Titan AI Privacy Policy

Last Updated: June 21st 2023

Introduction

Protecting your privacy is very important to Titan AI. Our mission is to craft tailored mobile games for players proud of their unique identities and this should not come at the price of your privacy.

Scope

Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive when you use our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Any information that we collect is subject to the Privacy Policy in effect at the time that information is collected.

Updates to this Privacy Policy

We may modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or take other actions as required by applicable law, and we’ll indicate when those changes will become effective.

Information We Collect

To provide our Services, we collect:

Information Provided by You or Collected with Your Permission
Information Related to Your Use of the Services
Information from our Partners

Information Provided by You or Collected with Your Permission.

User Data: We may collect demographic data and information about your interests to help us understand what content you might be interested in. When you set up your own account or otherwise interact with our Services, we may also collect certain personal information that can be used to identify you, which may include your name, your e-mail address, your profile image and other information.
SNS Data: We may allow you to use certain social networking services ("SNS") via the Services and may collect information about you from that SNS that you have made available via your privacy settings. For example, if you link your Twitter account to Titan AI and let us know that you want to see what news stories the people you follow on Twitter are sharing, the links to these news stories will be sent to you via our Services. Please refer to the privacy policy for the SNS you use for more information on how your information will be shared by the SNS and information available on your SNS accounts.
Survey Data: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information that may include personal information.

Information Related to Your Use of the Services

Device Data: We and third parties we work with may automatically collect certain data about the device you use to access our Services. This data may include your Internet Protocol (IP) address, mobile advertising identifiers (Google Advertising ID or Apple Advertising ID) and other unique identifiers, cookie identifiers, model name, operating system, country code, app version, and other user settings and preferences.
Activity Data: We automatically collect certain data about your activities on our Services, including the pages, content or features of our Services you browse and the time you spend on those pages, content or features, the hyper-links from the contents displayed on our Services that you click on, referrer information and other information about how you use our Services.
Location Data: You may, by your own choice, provide us with your location data such as your postal code, city and state information, or GPS location in order for us to display the weather, the local news and the local advertisements to you. In addition, we may also infer your location based on your IP address and use various other technologies to determine your approximate location, such as sensor data from your device that provides information on nearby Wi-Fi access points and cell towers.

Information from Our Partners

Third-Party Partners: We may receive your information from our partners, such as publishers, advertisers, and third-party data providers. Our partners may provide demographic data and information about your activities and interests off our services, including information about your device, device identifiers, your precise or approximate location, websites and advertisements you interact with, your browsing patterns, and information about how you use our partner’s services.

How Do We Use Information?

Our primary purpose for collecting and using information is to deliver quality mobile games to you, our players. We also collect and use your information for a variety of business purposes, including:

To Provide the Services or Information Requested
To Measure Performance and Carry Out Research
For Customer Support
For Advertising Purposes
For Administrative or Legal Purposes

To Provide the Services or Information Requested. This includes using your information to:

Fulfill our contract with you;
Tailor and deliver Content curated according to your interests which we infer from the data we collect;
Provide access to certain functionalities, and features of our Services, such as the local news feature and the weather forecast feature;
Create and update your account; and
Manage your information.

To Measure Performance and Carry Out Research. This includes using your information to:

Measure interest and engagement in the Services;
Pursue our legitimate interests, such as research and development (including marketing research), network and information security, and fraud prevention;
Improve our products and Services;
Develop new products and services; and
Carry out analytics. For example, we may use personal information and other data to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

For Customer Support. This includes using your information to:

Respond to questions, comments, and other requests from you;
Investigate and answer requests for customer or technical support; and
Communicate with you about activities on the Services and changes to our Terms of Service.

For Advertising Purposes. This includes using your information to:

Tailor and provide personalized advertisements with you. We and our third-party partners may provide you with these materials as permitted by applicable law.
Engage in cross device tracking, which helps us to track your browsing activity across different websites, devices and/or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your tablet. To do this, our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and/or devices that appear to be used by the same user.

For Administrative or Legal Purposes. This includes using your information to:

Ensure internal quality control and safety;
Verify individual identity to respond to certain requests or claims;
Carry out audits;
Prevent and prosecute potentially prohibited or illegal activities;
Enforce our agreements; and
Comply with our legal obligations. For example, we may disclose your information to certain government entities regarding certain claims or disputes relating to use of our Services.

