Last Updated: July 28, 2022
California Users: We do not sell personal information.
Roaring Tiger Software LLC, a Georgia limited liability company (“Roaring Tiger,” “we,” “us,” and “our”), provides this privacy notice (“Privacy Notice”) to explain how we or others collect, use, store, and share information about individuals in two different contexts (we refer to such individuals as “you,” “your,” and “yourself”): (1) visitors to this website located at roaringtiger.net and any other website on which this Privacy Notice is allowed to be posted or linked (such individuals, “Visitors”, and such websites collectively, the “Site”); and (2) End Users of Roaring Tiger’s owned and operated mobile applications (“Roaring Tiger apps” or “Apps”). This Privacy Notice also explains how we enable certain third parties to collect information directly from End Users of our Apps, as well as certain choices you may have regarding how we use information about you and rights you may have to access or correct such information.
If you are located in the European Economic Area (EEA), Switzerland or the United Kingdom and would like to review your rights under the EU GDPR or the UK GDPR (collectively referred to in this Privacy Notice as the “GDPR”), please go to Section 5 of this Privacy Notice. If you are a California resident, you may review your rights under the CCPA at Section 7 of this Privacy Notice.
Below, we explain certain terms that we will use in this Privacy Notice that may make it easier to understand:
● SDK or Software Development Kit: An SDK is a block of computer code owned by certain Third Party Data Collectors that we can integrate with our apps to enable those Third Party Data Collectors to collect certain data, which is often useful to the mobile advertising and other data industries.
● Third Party Data Collector: A third party that (1) owns or operates an SDK that is integrated with one or more Roaring Tiger Apps and (2) directly collects information from End Users of the Apps through integration of such SDK.
● Visitors: Individuals who visit or use our Site.
● End Users: Individuals who download and use one or more of the Roaring Tiger Apps on their Device.
● Devices: Internet-connected mobile devices such as Apple iPhones that use iOS or Samsung Galaxy devices that use Google’s Android OS.
● Roaring Tiger Apps or Apps: Mobile applications owned and operated by Roaring Tiger, including CFS.
● Advertising ID: A unique alphanumeric string randomly assigned by operating system manufacturers to each Device. Advertisers may use this ID to serve your Device more personalized advertising. Examples of Advertising IDs include iOS IDFAs and Android Advertising IDs.
● App Tracking Transparency/Opt-Out of Interest Based Ads: Features on iOS or Android Devices that allows users to disable or limit the Apps’ ability to access the Advertising ID on your Device.
Roaring Tiger’s primary business is the ownership and operation of mobile applications. We also maintain websites related to the mobile applications that we offer. As described further below, we typically do not collect any personal information from End Users of the Roaring Tiger Software but we do facilitate collection of such information by Third Party Data Collectors. Additionally, we may collect certain personal information that Visitors to our Site may choose to provide.
A. Information We Collect Through Our Apps
We do not directly collect personal information from End Users of our Apps. However, we may collect or receive certain aggregated, deidentified, or anonymous data related to usage of our Apps, primarily for the purpose of troubleshooting problems, reviewing how our Apps are being used by End Users, and other analytical or internal purposes. A full description of our use of this data can be found in Section 4 below. Additionally, we enable certain third party vendors to collect aggregated, deidentified, or anonymous information regarding usage of our Apps for the purpose of providing analytic reports to us, e.g., regarding the frequency and cause of one or more Apps crashing.
B. Information Third Party Data Collectors Collect Through Our Apps
■ App or system crashes
■ System crashes
■ Type of device (e.g., Samsung Galaxy S21)
■ Operating system (OS) information (e.g., iOS 14.5)
■ IP address
■ User agent (i.e., a characteristic string that lets servers and network peers identify the application, operating system, vendor, and/or version of the Device)
g. Network Information
The Third Party Data Collectors who collect information through our Apps may use such information in the manner set forth in their respective privacy policies. Generally, these Third Party Data Collectors may use information collected from or about End Users or Devices to (a) to customize and measure ads in apps and other advertising; (b) for app and user analytics; (c) for disease prevention and cybersecurity; (d) for market, civic or other research regarding aggregated human foot and traffic patterns; and (e) to generate proprietary pseudonymized identifiers tied to the information collected for the above purposes.
