Privacy Policy

Aldoo Ltd. updated June 2021

Aldoo Ltd., a company duly incorporated under the laws of the United Kingdom, registered with the Companies House under company No. 12755836, with registered office address at:  The Archive Centre Honeywood Road, Whitfield, Dover, Kent, United Kingdom, CT16 3EH (“ Aldoо ”, the “ Company ”, “ we ”, “ us ”, “ our ” or as the case may be), is committed to protecting t he privacy and security of our online visitors.   We are extremely sensitive to family concerns about their children’s personal information and safety while using our mobile game applications (the “ App/s ”). We want you to know about and understand the measures we have taken to keep the Apps brought by us safe and secure environment for everyone.

This Privacy Policy (the “ Policy ”) is an integral part of the Terms of Service (the “ Terms ”) which are available on our website https://aldoo.co.uk/terms-of-use  and on our Apps. All capitalized terms have the meaning given to them in the Terms, unless otherwise stated herein.

PERSONAL DATA

What is Personal Data

Personal Data is any information that relates to an identified or an identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

Personal Data We May Collect

Information that you provide to us

  • When you decide to contact us through our Contact form you provide us:
  1. Name;
  2. E-mail address; and
  3. Any other information that you may decide to share with us.
  • When you give consent/approval for use of the Apps by minors (users aged 16 or below, 13 and below for U.S. residents)
  1. Name of parent/ guardian
  2. Contact details of parent/ guardian (e-mail address)
  • Payment information

While we do not collect and store any financial information when you decide to take advantage of any of our in-app purchases, your App Store Provider is using this information. For further details, please refer to the Privacy Policy of your App Store Provider, such as Apple App Store

Information that we collect from third parties

We may receive information about you from other sources. We can add this information to the information we have already collected from you through our Apps to improve them.

Usually, the Personal Data collected by third parties is personally identifiable information such as: IP address, identifiers for advertisers and device identifiers, etc. This information is always anonymized .

Links to the privacy policies of third-party service providers used by the Apps:  

Apple App Store  

Unity Analytics

Firebase for Google Analytics

Users aged 16 or under

If you are aged 16 or under (13 for U.S. residents or other age depending on the age requirements of your national law), please speak to your parent/guardian to get their permission before you provide any Personal Data to Aldoo because without this consent, you are not allowed to provide us with Personal Data. We may also ask for your parent/guardian’s contact details so that we can check they are happy for you to use Aldoo’s Apps and/or services.

If Aldoo determines  that it has inadvertently gathered Personal Data from users under the age of 13 (for U.S. users) or 16 (as the case might be), without parent/guardian consent/approval Aldoo will  promptly delete any and all such Personal Data from Aldoo's records.

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

  • browser and device information, carrier, internet connectivity
  • server log file information and application usage logs
  • information collected through cookies, pixel tags and other technologies
  • demographic information and other information provided by you
  • location information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

FOR WHAT PURPOSES WE USE YOUR PERSONAL DATA AND ON WHAT GROUNDS

To the extent permitted by applicable law, we may use Personal Data for:

  • providing the functionalities of our Apps to your benefit and fulfilling your requests,  this may include: to complete your transactions, to send administrative information to you, such as information regarding the Apps and changes to our terms, conditions and policies.

The processing of your data for these purposes is in most cases necessary for managing our contractual relationship. Additionally, the implementation of these purposes requires processing under applicable law, including tax and accounting legislation.

  • accomplishing our business purposes

For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Apps, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We base these activities on our legitimate business interests by always ensuring that your fundamental rights and freedoms are unaffected.

  • for direct marketing

We require your prior consent to send you different marketing messages, e. g. newsletters, surveys. You can change your mind and withdraw your consent at any time by:

  • Using the "Unsubscribe" link in the messages you receive from us; or by
  • contacting us using the contact details below.

We base these activities on your consent.

  • Allowing you to participate in sweepstakes, contests and similar promotions

We may offer you the opportunity to participate in sweepstakes, contests and similar promotions. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Data.

We engage in these activities to manage our contractual relationship with you.

On our Application we can process information using cookies and similar technologies under the Cookie Policy below.

FOR HOW LONG WE STORE YOUR PERSONAL DATA

We keep your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide our services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). As a general rule, your data is stored for as long as you continue to play our Apps, unless a shorter period is applicable.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Data ( e.g. , information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Apps or otherwise to us.

HOW PERSONAL DATA MAY BE DISCLOSED

To the extent permitted by applicable law, your Personal Data may be disclosed:

  • to our third-party service providers who provide services such as data analysis, infrastructure provision, IT services, email delivery services and other services, to enable them to provide their services;
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

USER’S RIGHTS

Access to your Personal Data

You have the right to view, amend, or delete the Personal Data that we hold about you. To request access please email privacy@aldoo.co.uk.

