Privacy Policy

1. Who we are and what this covers

Torira Games LLC (“Torira Games”, “we”, “us”, or “our”) is a limited liability company registered in the United States of America. We publish, market and monetize mobile games.

This Privacy Policy explains how we handle information when you:

• visit toriragames.com (the “Site”);
• download, install or play a mobile game or application published by Torira Games LLC on Google Play, the Apple App Store or another authorized distribution platform (each, an “App”); or
• contact us, submit a game for publishing, or otherwise engage with our business services (together with the Site and Apps, the “Services”).

For personal data collected through the Services, Torira Games LLC is the data controller. Some of our Apps are developed by partner studios and published by us; unless an App states otherwise in its store listing, this policy applies to it.

Certain Apps may have additional or different practices. Where that is the case, an App-specific privacy notice is linked from that App’s store listing and in-game settings, and it prevails over this policy for that App.

2. Information we collect

2.1 Information you give us

• Contact and correspondence data — name, email address, company name, and the contents of messages when you email support@toriragames.com, submit a game, or request support.
• Account data — if an App offers an account, the identifiers you register with (for example a username, an email address, or a sign-in through a third-party service such as Google Play Games, Apple Sign in or Facebook Login).
• User-generated content — nicknames, avatars, in-game messages or other content you choose to submit within an App, where that feature exists.
• Business partner data — for developers and vendors, the details needed to enter into and administer an agreement, including payment and tax information required to pay revenue share.

2.2 Information collected automatically

• Device and technical data — device model, manufacturer, operating system and version, language, country/region, screen resolution, network type, mobile carrier, time zone, and app version.
• Identifiers — advertising identifiers (Google Advertising ID / AAID on Android, Identifier for Advertisers / IDFA on iOS where you permit tracking), app-instance or installation IDs, and randomly generated internal identifiers.
• Approximate location — coarse location derived from IP address, typically at country, region or city level. We do not collect precise GPS location unless an App clearly asks for it and you grant the permission.
• Gameplay and usage data — session start and end, level progression, scores, in-game events, feature usage, settings, and interactions with ads and offers.
• Purchase data — records of in-app purchases, including product purchased, price, currency, store transaction identifier and purchase status. Payment card details are processed by Google, Apple or another store operator and are never received or stored by us.
• Diagnostics — crash logs, error traces, latency and performance metrics.
• Site data — for the Site, standard server log data (IP address, browser type, referring page, pages viewed) and any cookies described in section 5.

2.3 Information from third parties

• App stores — aggregated install, uninstall, rating and revenue reporting from Google Play and the App Store.
• Advertising and attribution partners — install attribution data (which campaign, ad network and creative led to an install), ad impressions, clicks and estimated ad revenue.
• Sign-in providers — where you log in with a third-party account, the basic profile information that provider shares with us according to your settings with them.

2.4 Summary of data categories

The table below summarizes the categories we may process. The exact set depends on the App, your device settings and your consent choices. Each App’s Google Play Data safety section and Apple App Privacy label describe the data collected by that specific App.

We do not knowingly collect government identification numbers, precise financial account details, biometric data, health data, or other sensitive categories of personal information.

3. How we use information

• To provide the Services — run and maintain our Apps, save progress, deliver purchased items, and operate account features.
• To support you — respond to questions, investigate reports, and resolve technical issues.
• To improve our games — analyze gameplay and usage patterns, run A/B tests, fix crashes and balance game design.
• To display advertising — show ads in our Apps, including personalized ads where you have consented or where permitted by law, and measure ad performance.
• To market our games — run and measure user acquisition campaigns, attribute installs to campaigns, and build audiences for advertising in accordance with applicable law.
• To process payments — verify and fulfill in-app purchases and handle refunds and chargebacks through the relevant store.
• To keep the Services safe — detect and prevent fraud, cheating, ad fraud, abuse and security incidents.
• To meet legal obligations — comply with applicable law, respond to lawful requests, enforce our Terms of Service, and establish or defend legal claims.

We do not sell personal information in the ordinary meaning of that term, and we do not share it for cross-context behavioral advertising in a way that is not disclosed here. See section 13 for how US state privacy laws define those terms and how to opt out.

