Tooin Apps LLC (“Tooin Apps”, or “we”) supplies this Privacy Policy to advise you of our policies and procedures involving the collection, use and disclosure of private information we receive from users of our sites (collectively, the “Site”) as well as from users of any of our programs, whether on third party sites or as an application for mobile devices (together, the “Program”). The term “Services”, as used in this Privacy Policy, contain both the Program and the Website. This Privacy Policy applies only to information which you supply to us (or allow third party websites to supply us) or that we gather through the Services. Tooin Apps Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the main access points to the Services. You are advised to consult this policy regularly for any changes.
You’re consenting to our Processing of your information as set forth in this Privacy Policy and amended by us through the use of our Services. “Processing” means using cookies or information by any means, including, but not restricted to, gathering, saving and deleting, using, combining and revealing information and transferring it to the United States and internationally.
Information Collection and Use: Personally Identifiable Information You may supply personally identifiable information to us. Private Information includes, but isn’t restricted to, email and your name. We use your Private Information manage your questions and primarily to supply our Services.
If you select to buy any virtual goods within your use of the Services, to the extent available, we or our third party companies may collect information that is personal from one to allow your payment for such goods that are virtual.
In addition we gather other information which you supply in connection with your enrollment and/or use of the Services (e.g., without limit, birthday, sex, zip code (on its own), individual inclinations and specific information about your computer or mobile apparatus, such as operating system, software version and unique promotion identifier) (“Non-Identifying Info”). Specific Non-Identifying Information would be considered a component of your Personal Information if it were joined with other identifiers (as an example, joining your zip code with your street address) in a sense that empowers one to be identified. But the same bits of information are considered Non-Identifying Information when they’ve been taken alone or combined only with other non-identifying information (by way of example, your viewing preferences).
You may sign-up to use the Services directly via the Application or via certain third party social networking sites (each, a “Social Networking Site”). If you decide to create an account to use the Services via a Social Networking Site, we may extract the personal information you have provided to such Social Networking Site (such as your “real” name, email address and other information you make available via the Social Networking Site) from the account you have with such Social Networking Site and use that information to create your Tooin Apps account; the information we extract may depend on the privacy settings you have with the Social Networking Site.
If you choose to purchase any virtual goods as part of your use of the Services, to the extent available, we or our third party service providers may collect Personal Information from you to facilitate your payment for such virtual goods.
We also collect other information that you provide in connection with your registration and/or use of the Services (e.g., without limitation, birthday, gender, zip code (on its own), individual preferences and certain information about your computer or mobile device, such as operating system, software version and unique advertising identifier) (“Non-Identifying Information”).
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).
We also utilize Your Individual Information (in some instances, along with your Non-Identifying Information) to make contact with you with updates, advertising or promotional resources along with other information which may be of attention for you. Please follow the directions supplied in virtually any of the communications or revise your “user preferences” info should you choose anytime that you simply no further desire to obtain these communications from us. (View “Changing or Removing Info,” under.)
Log Data
When you use the Services, whether as a registered user or a non-registered user, for example in accessing our Services through a Social Networking Site, (any of these, a “Tooin Apps User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you visited before you came to the Service, pages of the websites involved in the Service that you visit, the time spent on those pages, information you search for, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the Service’s technical administration, to increase the functionality and user-friendliness of our Services, and to better tailor the Services to our visitors’ needs. For example, some of this information is collected so that when you use our Services again, it will recognize you and serve advertisements and other information appropriate to your interests, as described in more detail below. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Cookies
Like many websites, our Service uses “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We do not link the information we store in cookies to any Personal Information you submit while using our Services.
We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID and login password for future logins. Second, we utilize session ID cookies to enable certain features of the Services in order to better understand how you interact with the Services and to monitor aggregate usage by Tooin Apps Users and web traffic routing. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser.
We may participate in behavioral-based advertising services, meaning a third party may place a cookie on your browser, or use a web beacon, to collect information about your use of our application so that they can provide advertising about products and services tailored to your interest.  That advertising may appear either on our application, or on other websites.  You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. On mobile you can reset your settings by taking the following steps (for iOS:Opt out of interest-based ads in the App Store and Apple News and for Android: Block certain ads – Ads Help).  If you do not accept cookies, however, you may not be able to use all portions of the application or all functionality of our Services.
Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online.  At this time we do not modify your experience based upon whether such a signal is broadcast.
Information Sharing and Disclosure
Aggregate Information and Non-Identifying Information; Advertisers. We may share aggregated information that does not contain Personal Information and we may disclose Non- Identifying Information and Log Data with third parties for other purposes, demographic profiling and industry analysis.
In particular, we may determine to share Non-Identifying Info (including the promotion identifier currently associated with your device) and Log Data and other aggregated information with advertisers. Such information may be used to send you advertisements for services and products that are applicable to your own interests.
For example, we may collect and share the advertisements identifier associated with your device (such as the Apple IDFA and Android Marketing ID) with advertisers. We use the Apple IDFA exclusively as allowed by Apple, and we use the Android Marketing ID only as allowed by Google. A marketing identifier is assigned, and default on your own mobile device turns on, advertisement tracking. You may limit the use of or reset your marketing apparatus ID using the privacy settings on your cellular device; in some situations, you may have to reset the operating system to reset the advertisements device ID. We do not connect any of your private information with your marketing device ID without your consent (which may be given by you in our terms of use for a Program). Service Providers. We may use third party companies and individuals to facilitate our services, to supply our services on our behalf, to perform services linked to our Services (e.g., without limitation, care services, database management, web analytics and advancement of the site features) or to help us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to divulge or utilize it for another purpose.
Protection of Tooin Apps and Others. We may share personal information when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Tooin Apps, our products and services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Tooin Apps works with authorities and law enforcement officials and private parties to apply and comply with regulations.