We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.

Rectification of Personal Data

If any of the information we hold on you is inaccurate or incomplete, you may ask us to correct or complete it at any time.

Your right of erasure, or to be forgotten

 (for individuals within the European Economic Area (EEA) and the State of California)

You may ask us to delete your Personal Data, but only if:

- it is no longer necessary for the purposes for which it was collected; or

- you have withdrawn your consent (if the processing of the data is based solely on consent); or

- exercise a legitimate right of objection; or

- it has been unlawfully processed; or

- there is a legal obligation in this respect.

We have no obligation to honor your request for deletion of your Personal Data if processing is required:

- to fulfill a legal obligation; or

- to establish, exercise or protect a legal claim.

There are certain other circumstances in which we are not obliged to comply with your request for data deletion, even though these are the most likely circumstances in which we may decline your claim.

To request deletion of your personal information, contact privacy@aldoo.co.uk   using the email address we hold for you or otherwise proving your identity.

Please be aware that the process of deleting data and deleting the Apps with all data and documents associated with it is an irreversible process.

Restrict data processing

You may ask us to restrict the processing of your Personal Data, but only if:

- its accuracy is being challenged (see Rectification of Personal Data section) to be able to verify its accuracy; or

- processing is illegal, but you do not want the data to be deleted; or

- it is no longer necessary for the purposes for which it was collected, but we still need to identify, exercise or defend a legal claim; or

- you have already exercised the right of objection and you are checking whether the dominance of our rights is still in place.

We may continue to use your Personal Data as a result of a restriction request:

- if we have your consent; or

- to establish, exercise or defend a legal claim; or

- to protect the rights of the Site Owner or any other person or entity.

Data portability  (for individuals within the EEA)

You may ask us to provide your Personal Data in a structured, widely used and machine-readable format, or you may request that it is directly transferred to another data operator, but only if:

- the processing is based on your agreement or the conclusion of a contract with you; and

- processing is carried out automatically.

Right of objection

You may object at any time, for reasons related to your particular situation, to the processing of your Personal Data based on our legitimate interests if you believe that your fundamental rights and freedoms dominate these interests.

You may also object at any time to processing your data for direct marketing purposes by following the instructions on the email we send you or by sending an email to privacy@aldoo.co.uk.

Making automated decisions

Aldoo does not conduct profiling or automated individual decision-making.

Your right to file a complaint with the Supervisory Body

If you believe that Aldoo processes your personal data in the wrong way, you can contact privacy@aldoo.co.uk.

If you are located in the EEA, you have the right to complain to your jurisdiction’s local authority on the processing of your Personal Data.

DATA SECURITY METHODS

We follow generally accepted industry standards and internal procedures to protect Personal Data submitted to us, both during transmission and once we receive it.

The Data is encrypted and password protected and we have integrated commercially reasonable efforts to assure that your Personal Data remains secure when maintained by us, but please be aware that no security measures are perfect or impenetrable. If you have any questions about the security  of our mobile applications, you can contact us at   privacy@aldoo.co.uk.

We have implemented and shall maintain appropriate technical and organizational security measures to protect Personal Data and to preserve the security and confidentiality.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Apps link. The inclusion of a link on the Apps does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to these or other organizations.

We use the information we collect with the help of our analytics providers (Google Analytics and Unity Analytics) to constantly improve our Apps and make them better for you . We chose our providers carefully and request their compliance with valid legislation.

We and our analytics providers use Other Information and personally identifiable information to understand and optimize how our Apps are used, improve our marketing efforts, provide our content and features that are of interest to you, for statistics, analytics, research and development in order to continuously improve our apps and make them better for you. This includes correcting technical malfunctions, customization, providing better and improved content, developing new offers, measuring traffic and usage of our apps, promoting the apps and improving the user experience. We use aggregated and anonymized data log files and the activities of the user within our Apps for internal analytics to improve our Apps.

We also use your information to permit certain functionalities available within the Apps (such as in-app purchases), and send you local notifications to your device. We will only use local notifications to remind you about your activities within the App.

In-App purchases:  Our Apps enable in-app purchases. In order to make a purchase from us, you must use our third party checkout options to finalize and pay for your order. In-app purchases may be made only upon entering the app store password and you are responsible for maintaining the security of such password. Your authentication and security maintaining is subject to specific terms of the app store and the OS of your mobile device. You should be aware of the iOS’ 15-minute window after the downloading of an App, during which in-app purchases may be made without inserting an in-app store password.

