Last Revised: March 01, 2019
TWO LINES, respects the privacy of users (including children) in their mobile applications and obliges to protect information about users.
1. Your consent
We do not knowingly collect any personal information from Kids other than as expressly specified in Sections 3.2 and 3.3 below.
We hereby prohibit Kids from actively and directly providing us with any personal information other than as specified in Section 3.3 below. If you are a legal guardian of a Kid and believe your child has provided us with any personal information, please contact us at firstname.lastname@example.org and we will delete such information from our servers.
TWO LINES may collect and maintain the information described in Section 3, directly or through certain products or services, solely for providing support for TWO LINES internal operations as permitted under applicable laws and rules (described in greater detail below).
We included an age-gate in certain Apps to prevent access to specific features to Users who did not pass the age gate for protection of Kids (e.g. restricting behavioral advertising, information sharing by Kids, or the option to accept push notifications).
3. Offline Use
TWO LINES allows an offline use (without Internet connection and without GPS enablement) of some features of its Kids Apps. Offline use of Kids Apps will preclude collection by TWO LINES and/or Third Parties of any information pertaining to the User and its use of the Kids Apps.
4. Online Use
There are three types of data and information which may be collected from Users of our Kids Apps:
3.1 Non-personal Information:
TWO LINES and Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such Kids Non-personal Information, TWO LINES and the Third Parties are not aware of the identity of the User from whom Kids Non-personal Information has been collected. Kids Non-personal Information collected by either TWO LINES or Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. iPhone), data regarding User behavior within Kids Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s gameplay (e.g. level reached, frequency and time spent in the Kids App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Kids Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), other TWO LINES Apps installed, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.
3.2 Kids’ Persistent Device Identifier and No Other Kids personal identifiable information:
TWO LINES and Third Parties may passively collect a persistent device identifier from Kids, such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address (“Kids’ Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Kids Apps. In the case of IP addresses, we use them for general data protection regulation (GDPR). TWO LINES do not save IP addresses and does not permit Third Parties to collect from Kids any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about the Kids. We note that TWO LINES may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.
TWO LINES does not link any additional personally identifiable information to the Kids’ Persistent Device Identifier, even from other services. TWO LINES does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Kids.
3.3 Information gathered through the Kids Apps “Ask a Question” or “Support” type of a feature:
3.1 Non-personal Information:
If a Kid e-mails a question to TWO LINES, using the “Ask a Question” or “Support” type of a feature which may be available within the Kids Apps, TWO LINES may respond to such question by using the Kid’s e-mail address. Promptly after responding (or, at TWO LINES discretion, not responding) to such question, TWO LINES will delete the Kid’s e-mail address.
Purpose of the collection:
The information described above is collected and processed solely for the purpose of supporting TWO LINES internal operations. This means the following:
- providing and improving Kids Apps as well as ensuring proper functioning of the Apps and services;
- maintaining or analyzing the functioning of the Kids Apps and services;
- authenticating Users (e.g. verify the User’s identity when he/she interacts with advertisements or acquires in-app purchases);
- personalizing content and enhancing User experience;
- performing network communications;
- protecting the security or integrity of Users, Kids Apps and services;
- serving advertisements;
- capping the frequency of advertising;
- ensuring legal or regulatory compliance;
- fulfilling a User’s request under Section 3.3.
The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.
How is the Information about our Users of Kids Apps being collected?
The Non-personal Information and Kids’ Persistent Device Identifier are collected either by TWO LINES or by Third Parties through the Users’ use of the Kids Apps, including through Third Parties’ SDKs embedded in our Kids Apps. Non-personal Information and the Kids’ Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Kids Apps, such as “cookies-like technology” and local storage (see Section 19 below for further details on Cookies and Local Storage).
5. Sharing Kids information with third parties
We may share the Kids’ Persistent Device Identifier only in limited cases, including the following:
1. To satisfy any applicable law, regulation, legal process, subpoena or governmental request;
3. To detect, prevent, or otherwise address fraud, security or technical issues;
4. To protect the rights, property, or personal safety of TWO LINES, its Users, suppliers, licensors, and/or licensees, or the general public;
5. When TWO LINES is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
6. Pursuant to the approval of a Kid’s legal guardian, in order to supply certain services that such legal guardian or the User of the Kids Apps may have requested from the Company.
