Privacy Policy




TCM Inplay develops and publishes social games for the web and mobile devices. "TCM Inplay," or "we" or "us" refers to TCM Inplay. and the TCM Inplay Corporate Family in this Privacy Policy. The TCM Inplay Corporate Family means TCM Inplay's subsidiaries, parent companies, joint ventures and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors.


This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content, and/or the other domains provided by TCM Inplay, together referred to as "Services." This Privacy Policy describes:


•   what information we collect, how we collect it, and why

•   how we use that information and with whom we share it

•   how you can access and update that information

•   the choices you can make about how we collect, use, and share your information

•   how we protect the information we store about you

•   If you do not want TCM Inplay to collect, store, use or share your information in the ways described in this Privacy Policy, you may not play TCM Inplay's games or use TCM Inplay's Services.



TCM Inplay Limited is committed to protecting your personal information. This Privacy Policy lets you know what information we collect when you use our services, why we collect this information and how we use the collected information.



We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our platforms. We recommend that you revisit this Privacy Policy regularly. By using Our products you agree to changes to this Privacy Policy.





If you play TCM Inplay's games or access any of our other Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, TCM Inplay may receive certain information about you from the provider of the third-party application. The information we receive depends on the TCM Inplay game you're playing, the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.


For example, TCM Inplay may collect and store some or all of the following information shared by the provider of the connected third-party application:


•   your first and last name;

•   your profile picture or its URL;

•   your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;

•   the user ID number and other public data for your friends;

•   the login e-mail you provided to that third-party application when you registered with it;

•   your physical location and that of the devices you use to access our Services;

•   your gender;

•   your birthday and/or age range;

•   information about your activities on or through the connected third-party application;

•   other publicly-available information on the third-party application; and/or

•   any other information that you or the provider of the third-party application share with TCM Inplay.

•   If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application's Terms of Service and Privacy Policy.


If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.



Cookies and Automated Information Collection


We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:


•   cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;

•   web beacons, which let us know if a certain page was visited or whether an e-mail was opened;

•   tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively; and

•   local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.



We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:


•   IP addresses;

•   the type of computer or mobile device you are using;

•   your operating system version;

•   your mobile device's identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);

•   your browser types;

•   your browser language;

•   referring and exit pages, and URLs;

•   platform type;

•   the number of clicks on a page or feature;

•   domain names;

•   landing pages;

•   pages viewed and the order of those pages;

•   the amount of time spent on particular pages; and

•   game state and the date and time of activity on our websites or games.


In some cases, we will connect this information with your social network ID or TCM Inplay user ID.


For more information on how to limit the types of cookies you allow, please see Opting out of Cookie Tracking.


Other Information from Your Mobile Device

If you play TCM Inplay games on your mobile device, in addition to your device identifiers, we may also collect:


•   the name you have associated with your device;

•   your telephone number;

•   your country; and

•   your specific geolocation;

•   your mobile contacts (as further described below in "Information About Your Contacts"); and

•   information about TCM Inplay and other third-party apps you have on your device.



Information About You That You Share With Us Directly

When you use our Services (whether through a social network or through TCM Inplay directly), you may give us information directly (like when you're setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.


Some games or parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all of the following information:


•   your age or birthday;

•   your first and last names;

•   your e-mail address;

•   a password; and

•   other information that helps us make sure it's you accessing your account or helps us improve our services.


We may also let you create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other TCM Inplay players can see. Your player profile may include information like:


•   a profile photo;

•   game username(s);

•   your gender;

•   biographic details (like your age or age range);

•   approximate location information that you provide;

•   links to your profiles on various social network;

•   details about the games you play; and

•   a TCM Inplay player ID number that is created by TCM Inplay and used to identify your profile.


Certain information in your TCM Inplay profile may be publicly accessible on TCM Inplay's websites that offer direct access to TCM Inplay games, including:


•   The TCM Inplay player ID;

•   Your first and last names; and

•   Your player profile picture.