What Information Do We Share With Third Parties?

We may share the information that we have collected from you:

With Our Advertising Partners
With Our Service Providers
With Your Consent or at Your Request
With Affiliates
For Legal Reasons
In Connection with Business Transactions

Information Shared with Our Advertising Partners.

We may engage third party advertising partners to collect information and serve advertising on and through the Services. When you use our Services, these third-party advertising partners may collect information regarding your activities and your device (e.g., your IP address, mobile device identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit our Services and third-party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

Information Shared with Our Service Providers.

We may engage third party service providers to work with us to administer and provide the Services. The types of service providers to whom we entrust information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) analytics; (iv) marketing and advertising; (v) customer service activities; and (vi) the provision of IT and related services.

We also use analytics services from Google including Google Analytics for Firebase to collect analytics information on the Services. For more information about Google’s processing of your information, please visit: https://policies.google.com/technologies/partner-sites. To learn more about how to opt-out of Google Analytics’ use of your information on our website, please visit: https://tools.google.com/dlpage/gaoptout as well as Game Analytics: https://gameanalytics.com/terms/ and Unity Analytics: https://unity.com/legal/one-operate-services-terms-of-service

Information We Disclose with Your Consent or at Your Request.

We may share your information with third parties if you provide us with your consent or if you have expressly requested that we share your information.

Information Disclosed for Legal Reasons.

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

Information Shared in Connection with Business Transactions.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Cookies and Third-Party Technologies

Cookies and Pixel Tags. We may use cookies, pixel tags, and other similar technologies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our use of cookies and similar technologies falls into the following general categories: (i) operationally necessary; (ii) performance-related; (iii) functionality-related; and (iv) advertising-related.

Software Development Kits. We may use third party software development kits (“SDKs”) as part of the functionality of our App. SDKs typically collect your mobile device identifier and information related to your use of the Services. SDKs may allow third parties including analytics and advertising partners to collect your information for various purposes including to provide analytics services and personalized advertising. For more information about the SDKs we use, please contact us as set forth below.

Your Choices

General. You may have the right to opt out of certain uses of your information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).

Mobile Devices. We may send you push notifications through our App. You may opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect precise location information if you enable such collection via our App. You may opt-out of this collection by changing the settings on your mobile device.

Personalized Advertising. If you would like to opt-out of the advertising and other similar technologies (e.g., cookies) we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits, including by following the steps set forth below. Please note that you can opt out of personalized advertising (i.e., targeted advertising), but you will continue to see non-personalized online advertising on the Services and/or other digital properties.

To limit ad tracking by Apple, Google, or other mobile operating systems: please follow the instructions for Android, iOS, and others. Other operating systems for mobile devices may also provide instructions on how to prevent the delivery of personalized advertisements.
To opt-out of the personalized advertising by certain third parties: please opt-out of personalized advertisement using your account settings on each applicable service. If you do not have any account on a certain service, you likely will not see any personalized advertisements from that service.

Google: https://adssettings.google.com/authenticated
Facebook/Meta: https://www.facebook.com/ads/preferences/

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at https://optout.networkadvertising.org/, https://www.youronlinechoices.com/ and https://optout.aboutads.info/.

Please note that cookie-based opt-outs are not effective on mobile applications and you must separately opt out in each browser and on each device.

“Do Not Track” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers when you visit our website.

Individual Rights in Personal Information

In accordance with applicable law, you may have the right to:

confirm whether or not we are processing your personal information;
obtain access to or a copy of your personal information with accompanying details;
receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
change, update, or correct your personal information;
withdraw your consent to process your personal information;
request that we restrict or limit our use of your personal information;
request to opt-out of certain processing activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in profiling in furtherance of certain decisions that produce legal or similarly significant effects concerning you;
request erasure of personal information held about you by Titan AI;
object to our processing of your personal information; and
appeal our decision to decline to process your request.

If you would like to exercise any of these rights, visit the app store (Google Play or Apple App Store) for our mobile application and use the developer contact email. Please specify the nature of your request in the email you send. Please note that there may be technical limitations that prevent us from fulfilling certain requests. We may carry out deletion requests by de-identifying and/or anonymizing information such that it is no longer personal information.

We will process such requests in accordance with applicable laws. To protect your privacy, Titan AI will take steps to verify your identity before fulfilling your request.

