TCM Inplay is a trading name for TCM Inplay Limited, with company number: 2461493 and registered at Office 505, 5th floor, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong.
Data You Provide to Us:
- Contact information (such as name and email address)
- Player name and password
- Profile information (such as profile photo)
- Your messages to the Service (such as chat logs and player support tickets)
- Other data you choose to give us (such as data to identify a lost account)
Data We Collect Automatically:
- Data about your account and game progress
- Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
- Data about your device, such as device name and operating system, browser type and language
- Data we collect with cookies and similar technologies (see more below)
- General location data
- Precise geo-location data (GPS, with your consent)
- Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service
- In most cases, we also create a TCM Inplay-specific ID for you when you use the Service.
Data We Collect from Our Partners:
- Data we receive if you link a third party tool with the Service (such as Facebook, WeChat or Google)
- Demographic data (such as to determine the coarse location of your IP address)
- Data to fight fraud (such as refund abuse in games or click fraud in advertising)
- Data from platforms that the games run on (such as to verify payment)
- Data for advertising and analytics purposes, so we can provide you a better Service.
Why We Collect Your Data
In order to provide services and perform our obligations, where we process data necessary to:
- Create accounts and allow you to play our games and use our Service
- Operate the Service
- Verify and confirm payments
- Provide and deliver products and services you request
- Send you Service-related communications
In order to make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to
- Update and develop player profiles
- Develop and improve the Service and player experience
- Manage our relationship with you
- Provide social features as part of the Service
- Customize your Service experience
- Respond to your comments and questions and provide player support
- Provide you TCM Inplay offers in the Service as well as in other websites and services, and by email
- Send you related information, such as updates, security alerts, and support messages
- Enable you to communicate with other players
In order to show personalized advertisements.
To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to:
- Track the content you access in connection with the Service and your online behavior
- Deliver, target and improve our advertising and the Service
- For information on how to opt-out from personalized advertisements, see section ‘Your rights’ below.
In order to keep the Service safe and fair.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to:
- Analyze and monitor use of the Service and its social features
- Moderate chats either automatically or manually
- Take action against fraudulent or misbehaving players
In order to analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
With your consent.
With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.
Providing and optimising our Services
We use your information to enable us to provide our websites, advertising and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.
Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players, to TCM Inplay Customer Support. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 30 days your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
We use your information, including data that you provide directly to us in communications, to provide you with support through our customer service channels when you need it. We may also use it to contact you, for example as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
Analytics and Research
Social and Community
We have a number of social and community channels which we use to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels.
Promotions and Competitions
Fraud Prevention and Crime
We may use personal data that we hold to prevent fraud, cheating, and crime activities. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.
We may use your data as required or permitted by any applicable law. In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out for instance under European data protection law. The legal bases which we rely upon are the following:
- Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third party social network connectivity;
- Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
- Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Marketing, Advertising, analytics, research and optimisation of our games and other Services; and
Who Can See Your Data
Apart from TCM Inplay, your data can be accessed by others in the following situations:
Other Players and Users
Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
PARTNERS WORKING for TCM Inplay.
TCM Inplay has partners to perform services for us. These partners process your data only at and according to TCM Inplay´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
Other Companies and Public Authorities.
In order to prevent fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
Advertising and Social Media partners.
The Service includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at tcminplay.com/en/partner-opt-out. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
International Data Transfers
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
- Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 30 days of receipt of your request and verification of your identity.
- Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at firstname.lastname@example.org and we will correct it as soon as we can.
- Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. Please note that in order to process your request you must delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a wifi network.
- Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, such as Trophies, Tickets or Diamonds will be lost and we may not be able to restore them in the future.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
- Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see Legal Bases below).
- Direct marketing opt out. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).
For personalized in-game offers opt-out, you can use the options provided in the game settings.
Opting-out of interest-based advertising
You can choose to prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device. For more information, see How to adjust your preferences for interest based advertising below.
Please note that if you opt out of interest based advertising, you will still be able to play our games and you may still see advertising in our games but those ads will not be targeted using information that we hold about you. However, they may still be delivered based on contextual criteria such as the game that ad is to be displayed in, or the region in which your device is located.
Access the personal data we hold about you.
If you request, we will provide you a copy of your personal data in an electronic format.
We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
Visiting our websites
When you visit our other websites, such as http://isuperx.com, and other websites and forums operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis.
The information we collect and process about you when you visit our Websites includes:
- information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us;
- details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
- if you contact us or respond to messages and communications that we or other users of the Websites send to you, we may keep a record of that correspondence;
- your interactions with us on our social media channels; and information we collect via cookies (which are small text files placed on your device), and. Cookies allow us to collect data, such as your device’s model, operating system and screen size and other information about how you use our Services. For more information, see Ad identifiers, cookies and similar technologies below.