D. Information Roaring Tiger Collects from Site Visitors
Visitors can generally browse our Site without submitting any information. However, Visitors may choose to submit information via a “Contact Us” form, through our support email addresses (including support@roaringtiger.net and privacy@roaringtiger.net), or other voluntary means (such as submission of a request to exercise rights under applicable privacy laws). We only collect the information that Visitors choose to provide. Please see Section 2.E below for a description of how we use such information.
We may use information we collect about Visitors to our Site or End Users of our Apps for our corporate and internal purposes, including:
As stated previously, we only collect (1) information that Visitors to our Site choose to provide and (2) aggregated, deidentified or anonymous information related to usage of our Apps (which information does not identify an individual End User or Device). We may share such information with other parties, as follows:
○ We may share information we have collected when we have a legal obligation to do so. This may include compliance with a binding court order, exercising, establishing or defending Roaring Tiger’s legal rights, or those of our customers or any other third party, or in good faith to comply with the requirements of any applicable law or legal process.
○ Similarly, we may disclose any information we have collected as required to respond in good faith to legal process, including subpoenas (whether civil or criminal), court orders or search warrants.
○ We may share information to assist us in enforcing our legal rights, our Terms of Service, or other policies as applicable, or to investigate any potential violation of the same. We may also share information to investigate any potential violations of the law, to defend ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
○ If a third party seeks to acquire or actually acquires our business or assets in whole or in part, we may disclose information we have collected in connection to that transaction (including, without limitation, during due diligence that may be undertaken in advance of possible sales).
The Third Party Data Collectors who collect information through our Apps may share the information as described in their own privacy policies. Please see Section 2.C for instructions on how to access such privacy policies.
You can manage the way that we and third parties use information collected from or about you as described below:
For iOS devices:
● Go to Settings > Privacy > Advertising
● Turn on Limit Ad Tracking
For Android devices:
● Go to Settings > Google Settings > Ads
● Depending on your Device, either turn off Ad Personalization or turn on Opt Out of Interest-Based Ads
We use commercially reasonable administrative, technical, and physical safeguards to protect our physical infrastructure as well as in our computer systems, databases, and communications networks. These measures are intended to protect our systems (and the information contained therein) from loss, misappropriation, misuse, alteration or disclosure. No method of electronic transmission or storage is perfectly secure, however, so we cannot guarantee the security of information we collect with absolute certainty.
Information we and our authorized third parties collect may be stored and processed by us in the European Union, the United Kingdom, and the United States. When you use the Site or our Apps, the information we collect may be stored in or (if applicable) transmitted to the United States. Privacy laws in the United States and laws in certain other countries regarding the processing of personal information may not be as robust as those in your country.
GDPR is a data protection law that applies to individuals located within the European Economic Area and Switzerland (under the EU GDPR) and in the United Kingdom (under the UK GDPR). Pursuant to the GDPR, we are required to provide certain information about the processing of “Personal Data” of users in European Economic Area, the United Kingdom, and Switzerland who choose to provide such information when visiting our Site. “Personal Data” generally refers to data that identifies or is capable of identifying a particular person directly or indirectly though their Device. Names, addresses, cookie IDs, Advertising IDs, and precise location information are common examples of “Personal Data.”
If you have any questions about Roaring Tiger’s data practices in the context of the GDPR, you may contact our Data Protection Officer by emailing your questions to privacy@roaringtiger.net.
The representations and information we provide below, which are applicable only to individuals located in the EEA, the UK and Switzerland, are provided for purposes of compliance with the GDPR. Please do not rely on the information below if you are not located in one of those regions. All capitalized terms used in this Section but not defined elsewhere in this Privacy Notice have the means set forth in the EU GDPR or UK GDPR, as applicable.
○ Legitimate interest. We may rely on legitimate interest as a legal basis for processing Personal Data in some cases. We may do so when we use Personal Data for purposes of maintaining the security of our services (including to detect and prevent fraud or to facilitate the detection and correction of bugs or other errors) or use Personal Data provided by Site Visitors to respond to their inquiries. We also rely on legitimate interest when we analyze user activity on our Site or Apps.
○ Contractual Agreements. In some cases our basis for processing Personal Data is that the processing is necessary pursuant to a contractual relationship we have entered into.
