Privacy Policy

Toledo Apps Limited ("we," "us," or "our") operates toledoapps.com and mobile games. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our games and services.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access our games or website.

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Data Controller

The data controller responsible for your personal data is:

Toledo Apps Limited
Company Registration No: 16944030
Registered Address: 71-75 Shelton Street,
Covent Garden,
London,
United Kingdom
WC2H 9JQ
Email: support@toledoapps.com

2. Information We Collect

2.1 Information You Provide to Us

We may collect information that you voluntarily provide when you:

• Contact us via email for support or inquiries
• Subscribe to newsletters or updates (if applicable)
• Participate in surveys or feedback forms

This information may include your email address, name, and the content of your communications with us.

2.2 Automatically Collected Information

When you use our games or website, we may automatically collect certain information, including:

• Device information (device type, operating system, unique device identifiers)
• Gameplay data (progress, scores, achievements, in-game actions)
• Technical data (IP address, browser type, time zone, crash reports)
• Usage analytics (how you interact with our games, session duration, features used)

2.3 Information Collected by Third-Party Advertising Partners

Our games display advertisements provided by third-party advertising networks. These advertising partners may collect information about you through their own SDKs (Software Development Kits) embedded in our games. The information they may collect includes:

• Device identifiers (such as Advertising ID, Android ID, or IDFA)
• IP address and approximate location
• Device make, model, and operating system
• App usage and interaction data
• Ad interaction and viewing data

We currently use the following advertising partners:

• Google AdMob: Operated by Google LLC. AdMob may collect and use data to serve personalized advertisements. For more information, please review Google's Privacy Policy at policies.google.com/privacy and their information on how Google uses data from apps that use their services at policies.google.com/technologies/partner-sites.
• Petal Ads: Operated by Huawei. Petal Ads may collect and use data to serve advertisements. For more information, please review Huawei's Privacy Policy at consumer.huawei.com/uk/privacy/privacy-policy/.

We may add additional advertising partners in the future. When we do, we will update this Privacy Policy to reflect those changes.

These advertising partners act as independent data controllers for the data they collect. We do not have access to or control over the data collected by these third-party advertising networks. Their collection and use of information is subject to their own privacy policies.

2.4 Information Collected by App Stores and Platforms

When you download and use our games from app stores (Google Play Store, Amazon Appstore, Huawei AppGallery, Samsung Galaxy Store), those platforms may independently collect information about you, including:

• Your account information with the app store
• Purchase history and transaction data
• Device information and identifiers
• App installation and usage data
• Crash reports and performance data

This data collection is governed by the respective app store's privacy policy, not by this Privacy Policy. We recommend reviewing the privacy policies of the app stores you use:

• Google Play Store: policies.google.com/privacy
• Amazon Appstore: amazon.com/gp/help/customer/display.html?nodeId=468496
• Huawei AppGallery: consumer.huawei.com/uk/privacy/privacy-policy/
• Samsung Galaxy Store: samsung.com/uk/info/privacy/

We do not have access to or control over the data collected by these app store platforms.

2.5 Cookies and Tracking Technologies

We and our third-party advertising partners may use cookies, pixel tags, and similar tracking technologies to collect information about your browsing activities. You can control cookies through your browser settings. For more information about the cookies we use, please see our Cookie Policy (if applicable).

3. Legal Basis for Processing (UK GDPR)

We process your personal data under the following legal bases:

• Legitimate Interests: To operate, maintain, and improve our games and services, analyze usage patterns, and ensure security
• Contractual Necessity: To provide services you have requested and fulfill our obligations to you
• Consent: Where you have given specific consent for certain processing activities (e.g., marketing communications)
• Legal Obligation: To comply with applicable laws and regulations

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our games and services
• Respond to your inquiries and provide customer support
• Analyze usage patterns and optimize game performance
• Fix bugs and technical issues
• Develop new features and content
• Display advertisements within our games (through third-party advertising partners)
• Send you important updates, security alerts, and administrative messages
• Protect against fraud, abuse, and security threats
• Comply with legal obligations

Information collected by our advertising partners (AdMob and Petal Ads) is used by them to serve and personalize advertisements, measure ad performance, and for other purposes described in their respective privacy policies. We do not control how these third parties use the data they collect.

5. Sharing Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Advertising Partners: Our games contain advertisements served by third-party advertising networks (Google AdMob and Petal Ads). These partners collect data directly through their SDKs embedded in our games. They act as independent data controllers and use this data to serve personalized advertisements. Please refer to their privacy policies for more information on how they collect, use, and share your data.
• Service Providers: We may share information with trusted third-party service providers who assist us in operating our games (e.g., cloud hosting providers, analytics providers, customer support platforms). These service providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Analytics Partners: We may use analytics services to understand how users interact with our games. These services may collect and process data in accordance with their own privacy policies.
• Legal Requirements: We may disclose information if required by law, court order, or government authority, or to protect our rights, property, or safety, or that of others.
• Business Transfers: If we are involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.

6. International Data Transfers

Your information may be transferred to and processed in countries outside the United Kingdom, including countries that may not offer the same level of data protection as the UK. When we transfer your data internationally, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the UK authorities
• Adequacy decisions recognizing equivalent data protection standards
• Other legally approved transfer mechanisms

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention period depends on:

• The nature of the data collected
• The purposes for which it was collected
• Legal, regulatory, or contractual requirements

When we no longer need your information, we will securely delete or anonymize it in accordance with our data retention policies.

8. Your Rights Under UK GDPR

Under the UK GDPR and Data Protection Act 2018, you have the following rights regarding your personal data:

• Right of Access: You have the right to request access to the personal data we hold about you and receive a copy of it.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal data in certain circumstances.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain situations.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw your consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection matters. You can contact the ICO at ico.org.uk or by calling 0303 123 1113.

To exercise any of these rights regarding data we control, please contact us at support@toledoapps.com. We will respond to your request within one month, although this may be extended in complex cases. We may request verification of your identity before processing your request.

Advertising Choices and Opt-Out

You have choices regarding personalized advertising:

• Android Devices: You can opt out of personalized ads by going to Settings > Google > Ads > Opt out of Ads Personalization. You can also reset your Advertising ID in the same menu.
• iOS Devices: You can limit ad tracking by going to Settings > Privacy > Advertising > Limit Ad Tracking.

Please note that opting out of personalized advertising does not mean you will stop seeing ads; it means the ads you see will be less relevant to your interests.

For data collected by our advertising partners (AdMob and Petal Ads), you will need to exercise your rights directly with them according to their privacy policies, as they act as independent data controllers.

9. Children's Privacy

Our games and services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@toledoapps.com, and we will promptly delete such information from our systems.

10. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication procedures
• Regular security assessments and monitoring
• Employee training on data protection

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

11. Third-Party Links

Our games or website may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

12. Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making or profiling that produces legal effects or similarly significantly affects you.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by:

• Posting the updated Privacy Policy on this page
• Updating the "Last Updated" date at the top of this policy
• Sending you an email notification (where appropriate)

Your continued use of our games or services after such changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, or if you wish to exercise any of your rights under UK GDPR, please contact us at:

Toledo Apps Limited
Company Registration No: 16944030
Registered Address: 71-75 Shelton Street,
Covent Garden,
London,
United Kingdom
WC2H 9JQ
Email: support@toledoapps.com

We will respond to your inquiry as soon as possible, and in any event within one month of receiving your request.

15. Information Commissioner's Office (ICO)

If you are not satisfied with our response to your privacy concerns or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Tel: 0303 123 1113
Website: ico.org.uk