Information About Your Contacts


We may give you the ability to import your address book contacts or manually enter them so that you can locate your contacts on TCM Inplay and invite them to join you in our games or other aspects of our Services. You are responsible for getting your contacts' permission when you opt to give their contact details to us. We may also get information about you from other TCM Inplay users importing or entering their contacts. We use and may store this contact information to help you and your contacts connect through our Services. If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.


Payment Information


If you purchase a license to use in-game virtual currency or virtual items in a game you play on TCM, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information. TCM Inplay does not collect or store your financial information, like credit card numbers. However, TCM Inplay's payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. TCM Inplay may also obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies. Please note that purchases of third party credits or currencies may also be subject to those parties' policies.


Customer Support Correspondence


Except as provided herein, when you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your TCM Inplay player and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support and improve the Services. For users of our games designed for children under 13, we will use your contact information for the sole purpose of providing a one-time response to your question. We will then delete your information from our servers.


Information You Give Us For Text Messaging Services


We receive and store the information you provide, including your mobile telephone number, when you choose to sign up to receive SMS messages.


Other Sources


We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.





We may automatically collect certain data as discussed above and receive Personal Information about you where you provide such information through the services or other communications and interactions on Our website and applications. We may also receive Personal Information from online vendors and service providers, and from customer lists lawfully acquired from third-party vendors. In addition, we may engage the services of third-party service providers to provide technical support process your online transactions and maintain your account. We will have access to any information you provide to such vendors, service providers and third-party e-commerce services, and we will use the Personal Information as set out in this Privacy Policy below. This information will only be disclosed to third parties outside the company in accordance with this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online vendors protect your privacy.




We use the Personal Information we collect from you to deliver Our Services, to provide customer support, to undertake necessary security and identify verification checks, to process any of your online transactions, to assist your participation in third-party promotions, meet certain business requirements and for any other purpose related to the operation of the Services. As such, we may share your Personal Information with our carefully selected partners (including any other parties that have data sharing arrangements with the latter) always provided that we have entered into appropriate contractual arrangements with them that ensure that your Personal Information is duly protected.


Your Personal Information may also be used by us to provide you with: (1) promotional offers and information regarding our products and services; and (2) promotional offers and information regarding the products and services of Our partners, in order to enrich Our product portfolio and improve Our customer service. From time to time, we may request information from you via surveys or contests. Participation in such surveys or contests is completely voluntary and you have the choice to disclose or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age). By accepting any contest prize or winnings from us, you consent to use of your name for advertising and promotional purposes without additional compensation, except where prohibited by law. Unless you have elected not to receive promotional information, we may also use your Personal Information (including your email address and phone number) to provide you with information regarding Our products, services and promotions, including other products and products and services from third parties carefully selected by us.




We may disclose your Personal Information if required to do so by law, or if we believe in good faith that such action is necessary to: (1) comply with any legal proceedings officially required from Us, any of Our sites or the services or in circumstances where we are under a substantially similar legal obligation; (2) protect and defend Our rights or property; or (3) act to protect the personal safety of users of the services or the public. If, in Our sole discretion, you are found to have cheated or attempted to defraud Us, Our group companies or related businesses, or any other user of the services in any way including but not limited to game manipulation or payment fraud, or if We suspect you of fraudulent payment, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), We reserve the right to share this information (together with your identity) with other online gaming sites, banks, credit card companies, appropriate agencies and relevant authorities or other applicable bodies. (4) For the purpose of research on the prevention of addiction, data can be made anonymous and passed on to the respective institutions.





You may ‘opt out’ of receiving any promotional communications either by choosing to opt out via your account settings available on our sites or the services or in an email you receive from us, or at any time by sending an email, or by writing to our Customer Service.


In addition, You may contact us if you: 1) want to confirm the accuracy of the Personal Information we have collected about you; 2) would like to update your Personal Information; and/or 3) have any complaint regarding our use of your Personal Information. If requested, we will (1) update any information you have provided to us, in case you prove the necessity for such changes or (2) mark any information to prohibit future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy shall prevent us from retaining your Personal Information where we are required to do so by law.




