Privacy Policy
TurnPals is a product of Tobistech Ltd, a company registered in England and Wales. This Privacy Policy explains how Tobistech Ltd (“TurnPals”, “we”, “us” or “our”) collects, uses, shares and protects your personal data when you use the TurnPals apps, website and services (the “Service”), and the rights you have. It applies to players worldwide. By using the Service you also agree to our Terms of Service. For privacy questions, contact us at contact@tobistech.co.uk.
1.Who we are
Tobistech Ltd is the controller responsible for your personal data under this Policy. Our registered address is 82 King Street, Manchester, M2 4WQ, United Kingdom. You can reach us at contact@tobistech.co.uk.
2.Data we collect
Information you give us
- Account & profile: name/username, email address, password (stored only as a secure hash), avatar, and preferences. If you join the waitlist you may also provide a phone number (optional), country and platform preference.
- Social & gameplay content: chat and voice-room messages, gifts, friend/pal connections, reports you submit, and support enquiries (including any attachments).
Information we collect automatically
- Device & technical: device model, operating system, app version, language, approximate location inferred from IP address, IP address, and identifiers needed to run the Service.
- Gameplay: matches, moves, results, ratings, coin balances and transactions, streaks, missions, achievements, tournaments and event participation.
- Usage & diagnostics: in-app activity/analytics events, feature usage, and crash/error logs used to keep the Service working and improve it.
- Push tokens: a device push token so we can send notifications you’ve enabled (e.g. your turn, streaks, tournaments).
Voice rooms
When you join a voice room, your audio is transmitted in real time to other participants through our voice infrastructure provider so you can talk during play. We do not sell your voice audio.
Purchases
When you buy Coins or a subscription, the purchase is processed by the Apple App Store or Google Play and our subscription provider. We receive purchase and entitlement information (such as product, status, receipt/order identifiers and renewal state) - we do not receive or store your full card number.
3.How we use your data
- Create and manage your account, and provide the games, matchmaking, leaderboards, ratings and social features.
- Operate the coin economy, rewards, waitlist, referrals, purchases and subscriptions, and credit reserved rewards.
- Enable voice rooms, chat, gifting and pal connections.
- Keep players safe: prevent and detect cheating, fraud, abuse and violations of our Terms; moderate content and handle reports.
- Send service messages and, where enabled, push notifications; respond to your support requests.
- Measure and improve the Service, debug problems, and develop new features.
- Show advertising to non-premium players (see section 6) and measure its performance.
- Comply with legal obligations and enforce our Terms.
4.Legal bases (EEA/UK users)
Where the GDPR or UK GDPR applies, we rely on these legal bases:
- Performance of a contract - to provide the account, games and features you request.
- Legitimate interests - to secure the Service, prevent cheating/fraud, measure and improve the Service, and support non-personalised advertising, balanced against your rights.
- Consent - for push notifications, optional phone/marketing messages, personalised advertising and tracking where required. You can withdraw consent at any time.
- Legal obligation - to comply with laws and lawful requests.
6.Advertising & tracking
- Non-premium players may see ads, including optional rewarded ads. Ads are provided by Google Mobile Ads (AdMob).
- On iOS, we ask for your permission (App Tracking Transparency) before any tracking used for personalised ads. If you decline, you will still see ads, but they will be non-personalised.
- You can reset or limit your advertising identifier in your device settings, and manage Google ad personalisation in your Google account.
- A premium subscription removes ads.
7.International data transfers
We operate globally, so your data may be processed in countries other than your own, including countries whose data-protection laws differ from yours. Where we transfer personal data out of the EEA, the UK or other regions with transfer rules, we use appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) or reliance on an adequacy decision. Contact us for more information.
8.How long we keep data
We keep personal data for as long as your account is active and as needed to provide the Service, then for a reasonable period afterwards to comply with legal, tax, accounting, security and dispute-resolution needs. Some records (for example, purchase and anti-fraud records) are kept longer where the law requires. When data is no longer needed we delete or anonymise it.
9.Security
We use technical and organisational measures to protect personal data - including encryption in transit, hashed passwords, access controls and rate limiting. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Keep your login details private and use a strong, unique password.
10.Your privacy rights
Depending on where you live, you may have some or all of these rights:
- Access a copy of your personal data.
- Rectify inaccurate or incomplete data.
- Erase your data (“right to be forgotten”), including by deleting your account.
- Restrict or object to certain processing, including profiling and direct marketing.
- Portability - receive your data in a portable format.
- Withdraw consent at any time where we rely on consent.
- Complain to your local data-protection authority.
To exercise these rights, use in-app settings where available or email contact@tobistech.co.uk. We may need to verify your identity, and we will respond within the time required by applicable law. Exercising your rights will not lead to discriminatory treatment.
11.US state privacy rights
If you are a resident of California or another US state with a privacy law, you may have the right to know, access, correct and delete your personal information, and to opt out of “sale” or “sharing” of personal information and of targeted advertising. We do not sell your personal information for money. Certain advertising activity may be considered “sharing” or “targeted advertising” under some state laws; you can opt out via the App Tracking Transparency prompt on iOS and your device/Google ad settings, or by contacting us. To exercise your rights, email contact@tobistech.co.uk. You may use an authorised agent, and we will not discriminate against you for exercising your rights.
12.Children
The Service is intended for adults aged 18 and over. It is not directed to children, and we do not knowingly collect personal data from anyone under 18. If we learn that we have collected personal data from a person under 18, we will delete it. If you believe someone under 18 has provided us personal data, contact contact@tobistech.co.uk and we will take appropriate steps to remove it.
14.Changes to this Policy
We may update this Policy from time to time. If we make material changes we will take reasonable steps to notify you (for example, in-app or by email) and will update the “Last updated” date above. Please review it periodically.
15.Contact us
For any privacy question or request, contact
contact@tobistech.co.uk
or visit our Support page.
Tobistech Ltd, 82 King Street, Manchester, M2 4WQ, United Kingdom.