To clarify, TWO LINES may transfer and disclose Kids Non-personal Information to third parties at its discretion.
In addition, TWO LINES may advertise other TWO LINES Apps within Kids Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random TWO LINES Apps.
7. Which information may be processed from Users of our TWO LINES Apps?
There are two types of information which may be processed about Users of our TWO LINES Apps:
7.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). TWO LINES and Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to TWO LINES and/or Third Parties through use by Users of the TWO LINES Apps. For details of the categories of data constituting Non-personal Information please refer to Section 3.1 above.
7.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.
Game Center Features: If a User enables Game Center Features (defined in our TOU: https://two-lines.ru/apps-terms-of-use.html) in TWO LINES Apps, then TWO LINES will be provided with access to the identifier number of the User’s Game Center account (i.e. access token).
In addition, TWO LINES may collect and/or process, directly or through Third Parties, the following Personal Information:
1. The User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;
2. The User’s persistent device identifier such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address. In the case of IP addresses, we use them for general data protection regulation (GDPR). TWO LINES do not save IP addresses. We note that TWO LINES may collect, use and provide access to the User’s advertising identifier in accordance with the applicable Platform Provider’s rules, policies and guidelines.
In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 18.
To clarify, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
TWO LINES does not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Users.
8. How is the Information about Our Users collected?
8.1 Non-personal Information may be collected through your use of the TWO LINES Apps. In other words, when you are using a TWO LINES App, TWO LINES and Third Parties are aware of it and may gather information relating to such usage, through the TWO LINES Apps, APIs or SDK embedded in our TWO LINES Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the TWO LINES Apps, such as “cookies” and local storage (see Section 17 below for further details with respect to Cookies and Local Storage).
8.2 Personal Information which you provide TWO LINES directly and/or through Third Parties via your installation and/or use of the TWO LINES Apps or your behavior to ads inside such Apps. This information is collected via the TWO LINES Apps or such Third Parties’ APIs or SDKs embedded in our TWO LINES Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the TWO LINES Apps, such as “cookies” and local storage (see Section 16 below for further details about Cookies and Local Storage).
8.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides TWO LINES through the Apps “Ask a Question” type of feature.
9. What are the Purposes of the Collection of Information?
Non-personal Information is collected in order to:
Use it for statistical, analytical and research or business intelligence purposes (e.g., to track trends within our TWO LINES Apps, for reports and for public relations purposes); and for customization, development and improvement of our TWO LINES Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on behavior and preferences shown by Users usage within the TWO LINES Apps).
- Measure traffic and usage on the TWO LINES Apps.
- Promote our Apps.
Personal Information is collected in order to:
- Personalize and enhance the Users’ experience while using the TWO LINES Apps.
- Improve the TWO LINES Apps.
- Provide the Users with personalized content and information, including customized ads, interest-based ads, targeted ads, etc.
- Enable certain ad serving features, such as frequency capping etc.
- Enable certain functionalities available within the Apps, for example in-app purchases.
- Ensure proper functioning of the Apps and services, respond to questions or requests which were provided using the “Ask a Question” feature.
- Enable the User to use the Game Center Features and Social Features.
- Provide Users with updated information regarding our products and services, including about competitions which we may hold, where Users have asked us to do so.
- To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User’s participation.
- Authentication purposes including to verify clicks and/or installs, verify User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.
- Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the User (i.e. behavioral ads).
- Send push notifications to the User’s device after the User agrees to accept push notifications from TWO LINES or Third Parties. Users can deactivate push notification by changing the settings within the App and/or changing the notification settings in accordance with the instructions of the operating system running on the Users’ device. Users may also opt out by clicking the “unsubscribe” option contained in the message.
- Any other purpose explained at the time of collection.
