RORTOS Privacy Policy

Last Updated: June 21, 2016

RORTOS SRL and its affiliates (“RORTOS”, “us”, “our” or “we”) are dedicated to protecting the privacy rights of our users (“users” or “you”). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our websites, including www.rortos.com, www.rortos.it (the “Sites”) or any RORTOS game provided on any platform (for example, iOS and Android)(collectively, the “Service”). Please note that the scope of this Policy is limited to information collected or received by RORTOS through your use of the Service. RORTOS is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.
By using the Service, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Service.
If you have questions or concerns about our privacy policy or practices, please contact us at legal@rortos.com.

1. Definitions.

The following defined terms shall have the meanings set forth below:

“Financial Information” means information relating to payments and billing (e.g., name, account information, billing address) provided by you. All Financial Information is collected for billing and payment purposes only and will be protected and administered by Rortos and/or our authorized third party partners.

“Non-Personal Information” means information that, by itself, does not identify a specific individual or entity (e.g., demographic information, usage data or downloads).

“Personal Information” means specific identifiable information about an individual or entity which may be used to identify, contact or locate that person or entity (e.g., name, mailing address, Device ID (defined below), email address or phone number).

2. What Information Is Collected?

Information You Provide. Rortos may receive and store any Personal Information, Financial Information and/or Non-Personal Information that you provide when you interact with Rortos. Some features and/or functionality of the Rortos Services may be unavailable if you choose not to share certain information. Rortos may use information you provide to communicate with you and to improve the Rortos Services. Here are some examples:

  • Email Communications. Rortos may use your Personal Information to send you newsletters and emails related to promotions and/or events. You can opt out of receiving promotional emails by following the instructions in the relevant correspondence. Once Rortos has processed your opt-out request, Rortos will not send you further promotional emails unless you later opt back in. Whether you opt out of receiving promotional emails or not, Rortos reserves the right to email you with respect to important information, notices or changes relating to the Rortos Services.
  • Contact Us. If you choose to use the “Contact Us” form you will be asked to provide Personal Information, request type of inquiry, and describe the purpose for which you are contacting Rortos. If Rortos is aware that you are under the age of 13, Rortos will delete your email address once your request has been fulfilled.
  • Geo-Location Data. Rortos does not ask you for, access, or track any location based information at any time while downloading or using Rortos’s  applications or services.
  • Push Notifications. On occasion, Rortos will send you push notifications when using Rortos’s  applications regarding alerts to new high scores, as well as other account information that may be important to you. If you no longer wish to receive these types of communications, you may opt-out from receiving them by turning them off at the device level through the settings of the device or by contacting Rortos at info@Rortos.com.
  • Other Information. You may provide other Personal and Non-Personal information whenever you interact with the Rortos Services, including, without limitation, when you search the Rortos Services, participate in a contest, survey or questionnaire, place an order, or communicate with Rortos by phone or email.

With any of the above actions, you may supply Rortos with information such as your name, address, phone number, alternate contact information, information about your use of the Rortos Services, personal descriptions and product descriptions.

Information Collected Automatically or Through Technology. Rortos may receive and store certain Personal Information and Non-Personal Information whenever you interact with Rortos. While you are able to visit the Rortos Services and remain anonymous, Rortos and/or Rortos’s third-party service providers may still collect Non-Personal Information through technological means. Such information may be gathered by the following methods:

  • Cookies. Cookies are small pieces of information that are stored on your device’s hard drive which work by assigning to your device a unique number that has no meaning outside of the Rortos Services. Cookies do not generally contain any Personal Information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, because cookies enable you to take advantage of some of the features of the Rortos Services, Rortos recommends that you leave them turned on or you may not have access or use of such features. The use of cookies by third-parties is not covered by Rortos’s Privacy Policy. Rortos does not have access to or control over this information.
  • Device Information. When you download and use the Rortos Services, Rortos automatically collects information on the type of device you use, operating system, application version, and the persistent device identifier (“Device ID”). You consent to Rortos collecting this information.
  • Metadata. Metadata is data collected and used to facilitate the Rortos Services, monitor system usage, prevent fraud, and for other services. Some examples of metadata that Rortos may collect and analyze include, without limitation, the Internet protocol (IP) address used to connect your computer to the Internet, computer and connection information (such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform), the full Uniform Resource Locator (URL) click sequence to, through, and from the Rortos Services, including date and time, cookie number and any products, services or features you use or interact with arising out of or in connection with your use of the Rortos Services.
  • Log files. As true of most websites, Rortos gathers certain information automatically and stores it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
  • Tools. Rortos may use software tools to measure and collect information about your use of the Rortos Services, including, without limitation, page response times, upload and file transfer errors, interaction information (such as scrolling, clicks, and mouse- overs), features use, purchase tracking and order fulfillment and methods. Sometimes, you will have a choice whether or not to provide information, but if you fail to provide certain information it could impact some features and/or functionalities of the Rortos Services.
  • Information from Other Sources. Rortos may receive information about you from Rortos’s third-party service providers, or other sources such as purchase or redemption information, Rortos Services usage, payment information, reporting information, page-view information, technical, fulfillment, advertising, search information and credit history information.
  • Analytics. Rortos uses  analytics software to better understand the functionality of its  Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. Rortos does not link the information stored within the analytics software to any personal information you submit within the application.
  • Local Storage Objects. Rortos uses Local Storage Objects (LSOs) such as HTML 5 or Flash to store content information and preferences. Third-parties with whom Rortos partners to provide certain features on Rortos’s site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 or Flash to collect and store information. To manage Flash LSOs, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

3. How Information Is Used, Shared and Disclosed.

Rortos does not sell, and generally does not disclose, your Personal Information to third-parties without your consent. Parents have the right to consent to collection and use of personal information from their child without also consenting to its disclosure to third-parties, as Rortos does not share information that may be collected from your child. Rortos uses Personal, Non-Personal and Financial Information, among other things, to monitor system performance, analyze internal business systems, improve the Rortos Services, fulfill requests for additional products and services, contact you about promotional and marketing activities, provide customer support, and conduct research. The use and protection of information is an important component of Rortos’s business. Examples of how Rortos shares and discloses your information is as follows:

  • Legal. Rortos may disclose information you provide to respond to subpoenas, court orders, requests from authorities, and other legal process, and to establish/exercise Rortos’s legal rights. Rortos may also disclose your information to defend against legal claims when Rortos believes that disclosure is necessary to protect Rortos’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Rortos may share Personal Information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, violations of Rortos’s Terms of Use, or as otherwise required by law.
  • Business Transfers. As Rortos continues to develop its business, Rortos may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third-parties. In any of these types of transactions, any information you provide may be one of the transferred business assets (subject to any pre-existing privacy notice unless you consent otherwise). In the event that all or substantially all of Rortos’s assets are acquired or Rortos merges with a third-party, your information will likely be one of the transferred assets. You understand and agree that Rortos reserves the right to transfer any information collected from you in the case of any such transfer. In such event, Rortos will use reasonable efforts to notify you before Personal Information about you is transferred and becomes subject to a different privacy policy.
  • Affiliated Businesses We Do Not Control. Rortos may use third-party companies and individuals to perform functions on Rortos’s behalf. Examples include fulfilling orders, processing payments, hosting, data storage, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. Rortos will provide such entities with access to certain information needed to perform their functions, but will take measures to ensure that they may not use it for other purposes. Rortos shares information only as described above and with third-parties that are either subject to this Privacy Policy or to a privacy policy that is at least as protective as this Privacy Policy.

