Tōka Games provides services which require provision of information. Protecting your privacy is

really important to us. We only use your information where we have a legal basis to do so. This

you have when you make use of our Apps, our websites, buy merchandise from us, or take part in

other services (the "Services").

You should also read our Terms of Service which set out the contract between you and Tōka Games.

1. Who decides how your information is used?

Tōka Games generally is the data controller responsible for making decisions about how we use your

personal information.

If you have any questions or comments on this policy, you can:

Email us at info@toka-games.com.

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you

("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous

Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfil the

promises we make to you in the Terms of Service:

When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for

example when you sign up for an account. We collect and use that information in order to

authenticate you when you register an account and use the Services, to make sure you are eligible

and able to receive the Services, and so that you receive the correct version of the Services. That

information includes your age, the in-game username you choose to use on our Services, and internal

account IDs that we assign to your account.

You must have an account with a supported external single sign-on service to use our Services. As

such, the Personal Data we collect also depends on which external accounts you choose to use, their

services to access our Services.

Depending on the particular Service you sign up for, we may support other external single sign-on

services and collect additional Personal Data from them.

Some external providers may notify you that they make additional information, such as your public

profile, available to us when you use their single sign-on services. We do not collect that information

from them.

We collect and use your device location information as you use our Services (and, if you elect to turn

on background location tracking for our Services, while you are not directly interacting with the

Services). Our Services include location based events, so we need to know where you are to operate

these for you, and to plan the location of in-app resources. We identify your location using a variety

of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell

tower triangulation.

We also collect and use your in-app actions and achievements, as well as certain information about

your mobile device (including device identifiers, device OS, model, configuration, settings and

information about third party applications or software installed on your device), to operate the

Services for you and to personalize your user experience.

We also use the information above to show in-app sponsored locations that are in your vicinity as

part of the user experience.

We further use the information above in order to provide technical and customer support to you.

You also give us Personal Data when you make a purchase through us, subscribe to our publications,

which of these Services you use, that may include your name, mailing address, phone number,

country of residency, age, and email address. We use that information to fulfil those Services to you

and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Using your IP address, browser type, operating system, the web page you were visiting

before accessing our Services, the pages of our Services which you browsed or the features

you used, and the time spent on those pages or features, the links on our Services that you

click on, device and advertising identifiers, age, as well as actions you take during gameplay,

your in-app user settings and preferences and your in-app purchases to understand who is

using our Services and how.

Using your contact information, namely your email address in order to communicate with

you to provide technical and customer support.

Using your internal account ID and in-app username, as well as a profile picture, in order to

attribute to your account any user content (such as local points of interest) that you elect to

submit to us through the Services. This account also allows you to recover previous

achievements and/or profile and other relevant data in the event of loss or change of the

(mobile) device you are operating the applications, which however can also be recovered – if

allowed by user – through back-up instances on the software of the device (e.g. cloud

storage services for Apple)

Using your email address and device information in order to share updates and news with

you either within the games or by email. You can unsubscribe from these at any time in your

device settings or in-app settings.

Analyzing your in-game actions and achievements to show you rewards, promotions, or

other offers about our Services that are tailored to your personal user experience. You can

choose to opt out of this and certain other processing of your Personal Data by following the

steps described in Section 7 below.

To personalize the ads you see in our apps to make them more relevant to you, and to show

sponsored gifts containings messages and/or offers from our advertisers relevant to your

vicinity on the game map. You can choose to opt out of receiving sponsored gifts by visiting

the in-app settings.

To provide social features within our games so you can interact and play with other players,

including storing your communications, content, and other information shared with those

players, finding your friends and being found by them (also when not using the application),

including through imported contacts and localisation (as described above), and sharing your

gameplay experience and achievements with your friends. You can visit your app profile in-

app settings for opt-out options.

Calculating scores and ranks, and creating leaderboards and achievement lists, where you

can compare your achievements and ranking with other users (referring only to the

nickname and profile picture of the user);

Using your in-game actions and achievements, as well as certain information about your

mobile device (including device identifiers, device OS, model, configuration, settings and

information about third party applications or software installed on your device), to carry out

anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of

Service, to ensure that we provide a fair gaming experience to all players.

To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.

We will only use your Personal Data to do the following if we have your consent:

If you elect to turn on background activity tracking in our Services we will collect your Personal Data

as you use the Services as well as in the background when you do not have the Services open on your

device.

If you elect to enable the Facebook User Friends permission available in some of our games, we will

import from your linked Facebook account the list of your friends who also play the game and

enabled Facebook User Friends. If you enable that permission, your Facebook profile picture and the

name on your Facebook account will be visible to your friends in-game. You can change your mind

and unfriend other players at any time from your in-app Friends settings. You can also revoke

Facebook permissions for our games directly from your Facebook account settings.

If you elect to add information about our app live or in-game events to your mobile calendar, we will,

with your permission, access your device’s calendar and write in these events. We do not access or

collect any other information from your calendar. You can change your mind and disable access to

your calendar at any time in your device settings.

