with respect to our adherence to Privacy Shield.

6. CONFIDENTIALITY AND SECURITY

While we cannot guarantee that loss, misuse or alteration to your data will not occur, we make good faith efforts to prevent such occurrences. We do not warrant or represent that your account or any of your information or end user information will be protected against, loss, misuse, or alteration by third parties.

7. COMMUNICATIONS

It is our policy to provide communications, whether such communications are required by law or are for marketing or other business related purposes, to our customers via e-mail notice, written or hard copy notice, or through posting of such notice on our Sites, as determined by us in our sole discretion. Notwithstanding the foregoing, we reserve the right to determine the form and means of providing notifications to our customers.

8. DO NOT TRACK AND END USER CHOICES

Because the Sites we operate do not collect or use the type of information that is generally subject to your browser’s “Do Not Track” (DNT) privacy preference, our websites do not look for this signal from your browser. Your DNT settings, however, may affect the third-party services we use. End users may control how their browser responds to cookies by adjusting the privacy and security settings of their web browser. An end user may opt out of interest-based advertisements by adjusting the settings on the end user’s mobile device. For iOS mobile devices, go to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on the device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” An end user can review http://www.networkadvertising.org/mobile-choices for more information regarding how a consumer may opt out via the mobile platform. If an end user would like to disable the collection of the end user’s mobile device geolocation information, the end user can make this selection on the end user’s device. To learn more about interest-based advertising, and to access the opt-outs of certain online advertising companies, visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/#completed or Digital Advertising Alliance (DAA) at http://www.aboutads.info/choices/.   We use the services of Drawbridge for cross-device matching. An end user can opt out of Drawbridge’s services, including cross-device matching, at: http://www.drawbridge.com/optout.  The end user should complete the opt-out process for all devices and browsers the end user uses. If an end user opts-out of targeted advertising, the end user will still receive general advertisements.

9. RIGHTS OF DATA SUBJECTS

Chartboost recognizes that any individual in the EU or Switzerland has the following rights in relation to their information:

The right to obtain, at reasonable intervals and free of charge, confirmation as to what personal data about them are processed by Chartboost
The right to object to processing of personal data about them for direct marketing purposes
The right to have personal data about them rectified, blocked or deleted if the data are incorrect, incomplete, irrelevant, outdated or processed unlawfully
The right to object to processing based on their particular situation
The right to receive the personal data about them which they have provided to Chartboost in a structured and commonly used format and to transmit those data to another controller

Some of your information can be changed or deleted by following the process provided in the Online Services Account, unless we must keep the information for legitimate business or legal reasons. If you delete certain of your information, your account may become deactivated. If you wish to make a request based on the above, please inform us by visiting answers.chartboost.com and going to the ‘Contact Us’ page. We may request evidence of your identity for verification purposes. We will respond to your request within the applicable statutory term. If an end user exercises any of their rights with you with respect to the processing of their information by us, please use the tools in the Online Services Account to accommodate their request, or, if this is not possible, please visit answers.chartboost.com and go to the ‘Contact Us’ page.

10. RETENTION PERIOD

Chartboost retains information about you and your end users for as long as necessary to fulfil the purposes for which we collected the data, except if required otherwise by law. We may store information for longer periods for archiving or statistical purposes in which case we will take appropriate measures to ensure that the information is used solely for this purpose.

11. COMPLAINTS

If you do not agree with this Privacy Policy or the way Chartboost processes information about you, you can also lodge a complaint to a competent supervisory authority in your country of residence. End users also have the right to lodge a complaint with the supervisory authority in their country of residence.

12. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time, at our sole discretion. Any such changes or modifications will be effective immediately upon posting. If we make any changes to this Policy, we will change the “Last Updated” date above.

13. CONTACTIf you have any questions or suggestions regarding this Privacy Policy, or have any concerns about privacy, please contact us at privacy@chartboost.com.