Effective Date: May 13, 2020
Top Tier Club is the data controller for personal information collected from its users.
In compliance with the EU General Data Protection Regulation (“GDPR”), we have appointed www.toptier.club as our representative for GDPR purposes in the EU. Users who are residents in the EU may address questions relating to the way we collect, store, use and disclose their personal information to Top Tier Club at the address identified below.
For users not located in the EU
When signing up for the Service, you are invited to agree with this Policy and the processing of your data, including your personal information, also called personal data in some jurisdictions (we refer to this information/data collectively as “personal information” throughout this Policy), in the manner provided in this Policy and our Terms and Conditions. We, therefore, process your personal information based on your consent. In any event, any use of the Service will be construed as your consent to this Policy. You are free not to use the Service.
Specifically for users located in the EU, UK or Brazil
This Policy is merely informative about how TTC collects, stores uses, and discloses your personal information. We are not asking you to consent to this Policy. If we require your consent we will ask for it in separate notice and consent forms. Please note that if you provide us with consent, you have the right to withdraw this consent at any time by contacting us at [email protected]
It is advised that you review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).
We collect information about you directly from you, from third parties, and automatically through your use of our Service. We may combine the information that we collect about you from these various sources.
Information we collect directly from you
We will also collect any information or categories of information that you provide to us through your use of our Service from the sources identified below. The types of personal information we collect may vary depending on your activity. Personal information may include identifiers such as:
User identification number;
When you pay for products offered for purchase through the Service, we will also collect payment information, such as your billing address and complete credit card information that enables us to receive your payment and commercial information about your transactions with us. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Service without having to re-enter it each time. We do not directly access or store your credit card information and we will not use the payment information we collect except as needed to fulfill your purchase and/or communicate with you regarding your transaction.
If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.
Additionally, we may acquire information from you through your access and participation in message boards on the Service. This information may include posts, comments, photos or screenshots, videos, ratings, and in-game messages. If you post content to our Service, such information may be available to other users of our Service (e.g., in-game messages will be available to the recipient of your message and if you upload a profile picture, your image may be available to all other users of our Service). If you post your own content on our Service, your posting may become public and TTC cannot prevent such information from being used in a manner that may violate this Policy, our Terms, and Conditions, the law, or your personal privacy.
Information we collect about you from third parties
When you install any of the Services, we may collect and record the information you provide us voluntarily through a social networking website in accordance with their policies and terms.
If you log into our Service using Facebook, you must enter your Facebook email address and password. We will ask that you grant us permission to access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address) even if you have chosen not to make that information public. We also will access and collect any information you have set to public on your Facebook account.
If you log into our Service using Google, you must enter your Google email address and password. By logging in through Google, you are granting us access to your Google profile information, which may include your name, location, email, birthday, and any demographic data.
You may also be able to log into our Service using other third-party services, such as Mail.ru. We encourage you to read the privacy policies of third-party platforms that you use to log into your gaming accounts to understand how those third parties use and disclose your information. We have no control over how any third-party site uses or discloses the personal information it collects about you.
Information we collect automatically about your use of our Service
When you use the Service, we may record information regarding the use of the Service, including about your internet or other electronic network activity, and we may collect other information that is visible on your social network page in accordance with the relevant Terms and Conditions associated with that page.
The Service will also record gameplay information such as your high scores or game session duration. When you invite new members into your network on the Service or send messages through the Service, we collect and maintain the information associated with those messages, including email address and content.
If you use the Service on your mobile telephone or other mobile devices, including iPads and tablets, we collect mobile device identifiers, including Media Access Control (MAC) address, and possibly IP address. In certain games, we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, general location (based on your Internet Protocol (“IP”) address) or e-mail address. This information is useful to us for troubleshooting and helps us understand usage trends.
Except as described in this Policy, we will not share this information with any third party. If you no longer wish to allow us to track or use this information, you may turn it off at the device level. Please note that the application may not work properly if we are unable to tell where you are coming from (country-specific).
In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your account information to track the TTC games you are playing.
Please see the Cookies section below for more information about the information we automatically collect about you.
Some of the information you give us when you register to play our games is open to the public, such as your profile picture, number of friends, your username, the list of games that you play, and the date of your registration. Should you wish to hide any of the information that is made public, you can do so by changing the settings to “only me” in the privacy settings tab of your profile.
We need the above personal information for the purposes as described in this Policy, and not providing certain information will have an impact on our ability to provide you with the Service. TTC’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. This includes sending you electronic communications related to the Service, from which you can unsubscribe at any time using the instructions in such communications. In addition, we may use user information for the following purposes:
Providing and improving our Services. To facilitate payments and communications between users; to provide and maintain the Service; to improve the Service; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; to validate our users and ensure their qualifications to use the Service and for other customer service and support purposes.