If you elect to import your device’s address book contacts to find out which of your contacts uses our

Services and to send them Friend requests, or invite them to join you in our games or other aspects

of our Services, we will periodically sync your contacts’ information, including phone number and

email, to our servers. You are responsible for ensuring your collection and sharing with us of your

contacts’ information is compliant with applicable laws. This may require you to obtain your

contacts’ permission. We may also get information about you from other app users importing or

entering their contacts. We use and may store this contact information to help you and your contacts

connect through our Services. You can change your mind and turn off app access to your contacts at

any time in your device settings.

Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at

any time in your device settings or in-app settings.

We also rely on your consent where we use cookies or similar technologies. Insofar as cookies collect

Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a

pseudonym.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as

described below:

Information Shared with Our Service Providers. We engage external service providers to work with us

to administer and provide the Services (e.g. back4app.com). As part of that they will process your

Personal Data on our behalf. These external service providers have access to your Personal Data only

for the purpose of performing services on our behalf, in compliance with GDPR and other applicable

privacy law. The service providers we use help us to:

run, operate and maintain our Services through third party platform and software tools;

perform content moderation and crash analytics;

run email and mobile messaging campaigns;

perform user and marketing analytics;

to provide measurement services and target ads;

administer competitions, sweepstakes and promotions, including registering players,

managing check-in and attendance, verifying eligibility and prize fulfilment;

provide payment attribution;

provide technical and customer support; and

process payments for live events ticketing or other purchases.

Some external service providers may also collect information directly from you (for example, a

payment processor may request your billing and financial information) as a Third Party Service in

accordance with their own privacy policy. Such external service provider does not share your

financial information, like credit card number, with our apps, but it may share limited information

with us related to your purchase, like your zip or postal code.

Information Shared with Other Users. When you use the Services, we will share certain Personal Data

with other players. This Personal Data includes your in-app profile (such as your username, your

avatar, your online status), your in-app actions and achievements/rankings.

Information Shared Publicly: When you use the Services, use competitive features, the following

information about you may be shared on web pages accessible to the public and therefore become

publicly available: your username, in-app profile, achievements/rankings and public messages.

Information Shared with Third Parties. We share Anonymous Data with third parties for industry and

market analysis. We may share Personal Data with our third-party publishing partners for their direct

marketing purposes only if we have your express permission. We do not share Personal Data with

any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with

government and law enforcement officials or private parties to enforce and comply with the law. We

only share information about you to government or law enforcement officials or private parties when

we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including

subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and

safety of a third party or the public in general; and (c) to investigate and stop any activity that we

consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions. Information that we collect from

our users, including Personal Data, is a business asset. If we are acquired by a third party as a result

of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third

party in the event we go out of business or enter bankruptcy, some or all of our assets, including your

Personal Data, will be disclosed or transferred to a third party acquirer in connection with the

transaction.

4. How your Personal Data is transferred

Our apps operate their Services across the globe. Your Personal Data will likely be transferred and

stored in a country outside of your home country, for the purposes outlined in this Privacy Policy to

the extent permitted by applicable laws. The data protection laws in these countries may not be the

same as in your home country.

If we transfer your Personal Data, we ensure that a similar degree of protection is provided to your

Personal Data as within the EEA, as applicable.

5. How we keep your Personal Data safe

We have appropriate legal, organizational and technical security measures in place to prevent your

Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly

altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors

and other third parties who have a business need to know. They will only process your Personal Data

on our instructions and they are subject to a duty of confidentiality. We have put in place procedures

to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a

breach where we are legally required to do so.

6. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfil the

purposes set out in this Privacy Policy. This is also the case for anyone that we share your information

with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply

with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so

that it can no longer be associated with you. When removing Personal Data, we will take

commercially reasonable and technically feasible measures to make said Personal Data irrecoverable

or irreproducible.

7. Your rights and choices

You have certain rights in relation to your Personal Data. In order to exercise these rights, please

You can:

Request access to the Personal Data we hold on you by emailing info@toka-games.com.

Delete or correct your Personal Data. The easiest way to update your account information is via your

in-app settings.

Ask us to stop processing your Personal Data, including for direct marketing and promotional

purposes such as tailored rewards, promotions, and other offers, by emailing info@toka-games.com.

But be aware that sometimes we need to use your Personal Data in order to provide the Services to

you.

Have your Personal Data transferred to another organization (where it is technically feasible).

Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd

prefer you to contact us first. However, if you're based in the UK or the EEA and believe that we have

not complied with data protection laws, you can complain to your local supervisory authority.

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one

of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll

respect the choices you make. Please note that if you decide not to provide us with the Personal Data

that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the

information or complete the outcome you request within 30 days, or such shorter time period as

provided by laws of your jurisdiction

8. Children

The Services do not address anyone under the age of 13. We do not knowingly collect personally

identifiable information from children under 13. In the case we discover that a child under 13 has

provided us with personal information, we immediately delete this from our servers. If you are a

parent or guardian and you are aware that your child has provided us with personal information,

please contact us so that we will be able to do necessary actions.

9. Third Parties

In using our Services you may access links to websites and services that are owned or operated by

third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party

Service or that is collected by a Third Party Service is provided directly to the owner or operator of

the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not

responsible for the content, privacy, or security practices and policies of any Third Party Service. To

protect your information we recommend that you carefully review the privacy policies of all Third

Party Service that you access.

10. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such

information is collected. We may make changes to this Privacy Policy from time to time. You will be

given reasonable notice of any material change.