10. Sharing Information with other third parties
In addition to the sharing of Personal Information with Third Parties described in sections 7-9, we may share Personal Information in the following cases:
1. To satisfy any applicable law, regulation, legal process, subpoena or governmental request;
3. To detect, prevent, or otherwise address fraud, security or technical issues;
4. To respond to claims that any content published on the TWO LINES Apps violates any right of a third-party;
5. To protect the rights, property or personal safety of the Company, its Users, suppliers, licensors, licensees or the general public;
6. When the Company undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case your Personal Information may also be disclosed, transferred and/or assigned;
7. Pursuant to your explicit approval prior to the disclosure;
8. As part of a competition, receiving rewards or otherwise interact with our social media channels.
For clarity, TWO LINES may transfer and disclose Non-personal Information to third parties at its discretion.
Please note that some of the TWO LINES Apps include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. We do not access or use this User Generated Content in any way. It is stored locally on your device. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.
TWO LINES may promote TWO LINES Apps in Third Parties applications and platforms. In addition, TWO LINES may, at its discretion, advertise other TWO LINES Apps within the TWO LINES Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random TWO LINES Apps.
12. Using Game Center Features and Social Features
Our TWO LINES Apps may enable using certain Game Center Features and may include Social Features (defined in our TOU: https://two-lines.ru/apps-terms-of-use.html). The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”).
By using the Social Features and/or the Game Center Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby understand and agree that when you share content via Social Networks or Platforms your content may become public and any person may re-post-it.
13. Additional Terms and Conditions
14. Third Party Providers
15. The User’s compliance with Certain Additional Terms and Conditions
A User’s access to and use of the Apps (including use of Promotional Codes defined in TOU: https://two-lines.ru/apps-terms-of-use.html) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. TWO LINES does not exercise control of such third parties and is not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.
16. Links to third party sites
17. Cookies & Local Storage
18. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services
A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifier or limiting ad tracking setting. If you are using a Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent that such options exist) may not cease all tracking activities by TWO LINES Third Parties’ service providers.
If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such Third Parties and follow the instructions specified therein. If you wish to opt out of certain Unity Technologies Finland Oy’ personalized advertisements, please view Unity’s policies at: http://unity3d.com/legal/cookie-policy#cookies.
19. International Data Transfer
We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. We will take steps reasonably necessary to ensure the protection of your Personal Information (such as making transfers subject to standard contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. You can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.
20. California Privacy Rights
To the extent applicable, (i) California Civil Code Section 1798.83 may permit our Users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request please send an email to dev.gavrilovegor.@gmail.com. TWO LINES is only required to respond to one request per user each calendar year; and (ii) if you are a California resident under the age of 18 and a User, California Business and Professions Code Section 22581 may permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.
Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
21. Deletion and Modifications of Information
You or, as applicable, your legal guardian, may request, by sending us an email to email@example.com, the following:
1. To receive access to, amend, and/or delete your Personal Information and/or, as applicable, Kids’ Persistent Device Identifier, that we may hold, and/or that we cease collection or use of your Personal Information; and/or
2. That we request Third Parties who collected through the Apps the User’s Personal Information and/or, as applicable, the Kids’ Persistent Device Identifier, to do the same. TWO LINES will use reasonable efforts to ensure that such Third Parties do so.
We note that some of these actions may be done directly through the settings of your Account.
After you have stopped using the Apps and/or following the termination of your Account, we will retain User’s Personal Information, and, as applicable, Kids’ Persistent Device Identifier, collected through the use of the App for a reasonable period, as is necessary to fulfill the purposes for which it was collected, as those are specified above, including to comply with our legal or business requirements, to resolve disputes, prevent fraud, to enforce these Terms and our agreements and/or to enable Users to reinstate their Account, all as permitted under applicable privacy laws.
Personal Information that a User has shared using our TWO LINES Apps via any Social Network or third party Platform cannot be amended or deleted by TWO LINES, where such information is in the control of that Social Network or third party Platform. We note, however, that you can modify data that a Social Network or Platform shares with us, or stop our Apps interacting with that Social Network or Platform by adjusting your settings with that third party provider. However, should you choose to block such interaction, you may not be able to enjoy all the features of our Apps. Aggregate and/or anonymous information may remain on our servers indefinitely.
24. Got any Questions?