Marketing and communications. To communicate with you, including via email or push notification, about your account and use of the Service, including sending Service and product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. For more information about opting out of certain communications, please see the “Your rights and choices in relation to your personal information” section below.
Research and analytics. To analyze how you interact with the Service; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Protecting rights and interests. To protect the safety, rights, property, or security of TTC, the Service, any third party, or the general public; to detect, prevent or otherwise address fraud, security or technical issues; to prevent or stop the activity which TTC, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to enforce this Policy and our Terms and Conditions.
Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal processes; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
Specifically for our users who reside in the EU, UK, or Brazil, we rely on the following legal bases for the collection and use of your information:
to provide you with the service you request, pursuant to our Terms and Conditions.
Based on our legitimate business interest, and subject to your right of objection, to: (i) improve our services and your gaming experience, (ii) ensure the security of our games, (iii) send you newsletters, marketing emails, and push notifications with the latest information on our products and company as well as other advertising for our products, (iv) to protect our rights and property, enforce our Terms and Conditions and legal notices and for the establishment, exercise and defense of legal claims, and (v) to conclude corporate transactions (e.g., corporate restructuring, sale or assignment of assets, merger); (vi) share your information with third-party marketplaces and service providers for adverting purposes.
to comply with our legal obligations, any court order, or binding decision;
Cookies and Other Data Collection Tools
We may also employ web beacons or other technologies for a variety of reasons such as: (i) allowing us to know if a certain page was visited or whether an email was opened; and (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.
Do not track disclosure
Our Service does not respond to Do Not Track signals. You also may opt-out of certain interest-based advertising by following the instructions in the “Your rights and choices in relation to your personal information” section below.
Third party services
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
TTC uses a tool called “Google Analytics” to collect information about the use of this Service. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. TTC uses the information it gets from Google Analytics to understand Service usage and patterns and to improve its Service. Google Analytics collects only the IP address assigned to you on the date you visit a Service, rather than your name or other identifying information. TTC does not combine the information collected through the use of Google Analytics with other personal information.
Adjust And Other Similar Affiliates
Sharing of information with third parties
We will share your information with other TTC users to provide our Services. For example, if you post a profile picture, that picture may be available to all other users of our Services.
We also may share your information with third parties as required by legal or regulatory obligations; as requested by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; or as TTC otherwise deems necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to TTC or others.
We may share the categories of information listed above with third-party companies that perform services on our behalf, including payment processing, order fulfillment, data analysis, marketing services, email campaigns, hosting services, and customer service. While providing the services for us, these companies may access your personal information and are required to use it solely as directed by us for the purpose of our requested service.
In conjunction with the running of our games, we may partner with a third party to assist us in providing you with our Service. We will share the information you provide us through your social network, such as (1) your first and last name; (2) your profile picture or its URL; (3) your user identification number of the pertinent social network, which is linked to publicly available information such as name and profile picture; (4) the login email you provide to the pertinent social network upon registration; and (5) gameplay information with these third parties so they may facilitate the use of our Service as well as contact you about other games which may be of interest to you, service notifications and to solicit your feedback and input. If you do not wish to have this information shared please do not use our Service. If you wish to no longer have your personal information used by such partners you may contact us at [email protected] and we will facilitate your request to the partner.
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
We may use and share with third-party advertisers (and other third parties) certain technical and personal information and may allow advertisers to collect technical and personal information, which they may share with us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end-user activity to improve your experience). Please see your rights and choices in relation to your personal information section below for more information about opting out of behavioral advertising.
Information about our users is an integral part of our business. We share your personal information only as described in this Policy. TTC does permit third parties to collect personal information through our Service and shares personal information with third parties for business purposes. These business purposes are described above and include providing advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). While we provide you the choices described above in the “Cookies” and “Third Party Services” sections, we do not treat these relationships as “sales” of personal information where that concept is relevant under applicable law. The information practices of these third parties are also not covered by this Policy.
We may transfer your personal data outside your country of residence, including possibly to countries that do not provide a level of data protection equivalent to your country of residence. We implement appropriate safeguards to protect the personal information that we transfer in accordance with applicable data protection requirements. Where required by law, we put in place standard contractual clauses to protect your personal information. You can ask for a copy of such standard contractual clauses by [email protected]
Specifically for our users resident in the EU or UK, please note that TTC is located in Israel, a country that is deemed to provide an adequate level of data protection according to the European Commission or UK Secretary of State, respectively. Where TTC onward transfers your personal information to a company located outside of Israel, the EU, or the UK, we will take steps to ensure that your information is given a similar level of protection as that given in Israel, the EU, or the UK. You have the right to request from us information about, including a copy of the contractual safeguards TTC put in place to achieve this.