4. Security.

The security of your Personal Information is important to Rortos. Rortos follows generally accepted industry standards to protect the Personal Information submitted to Rortos, both during transmission and once it is received. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, Rortos cannot guarantee its absolute security. While no security system is completely secure, Rortos and its third-party partners and vendors take appropriate security measures to protect against unauthorized access or disclosure of the information collected by Rortos. For Rortos, this includes, but is not limited to, ensuring that all Personal and Financial Information is disclosed only on a “need to know” basis.

5. Advertising.

Rortos may use ads and ad-relating features in the Rortos Services. Such ads and ad-relating features may contain cookies that recognize your device each time you receive an online ad. This allows ad servers to compile information about your viewing and interaction with their ad and deliver targeted ads that they believe will be of most interest to you. This Privacy Policy does not cover the use of cookies by any advertisers, and Rortos encourages you to review the applicable advertiser’s website for their privacy policy. If Rortos uses pop-up ad windows irrelevant to the function of any of its games, you will be able to close the pop-up window.

Rortos has third-party ads in free versions of its applications and, provided that you are age 13 or older, Rortos collects your Device ID and may pass it to advertisers to enable certain advertising. Rortos does not store or otherwise save your Device ID.

6. Social Media Features and Tools.

The Rortos Services may include integrated social media features and tools, such as the Facebook “Like” button, the YouTube “Share This” button, and interactive mini-programs that run in the Rortos Services. These Features may collect information on your IP address, which page you are visiting on Rortos’s site, and may set a cookie to enable the Feature to function properly. Social media features and tools are either hosted by a third-party or hosted directly on the Rortos Services. Your interactions with these integrated social media features and tools are governed by the privacy policy of the company providing it.

7. Google+ or Other OpenID Provider.

You may be able to log in to some of Rortos’s applications using sign-in services such as Google+ or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with Rortos such as your name and email address to pre-populate Rortos’s sign up form.  Services like Google+ give you the option to post information about your activities on the Rortos website to your profile page to share with others within your network.

8. Links to Other Sites.

The Rortos Services contain links to other sites that are not owned or controlled by Rortos. Please be aware that Rortos is not responsible for the privacy practices of such other sites. Rortos encourages you to be aware when you leave Rortos’s site and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies only to information collected by the Rortos Services.

9. Access/Data Retention.

If you or your child’s information changes, or if you no longer desire the Rortos Services, you may make corrections and updates, delete inaccuracies, or request deletion or further contact with you or your child, by updating your account information or by contacting Rortos at info@rortos.com. Rortos will respond to your access request within 15 days.

Rortos will retain you and your child’s information for as long as you or your child’s account is active, or as needed to provide services. If you wish to cancel your child’s account or request that Rortos no longer use the information to provide services, contact Rortos at the email address listed above. Rortos will retain and use the information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

10. Special Notice REGARDING MINORS.

Rortos does not knowingly collect Personal Information from persons under the age of 13 without parental consent. Rortos requires device owners to specify their age before any Personal Information is collected. If it comes to Rortos’s attention that Personal Information has been collected from a person under the age of 13, Rortos will delete this information as quickly as possible. If you believe that Rortos may have Personal Information from or about a child under the age of 13, please contact Rortos at info@rortos.com.

11. Changes to This Privacy Policy.

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the Site. You are advised to review this Privacy Policy periodically for any changes.

12. Unity 3D.

To develop our game we us the Unity game engine. For their privacy policy:

https://unity3d.com/legal/privacy-policy

We use Unity Analytics to analyze how people play our games. This allows us to finetune our games so they are more fun. For Unity Analytics’ privacy policy:

https://unity3d.com/legal/privacy-policy and https://analytics.cloud.unity3d.com/terms_of_service

13. Contact Us.

If you have questions or comments regarding how Rortos protects your information or this Privacy Policy, please contact us at:

Attn: Privacy Policy Issues

E-mail: info@rortos.com

Rortos S.r.l.

Vicolo Santa Caterina 12B

Verona, 37122 Italy (IT)