Information placed on your device


When accessing our services, We may store information on your device. This information is referred to as cookies, which are small text files that are stored on your device when you visit online pages that record your preferences. We also use Local Shared Objects or ‘flash cookies. ‘Flash cookies’ are similar to browser cookies. They allow us to remember things about your visits across our sites. Neither cookies nor flash cookies can be used to access or use other information on your computer. We only use these methods to track your use of our services. Cookies help us monitor traffic to the site, improve our services and make it easier and/or more relevant for your use. We use flash cookies and third party cookies to help us show you more relevant and desirable advertisements.


Strictly necessary cookies


Strictly necessary cookies are essential to allow a user move around a website and use its features, such as accessing secure areas of the website or making financial transactions. Without these cookies, we would not be able to make our websites work efficiently.


During the registration process


These cookies will hold information collected during your registration and will allow us to recognize you as a customer and provide you with the services you require. We may also use this data to better understand your interests while online and to enhance your visits to our platforms.


On our website


For visitors to our website and app, we use cookies to collect information. Our servers use three different types of cookies:


•   A ‘session-based’ cookie: This type of cookie is only allocated to your computer for the duration of your visit to our website. A session-based cookie helps you move around our website faster and, if youre a registered customer, it allows us to give you information that is more relevant to you. This cookie automatically expires when you close your browser.


•   A ‘persistent’ cookie: This type of cookie will remain on your computer for a period of time set for each cookie. Flash cookies are also persistent.


•   An ‘analytical’ cookie: This type of cookie allows us to recognize and measure the number of visitors to our site /app, and monitor and analyse how visitors use our services. These helps us improve our product usability and efficiency.


You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, should you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.


•   Flash cookies: You can modify your Flash Player settings to prevent the use of flash cookies. The Settings Manager of your Flash Player allows you manage your preferences. To disallow flash cookies from all third party content go to the ‘Global Storage Settings’ panel of the Settings Manager and de-select the check box labelled ‘Allow third party flash content to store information on your computer’ and close the Settings Manager. Alternatively you can also adjust your settings for specific websites you visit through the ‘Website Storage Settings’ panel which is also found in the Settings Manager.


If you are using an old version of Flash Player or older web browser, the Settings Manager may not be available to you. We recommend that you ensure that you update your Flash Player and browser to the latest available versions.


If you choose to decline cookies, you may not be able to experience all of the interactive features on our sites.




In order to use Our services, you may be required to send money to and receive money from Us. We may use third-party electronic payment systems to process such financial transactions. By accepting this Privacy Policy, you expressly consent to Personal Information necessary for the processing of transactions including, where necessary, the transfer of information outside of your country. We take steps to ensure that our arrangements with payments systems protect your privacy.




We reserve the right to conduct a security review at any time to validate the registration data provided by you and to verify your use of the services and your financial transactions for potential breach of our Terms and Conditions and of applicable law. By using Our services and thereby agreeing to our Terms and Conditions you authorize us to use your Personal Information and to disclose your Personal Information to third parties for the purposes of validating the information you provide during your use of our services, including, where necessary, the transfer of information outside of your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third-party databases. In addition, to facilitate these security reviews, you agree to provide such information or documentation as we may request.




We understand the importance of security and the techniques needed to secure information. We store all of the Personal Information we receive directly from you in an encrypted and password-protected database residing within our secure network behind active state-of-the-art firewall software. We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures.




Personal Information collected on the services may be stored and processed in any country in which we or our affiliates, suppliers or agents maintain facilities. By using Our services, you expressly consent to any transfer of information outside of your country (including to countries that may not be assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.




The information that we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") such as Japan and the United States of America. We may use the storage facilities of third party suppliers (such as Amazon Web Services) for the purpose of storing your information and these facilities may also be located outside the EEA. Your information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers (such as Amazon Web Services) for the purposes set out in this Privacy Policy. By submitting your information on the Service, you agree to such transfer, storing or processing.


Find-a-Friend. Our Services may enable you to invite your friends who have an Account to join our website / app.