4. Legal bases for processing (EEA, UK and Switzerland)

If you are in the European Economic Area, the United Kingdom or Switzerland, we process personal data on the following legal bases:

• Performance of a contract — to provide the App or Service you requested, including purchases and account features.
• Consent — for personalized advertising, certain analytics, and any optional device permissions. You may withdraw consent at any time, including through the in-app privacy settings or consent management prompt.
• Legitimate interests — to secure our Services, prevent fraud, understand aggregate product performance, and communicate with business partners, balanced against your rights.
• Legal obligation — where processing is required by applicable law.

5. Advertising, analytics and third-party SDKs

Our Apps are usually free to play and are funded by advertising and in-app purchases. To do that, we integrate software development kits (SDKs) from third-party providers. These providers may collect or receive information such as advertising identifiers, device and network data, approximate location, and ad interaction data, and they act as independent controllers or as our processors depending on the service.

Depending on the App, our partners may include:

Keep this table aligned with the SDKs actually integrated in your live builds; remove any partner you do not use and add any that is missing.

Cookies on the Site. The Site uses only the cookies and local storage strictly necessary to serve pages and remember basic preferences. We do not run advertising cookies on the Site. Web fonts are loaded from Google Fonts, which receives the request data (including IP address) needed to deliver the font files.

6. How we share information

We share personal information only as described here:

• Service providers — hosting, analytics, customer support, attribution and anti-fraud vendors that process data on our instructions.
• Advertising partners — ad networks and mediation platforms, as described in section 5, subject to your consent settings.
• Platform operators — Google and Apple, in connection with distribution, billing, game services and policy enforcement.
• Development partners — where an App is co-developed with a partner studio, we may share aggregated or pseudonymized performance data needed to operate the title and calculate revenue share.
• Legal and safety — regulators, law enforcement or other parties where we believe disclosure is required by law or reasonably necessary to protect the rights, property or safety of Torira Games, our players or the public.
• Corporate transactions — in connection with a merger, acquisition, financing or sale of assets, in which case we will require the recipient to honor this policy or notify you of any material change.

We do not share your personal information with third parties for their own independent marketing purposes without your consent.

7. Your advertising choices

• Android — you can delete or reset your advertising ID, and opt out of ad personalization, in Settings → Privacy → Ads (the exact path varies by device).
• iOS — we ask for permission through App Tracking Transparency before using the IDFA for tracking across apps and websites. You can change this at any time in Settings → Privacy & Security → Tracking.
• In-app settings — where an App uses a consent management platform (for example in the EEA or UK), you can reopen the privacy or consent screen from the App’s settings menu to change or withdraw your choices.
• Industry tools — you can also use the controls offered by DAA AppChoices or Your Online Choices in Europe.

If you opt out of personalized advertising you will still see ads, but they will be less relevant to you.

8. Children’s privacy

We take children’s privacy seriously and design our Apps to comply with the US Children’s Online Privacy Protection Act (COPPA), the Google Play Families policy, the Apple App Store Kids Category requirements, and the GDPR rules on children’s data.

• Apps that are not directed to children are intended for users aged 13 and over (or 16 and over where local law requires a higher age). We do not knowingly collect personal information from children below that age in those Apps.
• Apps that are directed to children or to mixed audiences apply a child-appropriate configuration: only self-certified, family-friendly ad SDKs, no personalized or interest-based advertising, no advertising identifiers used for tracking, an age screen where required, and no collection of persistent identifiers beyond what is needed to support internal operations.
• We do not knowingly enable children to make in-app purchases without the account holder’s authorization, and we rely on the store’s parental control and purchase authorization mechanisms.

If you are a parent or guardian and believe a child has provided us personal information contrary to this policy, email support@toriragames.com. We will verify the request and delete the information promptly.

9. Data retention

We retain personal information only for as long as needed for the purposes described in this policy:

• Gameplay and account data — for as long as the account or game profile is active, and then generally up to 24 months after the last activity, unless you ask us to delete it sooner.
• Advertising and attribution data — typically retained in identifiable form for up to 12 months, then aggregated or deleted, subject to each partner’s own retention schedule.
• Support correspondence — up to 24 months after the matter is closed.
• Transaction and tax records — for the period required by applicable US law, generally up to 7 years.

