This Privacy Policy is designed to explain how our company, Towards Mars Limited, uses the personal data we collect from you when you use any Towards Mars game, application or any other digital content (hereinafter “TM Service”). The security of your personal information is important to us, and we want to help you feel more confident about the privacy and security of your information.

By using the TM Service, you agree to the collection and use of your personal information by us in accordance with this Privacy Policy. By using the TM Service, you agree and acknowledge that our partners may collect limited aspects of your personal data (such as online data) while you use the TM Service. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use the TM Service.

This Privacy Policy (together with our Terms and Conditions of Use) sets out the basis on which we process any personal information we may collect from you, or that you provide to us through the TM Service, as well as what personal data we collect and what are your data protection rights.

If you have any questions or suggestions regarding our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please contact us at: https://support.towardsmars.com. Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the corresponding Supervisory Authority of the Republic of Cyprus. The terms “We”/”Us”/”Towards Mars” when used in this Privacy Policy means Towards Mars Limited., and “you”/”your” means you as a user of any of our TM Service.

SECTIONS:

1.     Age Requirements

2.     Information We May Collect from You

3.     How We Use Your Information

4.     How We Share Your Information

5.     How and Where We Store Your Information

6.     How We May Use Cookies

7.     Links

8.     Advertisers and Marketing

9.     Keeping Your Account Secure

10.  Your Data Protection Rights

11.  Changes to Our Privacy Policy

 

1. AGE REQUIREMENTS

We do not knowingly collect personal information from children under 18 years of age. If you are under 18 years old, please do not provide any personal information to us.

2. INFORMATION WE MAY COLLECT FROM YOU

2.1 We may collect and process the following information about you:

2.1.1 information that you provide when registering online for our TM Service;

2.1.2 information that you publish on your user profile or which you post on in-game message boards. Please note that information that you voluntarily make public in your user profile, or which you disclose by posting comments will be publicly available and viewable by others. We do not hold any liability for any information that you voluntarily choose to be public through such and/or other explicit actions;

2.1.3 information that you authorize a third party (e.g., a social network such as Facebook) to share with us, such as your email address or other information that may identify you;

2.1.4 correspondence, or a record of it, if you should contact us;

2.1.5 customer surveys or feedbacks that you voluntarily complete;

2.1.6 statistical data about your browsing actions and patterns, which does not identify you.

3. HOW WE USE YOUR INFORMATION

3.1 We use information held about you for the below specific purposes:

3.1.1 to ensure that the TM Service is presented in the most effective manner for you and for your device;

3.1.2 to identify you when you use the TM Service;

3.1.3 to answer your questions and improve the TM Service;

3.1.4 to notify you about changes to our TM Service;

3.1.5 to provide you with updates and other information about special offers and new features of our TM Service we think you might like; and

3.1.6 for marketing purposes where you agree to this by not turning off this setting on your device (refer to your device settings) or withdraw your consent, by contacting us.

4. HOW WE SHARE YOUR INFORMATION

4.1 By using the TM Service you agree that we may share your personal information with third parties in the following circumstances:

4.1.1 for marketing purposes;

4.1.2 to other members of the Towards Mars Limited group of companies, our partners and service providers for the purpose of: managing or administering certain aspects of our TM Service; for analytics purposes; so that they may offer you their products and services and to help us develop new services;

4.1.3 to protect the rights, property or safety of us or other TM Service users;

4.1.4 where we are obliged, or permitted, to do so by law; or

4.1.5 if we (or substantially all of our assets) are acquired by a third party, in which case personal information held by us about our users will be one of the transferred assets. We may pass aggregated information to third parties about how our users use our TM Service but this will not include information which could be used to identify you.

5. HOW AND WHERE WE STORE YOUR INFORMATION

5.1 We take appropriate organizational and technical measures to protect the personal information that we hold. We limit access to your personal information to those persons required for the execution of the specific purposes as specified in Clause 3 above, to carry out their duties.

5.2 We take all possible measures to securely store your personal information in the territory of USA and the Netherlands. Your personal data is encrypted and stored under the password and any access to your personal data is limited.