We, our suppliers and group companies, may use this information:
- as necessary in order to provide the Websites and related services to you;
- for the purposes of contacting you, for example as part of customer service or to send you updates about the Websites;
- for the purposes of managing your account and relationship with us and improving your experience when you use the Websites;
- for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;
- for the purposes of marketing and promotion of TCM Inplay’s products, for example sending you communications (including by email) for these purposes on our, or a third party’s behalf. For example, we might send you information about merchandise relating to our games. If you do not want us to use your data in this way please let us know by contacting us at email@example.com;
- to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with the Websites;
- for the purposes of preventing cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention; or
TCM Inplay Profile and Playing Socially
TCM Inplay Profile
When you play our games, we will give you a randomly generated unique identifier which we will associate with a TCM Inplay account known as a “TCM Profile”. Your TCM Inplay Profile will not be personally identifiable unless you choose to add your personal information to it, such as your name, avatar, email address or other information.
Your TCM Inplay Profile and the information it contains will be visible to other users of our Services. If you choose to add personal information to your TCM Inplay Profile it will be visible to your friends and other players anywhere in the world.
If you choose to view another individual’s TCM Inplay Profile, that individual and other users of our Services will know that you have visited them because some of your social information and a link to your TCM Inplay Profile will be displayed on that individual’s TCM Inplay Profile.
Connecting with a third party network
Where we make this available, you can choose to log in to your TCM Inplay Profile using your account details with a third party network, such as Facebook or Google. If you do this, you will be able to use your account to log in on multiple devices and synchronise progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play, as TCM Inplay other players for lives and direct messaging.
Information we receive from Facebook
If you log in to your TCM Inplay Profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your TCM Inplay Profile. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your username, email address, age range, gender, chosen language, country, friends list and any other public information.
We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your TCM Inplay Profile. If you provide us with your email address we may from time to time use that email address to send you marketing emails about our other games and Services. You can opt out of this at any time – see Opting-out of direct marketing from TCM Inplay below.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see you and your progression in our games, you can prevent this by disconnecting from Facebook from within our games and updating your app permissions from within your Facebook settings.
Information we receive from Google
If you log in to your TCM Inplay Profile using your Google account details, we will receive some of your Google account information. Exactly what information we receive will depend on your settings in your Google account, but typically we will receive your basic public profile information such as your name, email address and profile picture. If you choose to grant us access to your Contact List, we will use and store this to help you find those of your Google contacts that are already playing our games.
You can revoke future access to your information at any time by following the steps at https://support.google.com/accounts/answer/112802?hl=en.
Unless you opt out as explained below, we and our third party partners use information collected about you to send you marketing communications about other TCM Inplay games and related Services based on your interests. For example, we may send emails, serve ads within our Services or place ads on third party websites, apps and Internet-connected devices.
We may use the information that we hold about you to promote TCM Inplay’s own Services in a number of ways. This might include:
- advertising within third party websites, apps and Internet-connect devices;
- showing you promotions for other TCM Inplay or third-party games within the games you play; or
- sending you marketing materials by email.
What Information Do We Use for Marketing?
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:
- ad identifiers and other non-personal information collected from your device.
- the games you play and information about how you interact with our Games and Services;
- your age, country or region, and gender; and
- other information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
When we market our games in media published by other companies, we use various third party marketing partners to assist us on our behalf, and we may share information which we have collected about you with such third parties for these purposes.
Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for TCM Inplay’s games or Services, they will serve you with a TCM Inplay ad while you are using other websites and services.
We use information that we hold about you to better target ads for third party goods and services to people that might be most interested in them. These ads may be shown to you within our games or Services.
What information is used for advertising?
- ad identifiers and other information collected from your device. For more information, see Ad identifiers, cookies and similar technologies;
- the games you play and information about how you interact with our games and Services;
- your age, country and region, and gender; and
- other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
You consent to the collection and use of your data for targeting advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. We recommend that you review our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found here. You can refuse or withdraw your consent to such use at any time – for more information, see How to adjust your preferences for interest based advertising.
Ad identifiers, cookies and similar technologies
To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
- recognise you and your device;
- allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
- allow our payment processors to process your payment instructions;
- provide interest-based advertising to you; and
- enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.
How do ad identifiers, cookies and similar technologies work?
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.
Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.
How to adjust your preferences for interest-based advertising
You can choose to prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings of your device. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings.
If you live in the USA, Europe or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
If you choose to adjust your preferences in order to prevent these technologies, you may find that you cannot enjoy the full use of our Services.
Please note that adjusting your preferences as described in this section does not mean you will no longer receive adverts, it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us).
How Do We Protect Your Data
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
- via our Customer Support page;
- via email to firstname.lastname@example.org; or
- in writing to TCM Inplay, Office 505, 5th floor, Beverley Commercial Centre, 87-105 Chatham Road South, Tsim Sha Tsui, Kowloon, Hong Kong.