Social Networking Sites.
 We may share the information in your Tooin Apps account profile (including your Private Information) with the Social Networking Sites you have linked to your Tooin Apps account to provide you with enhanced services. These third parties have access to your own Private Information only for this goal (unless they’ve received your Personal Information independently of the Tooin Apps service) and are obligated not to divulge or utilize it for any other purpose. In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.
Please see the privacy policy of the website or app where a Tooin Apps ad is shown for more information about its privacy practices and privacy choices it may offer.
Business Transfers. Tooin Apps may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information
By contacting us, all registered Tooin Apps users may review, update, correct or delete the Personal Information in their registration profile. If you completely delete all such information, your account may become deactivated. Please contact us if you would like us to delete your records in our system and if we do not have any legal obligation to retain the record, we will attempt to accommodate your request. See below for privacy contact information.
Security
Tooin Apps is concerned with safeguarding your information. We apply reasonable electronic, physical and administrative measures designed to help protect your information. No security, nevertheless, can eliminate the possibility we cannot guarantee your information will remain secure in all situations and your information may be accessed by an unauthorized third party.
We will make any lawfully required disclosures of any infraction of the security, confidentiality, or integrity of your unencrypted electronically stored “private information” (as defined in applicable state statutes on security breach notification) to you via email, mail, phone, or noticeable posting on our web site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to establish the extent of the breach and restore the reasonable integrity of the data system. We hold the right to select which approach we use to contact you about such an event.
International Transfer
Your information may be transferred to and maintained on computers found outside of your state, province, nation or other governmental authority where the privacy laws may not be as protective as those in your jurisdiction. In case you are located outside the United States and choose to supply us with information, Tooin Apps procedures it there and transfers Personal Information to the USA. Your agreement is represented by your consent to this Privacy Policy followed by your submission of such information to that transport.
Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
International Data Transfers
Tooin Apps is headquartered, incorporated in the United States, with servers based in the United States. Information we collect from you will be processed in the United States. When we transfer EU subject’s personal information to third parties outside of the European Economic Area (EEA), we rely on the appropriate safeguards or specific derogations recognized under the EU data protections law, including the GDPR. The European Commission has adopted standard data protection clauses, which provide safeguards for Personal information transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal information from a country in the EEA to a country outside the EEA.
EU Data Subjects Privacy Rights
EU data subjects have certain rights with respect to the personal information that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal information. You can often go directly into the Service under Account Settings to take these actions. Please note that even if you request for your personal information to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in the Section titled “Data Retention”, above.
You may object to processing of your personal information on the grounds that you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes.
You have the right to ask us to suspend the processing of your personal information.
You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent. If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information.
To file a request or take action on one of your rights, please contact us at the contact details provided. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Policy Regarding Children

Tooin Apps is committed to complying with the laws protecting the privacy of children, including the United States’ Children’s Online Privacy Protection Act (COPPA) Our Services are not directed to children under 16. We do not intentionally collect personally identifiable information from children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their permission, he or she should contact us at privacy@tooinapps.com. If we become aware a child under age 16 has provided Private Information to us, we’ll delete such information from our files. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

Phishing
Identity theft and the practice currently known as “phishing” are of great concern to Tooin Apps. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, please visit the Federal Trade Commission’s website.