Contest. In order to invite friends with Accounts to join a Contest, you may either enter (1) your friends username associated with their account to find and locate them or (2) in the event you are using Our Application, use our contact importer tool to import and search through your contacts (including contacts in your address book) to match those of your friends who are also registered users of the Services. With your permission, we will access your address book, and import your contacts’ names, e-mail addresses, phone numbers, image, geographic location and any other information associated with your contact to facilitate automatic connection with your friends.


Information Collected from Other Sources


We may supplement the information we have about you with information received from other sources including from our pages on Social Networking Sites, the Social Networking Sites themselves, and from commercially available sources (e.g., data brokers and public databases). The information we receive may include demographic data such as age, gender and income level, your interests and purchase data and other information that is necessary or useful to assist our marketing efforts or for user verification, authentication, fraud detection or to comply with regulatory requirements.



Creation of Anonymous Data. We may create anonymized data (data that is not reasonably associated with or linked to any data that would reasonably be expected to allow someone to identify you or contact you) from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymized data to analyze request and usage patterns so that we may enhance the content of our Services and improve Website navigation. We reserve the right to use anonymized data for any purpose and disclose anonymized data to third parties for any reason.




We cannot ensure the protection of any information that you provide to a third-party online site that links to or from the services or any information collected by any third party administering our affiliate program (if applicable) or any other program, since these third-party online sites are owned and operated independently from us. Any information collected by these third parties is governed by the privacy policy, if any, of such third party.




The Services operate ‘AS-IS’ and ‘AS-AVAILABLE’ without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we cannot guarantee nor do we claim that there will be error-free performance regarding the privacy of your Personal Information, and we will not be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said Personal Information.




Your use of our services constitutes an agreement to our Privacy Policy.


This is our entire and exclusive Privacy Policy and it supersedes any earlier version. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable terms posted on our platforms. We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on our Platforms. Your continued use of our services following any changes to this Privacy Policy constitutes your acceptance of the changes. We recommend that you revisit this Privacy Policy regularly.




Email Communication. We will periodically send you free newsletters and emails that contain information about our various products and services, or other products and services we feel may be of interest to you. At any time you can easily indicate your preference to stop receiving further communications from us and you may opt out of receiving further marketing from TCM Inplay Limited by emailing us at support@TCM Inplay or by following the unsubscribe instructions provided in the email you receive. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use and privacy notice.


Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by editing your "personal information" within your Account or by sending an email to us at the address listed below. You may request deletion of your Personal Information by Us, and We will use commercially reasonable efforts to honour your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case We will comply with your deletion request only after we have fulfilled such requirements). When We delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or money laundering prevention or similar purposes.


Applications. You may stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.




You can request a copy of the personally-identifiable information that TCM Inplay Limited has collected about you via the Services by contacting our Information Privacy team at the e-mail address listed in the "How to Contact Us" section below. You may also request that TCM Inplay Limited correct any factual inaccuracies contained in this information by contacting this same person.


Stopping Use of Your Information


If you no longer want TCM Inplay to make active use of your information, you may send an e-mail to (link sends e-mail). Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within thirty days. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.


Opting Out of Geolocation

If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device's settings for the relevant application or the "settings" page for the relevant game.


Opting Out of Ongoing Collection of Information About Non-TCM Inplay Apps You Have On Your Device

To the extent that one of our games is collecting information about non-TCM Inplay apps you have on your device, the game will provide you with an option to stop making that information available to us in the "settings" page for the relevant game.


Opting Out of Promotional Emails from TCM Inplay

If you want to stop receiving promotional e-mails from TCM Inplay, click on the "unsubscribe" link in any promotional email from TCM Inplay or visit the e-mail preference page. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than ten business days.


Opting Out of Other Communications

You can opt out of receiving SMS messages (for example, text messages) by texting back STOP to the number we send the text from for that particular SMS message program. In some cases a preferences management page will also be available. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.


When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device's "settings" page.





If you would like to contact us for any reason regarding our privacy practices, our privacy notice, or if you want to report any security violations to us, please e-mail us at the following address:


TCM Inplay Limited.


========© 2017 TCM Inplay Limited All Rights Reserved.