Advertising Providers:  We do not show ads within our Services .

TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

We do not share your Personal Data with third parties, unless it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your Personal Data to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

In th e  event  of transfer , we will ensure that the recipient of your P ersonal D ata offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.

For EU residents: We have implemented safeguards to ensure an adequate level of data protection where your P ersonal D ata is transferred to countries outside the EEA.

For further details on the transfer of your P ersonal Dat a, including a list of the organizations with whom said information may be shared, please reach out to our team at privacy@aldoo.co.uk.

OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN

Our Apps comply with the Children’s Online Privacy Protection Act (“

COPPA

”). We don’t knowingly collect personal information from children under the age of 13, and if in the event that a user identifies himself or herself as a child under the age of 13 through a support request or through any feedback, we will not collect, store or use, and will delete in a secure manner, any personal information of such user, unless a prior consent for such processing is given by the child’s parent/guardian.

We do not make Personal Data collected from children publicly available nor do we enable children to so on our Apps. We will not condition a child’s participation in any activity or service on the disclosure o f  more personal information than is reasonably necessary to participate in the activity.

Parents/guardians may contact us at privacy@aldoo.co.uk   to review, update or delete any of their children’s Personal Data that we may have collected and to elect for us not to collect any additional personal information from their children.

ADDITIONAL INFORMATION FOR CANADA RESIDENTS

Personal data (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“ PIPEDA ”)) will be collected, stored, used and/or processed by Aldoo in compliance with Aldoo’s obligations under PIPEDA.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section provides information for California residents in connection with the California Consumer Privacy Act (“ CCPA ”).  Under CCPA, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident or household and includes the categories listed below.  This section does not expand upon our practices with respect to our collection of Personal Information (Personal Data) from children, as described above in section entitled “Our Collection of Personal Information from Children”  This section may, however, give children who are residents of California (and their parents or guardians) additional rights.

The following sections provide details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months:

Categories of Personal Information Collected:  The categories of Personal Information collected are listed in sections “Personal Data We May Collect” ana “Other Information” above.  

Sources of Personal Information :  We may collect this Personal Information directly from California residents themselves, as well as from third-party sources, public databases, and joint marketing partners.

Purposes :  We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to otherwise accomplish our business purposes and objectives.  Our business purposes and objectives include, for example, providing our products and services; developing, improving, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research and data analysis; undertaking quality assurance measures; conducting risk and security control and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.

Disclosures of Personal Information: The Personal Information may be disclosed to our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services. The Personal Information of users aged 16 or below (13 for U.S. residents) may be disclosed to our Analytic Providers.

Other Uses and Disclosures: We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • to comply with applicable law and regulations. This can include laws outside your country of residence.
  • To cooperate with public and government authorities. To respond to a request or to provide information we believe is important. These can include authorities outside your country of residence.
  • To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons. To enforce our terms and conditions, or to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
  • In connection with a sale or business transaction. We have a legitimate interest in using, disclosing, or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
  • Sales of Personal Information.  We have not sold Personal Information.  For purposes of this CCPA Notice, “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.  

 If you are a California consumer, you have the following rights:

  • Right to Know .  You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
  • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • The specific pieces of Personal Information we collected about you;
  • The business or commercial purpose for collecting Personal Information about you; and
  • The categories of Personal Information about you that we disclosed and the categories of third parties to whom we disclosed such Personal Information.
  • Right to Request Deletion .  You have the right to request that we delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us at privacy@aldoo.co.uk.

  In some instances, we may decline to honor your request where, for example, we are unable to verify your request or where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.  

  • Right to be Free from Discrimination.   You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

How you can access, change or suppress your Personal Information

If you would like to request to review, correct, update, suppress or delete Personal Information, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

COOKIES POLICY

What are cookies?

Cookies are small text files that are stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way.  They can do this because websites can read and write these files, enabling them to recognize you and remember important information that will make your use of a website more convenient (for example by remembering preference settings).

At the moment, Aldoo does not use cookies at its Services. You shall be informed if cookies are implemented into our Services.

DATA CONTROLLER

Where we collect Personal Data directly from the data subjects, such as our users or our users parents/guardians, and make decisions in regards to processing such Personal Data, we act as the data controller.

Data controller information:

Aldoo Ltd., a company duly incorporated under the laws of the United Kingdom, registered with the Companies House under company No. 12755836, with registered office address at:  The Archive Centre Honeywood Road, Whitfield, Dover, Kent, United Kingdom, CT16 3EH.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on https://aldoo.co.uk/privacy-kids

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at:

privacy@aldoo.co.uk

Because email communications are not always secure, please do not include sensitive information in your emails to us.