Links to Other Sites
Our Services may provide links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or clicking on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise any control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Marketing and Advertising Practices
We may reach out to you in different ways, for example, to tell you about new features, games, or sweepstakes on the App we think you’d be interested in, or to show you how to use a particular feature we think you may enjoy. However, you can also let us know that you’d rather not hear from us with this type of communication.

Promotional Offers from Tooin Apps

We may use any of the categories of personal information we collect to make decisions about what we think you may desire or need as our customer. We will only make these marketing decisions if you agree to receive email marketing from us. In all cases, we allow you to opt-out of receiving marketing communications from us.

Interest Based Advertising
. Tooin Apps uses advertising to help fund our services and we utilize numerous advertising technology platforms to help deliver relevant advertising to you. Tooin Apps and our technology service providers may collect, receive, or use your personal data in connection with our use of the platform in order to provide interest-based advertising to you. In such cases the advertiser is acting as a controller of the data for its own purposes.

Most of the third-party advertising and data companies we work with subscribe to the DAA Principles and/or are members of the Network Advertising Initiative (“NAI”). To learn more about the information collection practices of NAI members and your related opt-out choices, please visit the NAI’s website here. For more on EU online choices, please visit the EU online choices website here. You can opt out of interest-based advertising from Google by visiting the About Google Ads page or opt out of the DoubleClick cookie by installing the DoubleClick opt out extension. For information about how Google uses data from DoubleClick for Publishers, click here.

Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertisers include the following:
AdColony: https://www.adcolony.com/privacy-policy/
AdMob: https://policies.google.com/privacy
AppLovin: https://www.applovin.com/privacy/
Facebook: https://www.facebook.com/about/basics/advertising
InMobi: https://www.inmobi.com/privacy-policy
Unity: https://unity3d.com/legal/cookie-policy#cookies
Verizon: https://www.verizon.com/about/privacy/about-our-ads
Vungle: http://vungle.com/privacy


Mobile App Advertising and Tracking.
Tooin Apps, our authorized service providers and/or other third-party partners (listed above) involved in the delivery of advertising you receive through our App may collect information about your mobile device, including your mobile device’s advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. Tooin Apps and our partners use this information to enable interest-based advertising you receive through our Services and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device’s advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions. Visit the privacy settings for your mobile device for more information.

In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser. Please see the privacy policy of the website or app where a Tooin Apps ad is shown for more information about its privacy practices and privacy choices it may offer.

CCPA
To the extent Tooin Apps receives personal information on your behalf that is subject to the CCPA, Tooin Apps: (a) certifies that it understands and will comply with its obligations as a service provider under the CCPA, and (b) will not retain, use, or disclose such personal information other than for the specific business purpose of performing the services for customers as contemplated under this Privacy Policy or as otherwise permitted by the CCPA.

California Privacy Rights (Under California Civil Code Section 1798.83)

California residents have the right to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed certain types of personal information (if any) for their direct marketing purposes in the prior calendar year. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes. You can read these instructions above in the “Marketing and Advertising Practices” section of our Privacy Policy. Or, if you are a California resident and prefer that we send you a separate response, please email your request to privacy@tooinapps.com. At this time, our Website does not respond to browser “Do Not Track” signals.

Changes to our Privacy Policy
By using this website and/or Tooin Apps apps, you agree to the terms and conditions contained in this Privacy Policy and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website. You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California. You also agree to arbitrate such disputes in California, and to abide by any limitation on damages contained in any agreement we may have with you.
This Policy is expected to change from time to time. We reserve the right to amend this Privacy Policy at any time and provide notice to you by posting the amended Privacy Policy on the website. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of these Services.
Contact Us
If you have any questions or wish to register a complaint in relation to this Privacy Policy or the manner in which your personal information is used by us, please contact us by any of the following means:
Tooin Apps LLC
2440 Amsterdam ave, 4F
New York
NY 94104-5401
Attn: Privacy Department
Or:
privacy@tooinapps.com
Copyright 2020 © Tooin Apps LLC | All Rights Reserved
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