In order to verify your request, we use an identifier that is unique to your device that has been assigned by our App. If you submit a request in accordance with the instructions listed above, we will automatically receive the identifier. If we do not receive this identifier when you make a request, we will not be able to verify your identity and will deny your request.

If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

How Long Do We Retain Your Information?

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Supplemental Notice for California Residents

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Titan AI has collected about them, whether Titan AI disclosed that personal information for a business purpose (e.g., to a service provider), whether Titan AI “sold” that personal information, and whether Titan AI “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Titan AI	Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose	Category of Third Parties Personal Information To Whom Personal Information is Sold and/or Shared
Identifiers	Our affiliates Service providers	Advertising partners
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Our affiliates Service providers	N/A
Protected classification characteristics under California or federal law	Our affiliates Service providers	Advertising partners
Commercial information	Our affiliates Service providers	Advertising partners
Internet or other electronic network activity	Our affiliates Service providers	Advertising partners
Geolocation data	Our affiliates Service providers	N/A
Inferences drawn from other personal information to create a profile about a consumer	Our affiliates Service providers	Advertising partners
Personal information that reveals a consumer’s precise geolocation	Our affiliates Service providers	N/A

The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth above in “Information We Collect”, “How Do We Use Information?” and “What Information Do We Share With Third Parties?”, respectively. We will retain personal information in accordance with the time periods set forth above in “How Long Do We Retain Your Information?”.

The purposes for which we “sell” personal information and “share” personal information for “cross-context behavioral advertising” are to provide personalized content (including advertising), measure and analyze performance, improve the services we provide, and detect illegal or harmful activities.

Additional Privacy Rights for California Residents

Right to Opt-Out of “Sales” and “Sharing” for “Cross-Context Behavioral Advertising”. California residents have the right to opt-out of the “sale” of their personal information and the “sharing” of their personal information for “cross-context behavioral advertising.” California residents can exercise these rights in the Settings menu of the Titan AI mobile application.

Right to Limit the Use and Disclosure of Sensitive Personal Information. California residents have the right to limit our use and disclosure of their “sensitive personal information.” California residents may do this by disabling our collection of precise geo-location via their device settings.

Disclosure Regarding Individuals Under the Age of 16. Titan AI does not have actual knowledge of any “sale” of personal information of minors under 16 years of age. Titan AI does not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”

Verification Process. We will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. As part of this process, we require that you follow the prescribed procedures to verify your identity unless the CCPA requires otherwise:

If you have your account, we will request you to provide your account name and your email address of your account, and a device token obtained from the Settings menu of the Services, or to log in to the Services via your account. However, for requests for the disclosure of specific pieces of personal information, we will request the submission of three documents (driver's license, health insurance card, passport, utility bill payment document, etc.) that can verify your personal information, along with a signed declaration under penalty of perjury that you are the person in possession of the personal information.
If you do not have your account, we will request you to provide multiple pieces of information that are known only to you (e.g., device tokens, recently viewed articles, locations where you have used our application, etc.) or sending a push notification to your device and requesting a response. However, for requests for the disclosure of specific pieces of personal information, we will also request you to follow the same procedure as set forth in (1) above.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent and exercise any rights, please contact us as set forth below.

Our Lawful Basis for Processing Personal Information

If your personal information is subject to the EU General Data Protection Regulation or other related legislation, our processing of your personal information is supported by the following lawful bases:

	Performance of a Contract (i.e., to Provide Our Services to You)	Legitimate Interest	Consent	For Compliance with Legal Obligations
To Provide the Services or Information Requested	✔	✔		✔
To Measure Performance and Carry Out Research	✔	✔	✔
For Customer Support	✔	✔	✔	✔
For Advertising Purposes		✔	✔
For Administrative or Legal Purposes	✔	✔		✔

Links to Other Services

Our Services may contain links to other websites and services. Any information that you provide on or to or that is collected by a third-party website or service is provided directly to the owner of the website or service and is subject to that party's privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access. Visiting these other websites or services is at your own risk.

International Transfer

Your information may be transferred to, and maintained on, computing equipment located outside of your state, province, country or other governmental jurisdiction including, but not limited to the United States of America, or other countries, where the privacy laws may not be as protective as those in your jurisdiction. We endeavor to safeguard your information consistent with the requirements of applicable laws.

Our Policy Toward Children

Our Services are not directed to children under 16 and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information of a child under 16 we will take steps to delete such information from our files as soon as possible.