5.3 We will keep your personal information for a period of at least 180 days since your last access to TM Service. Once this time period has expired, we reserve the right to delete your personal information.

5.4 The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us and for the specific purposes detailed in Clause 3 above, one of our associated companies and partners or a third party engaged by us. By submitting your personal information to us, you agree to such transfer, storing or processing.

5.5. The protection offered by the General Data Protection Regulation (GDPR) travels with the personal information, meaning that the rules protecting personal data continue to apply regardless of where the data lands. The processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law of the Republic of Cyprus. In any case, we will take all steps reasonably necessary to ensure that your personal information is treated securely at all times and in accordance with this Privacy Policy.

6. HOW WE MAY USE COOKIES

6.1 Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

6.2 We use cookies and similar technologies such as local storage within our apps to provide and optimize our TM Service. You can control which cookies you get and which you keep on your device through your browser settings. Unless you have adjusted your browser settings so that it will refuse our cookies, our system will issue cookies when you visit our website. However, if you do not accept cookies you may not be able to take advantage of many of the special features of the TM Service.

6.3 We use cookies to keep track of the pages you and other users have been to on our TM Service. Cookies enable to recognize you and remember important information that will make your use of our TM Service more convenient (e.g., by remembering your user preferences). This information could include what language you prefer and location you are in.

6.4 We also use cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

6.5 All of the major browsers offer tips and guidance for managing the cookies available on your browser. There are also lots of different third-party browser plugins and extensions available which you can download to make it easier to see and control your cookies.

6.6 You can find out more about internet advertising by visiting the following websites: www.allaboutcookies.org, www.yourchoicesonline.eu, and www.networkadvertising.org. Some of these sites enable you to opt out of online behavioral advertising and other tracking cookies (in addition to the control settings on your browser).

7. LINKS

Our TM Service may contain links to and from other websites and services. Our Privacy Policy applies only to our websites and we are not responsible for the privacy practices or the content of any third-party sites. Please check the individual privacy policy of any such websites or services before you submit any personal information to them.

8. ADVERTISERS AND MARKETING

8.1 We may from time to time use third party advertisers or sponsors on our TM Service. In the event that we do so we will not disclose identifiable information about individuals but we may provide them with aggregated information about our users. We may also use such aggregated information to help advertisers reach the kind of audience they want to target (for example, men in London). We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ and sponsors’ wishes by displaying their advertisement to that target audience.  

9. KEEPING YOUR ACCOUNT SECURE

9.1 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the TM Service, you are responsible for keeping this password confidential and you are responsible for any misuse of such information. You must change your password on a regular basis and must not share your password with anyone.

9.2 You are solely responsible for the security and confidentiality of your account. Please ensure that you do not allow anyone else to access the TM Service in your name and sign off after you have finished accessing your account.

9.3 You are responsible for all orders, and for the accuracy of all information, sent via the internet using your user ID, password or any other personal identification used to identify you on the TM Service.

9.4 You will be liable to us for all orders or transactions placed by use of your user ID and password, even if such use might be wrongful. We will not be liable to you for any loss that you may incur as a result of misuse of your user ID and password, and we accept no liability resulting from its unauthorized use, whether fraudulent or otherwise.

10. YOUR DATA PROTECTION RIGHTS

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – you have the right to request us for copies of your personal data. Your right of access can be exercised in accordance with the Republic of Cyprus Law on Legal Protection of Personal Data. Contact us at: https://support.towardsmars.com for details. We may charge you a small fee for this service.

The right to rectification – you have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – you have the right to request us to erase your personal data, under certain conditions. You acknowledge and agree that execution of your right to erasure leads to termination of your account in TM Service.

The right to restrict processing – you have the right to request us to restrict the processing of your personal data for marketing, analytics or other purposes and under certain conditions.

The right to object to processing – you have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – you have the right to request us to transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, or to “opt out” from collection of your information, please contact us at https://support.towardsmars.com.

11. CHANGES TO OUR PRIVACY POLICY

We occasionally modify our Privacy Policy and any changes we may make to it in the future will be posted on this page and, where appropriate, notified to you by e-mail or other message. This privacy policy was last updated on 01 February 2021.