Storage of your personal information
The personal information we collect, as described in this Policy, is being stored on servers in Serbia and available to our other services in China and the USA. You expressly agree with your personal information being stored and processed in those countries.
Specifically for our users who are residents in the EU, UK, and America, we are not asking you to consent to the storage of your information in the above-mentioned countries. Rather, we have put in place appropriate contractual safeguards to protect your personal information in compliance with applicable laws. As indicated above, you have a right to request information on those contractual safeguards.
We will keep your information as reasonably necessary for the purposes set out above in accordance with applicable law, generally no longer than 3 years from the date you stopped using our services.
We may keep your personal information for longer if required or permitted by applicable laws.
Protecting personal information
We strive to protect personal information while it is under our control. If you have an account with us, your account information is accessible online only through the use of a password. To help protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You acknowledge that you provide your personal information at your own risk. You are also responsible for all uses of the TTC games and applications by any person using your password. Please advise us immediately if you believe your password has been compromised or misused.
We have implemented technical, physical, managerial, and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, or disclosure. However, please note that no system or network is 100% secure and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes.
To protect your privacy and security, we may take reasonable measures (such as requiring a unique password) to verify your identity before permitting you access to your account or the Service. You are responsible to maintain the secrecy of your unique password and account information, and for controlling access to your email communication or interaction through the Site or TTC’s authorized social networking at all times.
Your rights and choices in relation to your personal information
Accessing, correcting, or deleting your personal information
TTC takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others’ privacy), you may have rights under applicable law to request information from us about the personal information we hold in relation to you and correct any inaccurate data we hold.
Furthermore, depending on where you live, you may also have the right to change or request that we delete any personal information about you, such as by changing the applicable information found in your TTC account. However, if you decide to delete or anonymize your personal information, you may no longer have access to certain content (e.g. information on your game progress) and your account may become deactivated.
In certain territories (including the EU, UK, and America), you also have a legal right to ask for a restriction of processing or to object to processing.
You may also have the right to withdraw your consent, on the basis of which we process your personal information, at any time, by closing your account or otherwise clearly indicating your withdrawal of consent. However, this does not affect our lawful processing based on your consent before this withdrawal.
Subject to applicable law, you also may have the right to request that we provide such information to you in a portable format, or to request additional information about how we collect or disclose your personal information.
The rights that you have are subject to conditions and may not always be applicable.
If you or an authorized agent wants to exercise any of these rights, please contact us at: [email protected] Subject to applicable law, you can freely exercise these rights and choices. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Once we receive your request from you, we may verify it through your account or by requesting information sufficient to confirm your identity.
Subject to applicable legal provisions, we may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Service you have requested or received from us.
We may occasionally send you push notifications through our mobile applications to send you game updates, high scores, and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
Users in the United States may opt-out of receiving interest-based advertising from many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Users in the European Union or the United Kingdom may go to the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt-out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt-out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or App or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). If your browser is configured to reject cookies when you opt-out on the DAA, NAI, and/or EDAA websites, your opt-out may not be effective. Please note that if you use multiple devices you will have to opt-out on each individual device.
Links to other websites or applications
Policy regarding children under the age of 13
TTC’s Services are generally designed for a general audience and are not directed to children under the age of 13. Through these Services, TTC does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to access those Services.
Through other Services, TTC may be more likely to collect some personal information about children under 13. For such Services, TTC will request users’ ages and, if a user indicates that s/he is under 13, TTC will only collect personal information, such as persistent identifiers (e.g., IP address and device information), necessary for internal operations of the Service, or as otherwise permitted by law. TTC will only use such information to support internal operations of the Service and not for other purposes except as consistent with applicable law.
If you are under 13, please do not attempt to register an account with any of the Services or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information other than persistent identifiers used to support internal operations of the Services, from a child under the age of 13, we will delete that information as quickly as possible. We recommend that minors under the age of 13 ask their parents or guardians for permission before sending any information about themselves to anyone over the Internet.
If you are between 13 and 16 years old, live in the European Union, United Kingdom, or America, and we ask for your consent, make sure that under your country’s data protection laws you are able to provide valid consent without authorization of your parents or guardian. We will verify your age and as the case may be and ask for parental/guardian consent.
Changes to this policy
TTC may amend this Policy from time to time. The use of the information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you, such as by posting an announcement on our Service or sending you an email. You are bound by any changes to the Policy when you use the Service after such changes have been first posted. If you object to any change, you may immediately terminate your account and cease using the Service.
Questions or concerns & contact details
If you have any questions or concerns regarding privacy at TTC, please contact us at email: [email protected]