1. Introduction
Gtadatc LLC ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you play our game, Tower of Valor (the "Game").
The Game is a mobile game directed to users in the United States. By installing, accessing, or playing the Game, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Game.
2. Information We Collect
We collect information to provide and improve the Game. Depending on how you interact with the Game, we may collect:
2.1 Information You Provide Directly
Support Communications: When you contact us at gtadatc@outlook.com, we collect your name, email address, and any information you choose to provide.
2.2 Automatically Collected Information (via Online Features)
Even though the Game is single-player, its online components may automatically collect:
- Device Information: Hardware model, operating system version, device identifiers (e.g., IP address, advertising ID where applicable), screen resolution, and system language.
- Gameplay Data: Playtime, progress, achievements unlocked, high scores, save file metadata, and use of online features (e.g., leaderboard submissions).
- Performance & Crash Data: FPS, error logs, crash dumps, and technical performance metrics to help us fix bugs.
- Network Information: IP address, connection type (Wi-Fi/mobile), and approximate geolocation (at the country or city level, not precise GPS).
3. How We Use Your Information
- To operate and maintain the Game, including online features such as leaderboards, cloud saves, and achievements.
- To improve and optimize the Game, including fixing bugs, balancing gameplay, and enhancing performance.
- To authenticate your license and prevent cheating or fraudulent activity.
- To respond to your support requests and communicate with you about the Game.
- To comply with legal obligations, including responding to lawful requests from authorities.
- For internal analytics, such as counting active users and measuring feature popularity.
We do not use your information for targeted advertising or sell your personal data to third parties.
4. Children's Privacy - COPPA Compliance
The Game is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it immediately.
Protections for children under 13:
- We do not use incentives (e.g., "play to earn rewards") to encourage children to provide personal information.
- We collect only the information necessary to provide the core functionality of the Game (local saves and single-player features); we do not collect nonessential device information or analytics from children.
If you believe we have collected information from a child under 13, please contact us at gtadatc@outlook.com. We will delete the information within 48 hours.
Parent / Guardian Rights
You may contact us at any time to review, delete, or refuse further collection of your child's information. We may need to verify your identity.
5. Data Sharing & Disclosure
We do not sell, rent, or trade your personal information.
We may share your information in the following limited circumstances:
5.1 Service Providers
We engage third-party companies to perform services on our behalf, such as:
- Cloud storage providers (e.g., AWS and Google Cloud) for save files and leaderboards.
- Analytics providers (e.g., Unity).
- Customer support platforms.
These providers are contractually obligated to use your data only for the services they perform for us and to maintain its confidentiality.
5.2 Legal Compliance
We may disclose your information if required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Gtadatc LLC, our players, or others.
5.3 Business Transfers
If we are involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will notify you via email or an in-game notice.
6. International Data Transfers
Your information may be transferred to and processed in countries other than your own, including the United States (where we are based) and countries where our service providers operate. When we transfer data, we take steps to ensure that appropriate safeguards are in place.
7. Data Retention
We retain your information only as long as necessary for the purposes described in this Policy:
- Account data: For as long as your user account remains active.
- Gameplay data (leaderboard scores and achievements): Retained until you delete your account or request deletion.
- Crash logs & analytics: Typically stored for up to 90 days in accordance with our data retention schedule, which may be longer if required to comply with legal obligations, resolve disputes, or enforce our agreements.
- Support correspondence: Retained for up to 2 years after resolution of your request.
When you uninstall the Game, your local save files remain on your device; you must delete them manually. Your data stored on our servers (e.g., cloud saves and leaderboard entries) will be deleted in accordance with our retention schedule or upon your request.
8. Your Privacy Choices & Rights (US Users)
If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, or another state with comprehensive privacy laws, you have the following rights under laws such as the California Consumer Privacy Act (CCPA/CPRA):
8.1 Right to Opt-Out of Sale or Sharing
We do not sell your personal information. However, if you wish to limit our use of your data for certain analytics or targeted advertising purposes, you may request to opt out at any time by contacting us via email.
8.2 Right to Access and Portability
You have the right to request the categories and specific pieces of personal information we have collected about you. You may also request that we provide this information in a portable format.
8.3 Right to Deletion
You have the right to request that we delete the personal information we have collected from you, subject to certain exceptions (e.g., to complete a transaction, detect security incidents, or comply with legal obligations).
8.4 Right to Correction
You have the right to request that we correct inaccurate personal information we hold about you.
8.5 Right to Non-Discrimination
Exercising any of these rights will not cause us to deny you services, charge different prices, or provide a lower quality of service.
How to Exercise Your Rights
Contact us at gtadatc@outlook.com with "CCPA Request" or "US Privacy Request" in the subject line. We will verify your identity and respond within 45 days (extendable once by another 45 days). If you use an authorized agent to submit a request, we may require written permission from you.
9. Security Measures
We implement reasonable administrative, technical, and physical safeguards to protect your information, including encryption of data in transit (TLS) and at rest (AES-256). However, no method of transmission over the internet is 100% secure. You use the Game at your own risk.
10. Third-Party Links & Services
The Game may contain links to third-party websites (e.g., our official website and social media). This Privacy Policy does not apply to those services. We encourage you to read their privacy policies.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Game (e.g., a pop-up on launch) or via email.
12. Contact Information
If you have any questions or concerns about this Privacy Policy or our data practices, or wish to exercise any of your rights, please contact us at:
Gtadatc LLC
1715 15th St Ste 206, Boulder, CO 80302
Email: gtadatc@outlook.com