Aggregated or de-identified data that can no longer reasonably be linked to you may be kept indefinitely.

10. Security

We apply technical and organizational measures appropriate to the risk, including encryption in transit (HTTPS/TLS), access controls and least-privilege access to production systems, use of reputable cloud infrastructure, and regular review of the SDKs and vendors we rely on. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your personal data and applicable law requires it, we will notify you and the relevant authority without undue delay.

11. International data transfers

We are based in the United States and our service providers may process data in the United States and other countries. If you are located in the EEA, the UK, or another region with data transfer restrictions, your information may be transferred to countries that do not provide the same level of protection as your home jurisdiction. Where required, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) with our vendors, together with supplementary technical measures.

12. Your rights, access and deletion requests

Subject to your jurisdiction and to verification of your identity, you may have the right to:

• access the personal information we hold about you and receive a copy;
• correct inaccurate or incomplete information;
• delete your personal information and, where applicable, your game account;
• restrict or object to certain processing, including direct marketing and profiling;
• withdraw consent at any time, without affecting processing carried out before withdrawal;
• receive your data in a portable, machine-readable format; and
• lodge a complaint with your local data protection authority.

How to request account and data deletion

You can ask us to delete your data in either of these ways:

1. In the App — where an App supports accounts, open Settings → Account → Delete account and confirm. This is available in-app as required by the Google Play and Apple App Store account deletion policies.
2. By email — send a request to support@toriragames.com with the subject line “Data deletion request”. Please include the name of the App, your platform (Android or iOS), and any in-game player ID or username so we can locate your records.

What happens next. We acknowledge requests within 5 business days and complete verified requests within 30 days (or 45 days where US state law allows an extension, in which case we will tell you). Deletion removes your account identifiers, game progress and associated personal data from our active systems, and instructs our processors to do the same. Backups are purged on our regular backup rotation, within 90 days.

What we may keep. We may retain limited information where the law requires it — for example transaction and tax records, records needed to resolve disputes or enforce our agreements, and a minimal record of your deletion request itself. Aggregated and de-identified analytics that cannot be linked back to you are not deleted.

Requests are free of charge. We do not discriminate against you for exercising any of these rights.

13. US state privacy rights

If you are a resident of California or another US state with a comprehensive privacy law (including Colorado, Connecticut, Virginia, Utah, Texas and others as they take effect), you have the rights described in section 12, plus the right to opt out of the “sale” or “sharing” of personal information and of targeted advertising.

We do not sell personal information for money. However, sharing advertising identifiers with ad partners for personalized advertising may be treated as a “sale” or “sharing” under some of these laws. To opt out:

• use the device controls described in section 7; or
• email support@toriragames.com with the subject “Do Not Sell or Share My Personal Information”.

We honor Global Privacy Control (GPC) signals received through the Site where technically feasible. You may use an authorized agent to submit a request on your behalf; we will ask for proof of authorization. We do not knowingly sell or share the personal information of consumers under 16 years of age.

14. Third-party services and links

Our Services may link to or interoperate with third-party websites, stores, social networks and platforms that we do not control. Their handling of your information is governed by their own privacy policies, and we encourage you to read them. Downloading an App also involves the store operator (Google or Apple), whose privacy policies apply to the transaction and account you hold with them.

15. Changes to this policy

We may update this Privacy Policy to reflect changes in our Services, technology, or legal requirements. When we do, we will revise the “Last updated” date at the top of this page. If the changes are material, we will provide a more prominent notice — for example an in-app message or a notice on the Site — and, where required, ask for your consent again. The current version is always available at https://toriragames.com/privacy.html.

16. Contact us

For any privacy question, request or complaint, contact us at:

• Email: support@toriragames.com
• Company: Torira Games LLC, United States of America
• Mailing address: [Insert full registered address]

We aim to answer every privacy enquiry within 5 business days. If you are in the EEA or UK and are not satisfied with our response, you may contact your national data protection authority.