○ Legal Obligations. We may process Personal Data when it is necessary for us to comply with our legal or regulatory obligations.
○ How We Retain Personal Data: We generally retain Personal Data we collect for as long as is necessary for compliance with our legal obligations, dispute resolution, and to enforce our contracts. We may also retain information insofar as we have a legal or operational need to do so, for example, for purposes of auditing, corporate record-keeping, legal compliance, accounting, security and bug-prevention purposes.
○ Right to Access: You may contact us at privacy@roaringtiger.net in order to exercise your right to access Personal Data we process as a data controller. We will respond to your request by explaining the steps you must follow to access your Personal Data after we receive your request. Because we are required to verify the identity of the individual making a request before we provide access to Personal Data, we will evaluate requests to exercise certain rights to access Personal Data on a case-by-case basis. In conducting this evaluation, we may consider both (1) the effort involved in verifying whether Personal Data that we process actually pertains to the data subject making the request – and only to that data subject; and (2) any potentially negative consequences that may result from erroneously releasing Personal Data to an individual other than the data subject. We may also limit the amount or kind of Personal Data we will release in circumstances where we believe it is likely that the improper release of Personal Data would adversely affect the privacy rights and freedoms of the data subject. We will only honor requests for access to Personal Data for which we act as a data controller, as explained more fully in sub-section (d) below. Where we act as a processor for Personal Data on behalf of another entity (for example, our customers), you may contact that company instead of Roaring Tiger to make a data access request.
○ Right to Correct: You may exercise your right to correct Personal Data by contacting us using the contact information provided below.
○ Right to Withdraw your Consent or Object to our Personal Data Processing: You may use the opt-out methods described in Section 6 of this Privacy Notice to withdraw your consent for our processing of your Personal Data (when we are relying on your consent). If you withdraw your consent, we will stop processing your Personal Data within 30 days or fewer.
○ Right to Request Deletion: You have the right to request that we delete Personal Data concerning you that we process as a controller. If you use the opt-out process described above, we will also delete your Personal Data. You may also contact us at privacy@roaringtiger.net to request that we delete your Personal Data. We will provide further instructions on how you can exercise your right to deletion after we receive your email request. In certain circumstances we may keep copies of Personal Data in back-up files (or otherwise in inactive form), for certain of our internal purposes that are important to our business, including legal, auditing, accounting and billing, bug-detection and correction. We may keep such backups for as long as is necessary to fulfill those purposes.
○ Right to Make Complaints: You have the right to lodge a complaint regarding our processing of Personal Data with a relevant data protection authority. If you have a complaint, please contact us first to allow us to assist you in resolving it.
We do not intend for our Site or Apps to be used in connection with minors under the age of 16, and we do not intentionally collect data from them. If you believe that we may have inadvertently collected of any such data, please use the contact information provided in Section 9 below to let us know.
California residents have certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) with respect to their personal information. “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. If you are a California resident, this section of the Privacy Notice applies to you insofar as we have collected personal information about you (e.g., if you are a Visitor to our Site and submitted a “Contact Us” form that included your personal information). If you are not a California resident, you should not rely on the information we provide in this section as it does not apply to you. The information we provide here supplements the information we provide in the other sections of this Privacy Notice.
As required by the CCPA, we describe the personal information we collect about California residents, and the purposes for which we may use it, in the following sections:
A. Categories of Personal Information We Collect; How We Use It; and How We Share with Third Parties
We may collect the categories of personal information about you described below. The table also describes the categories of third parties with whom we may share the categories of Personal Information specified. You may exercise your Right to Access in connection with any of the Personal Information Categories in the table below.
|
Personal Information Category |
Information Sources |
Categories of Third Parties with whom this Personal Information is Shared |
|
Identifiers (including name, email address, Advertising ID, and other information you choose to submit, whether in connection with visiting our Site or submitting a request to exercise your rights under the CCPA) |
Visitors to our Site; individuals that submit a request to exercise rights under the CCPA |
Our affiliates |
|
Internet or Other Electronic Network Activity Information (e.g., information regarding a consumer or device’s interaction with a website or application) |
Visitors to our Site |
Our affiliates |
B. Business Purposes for Collecting and Sharing Personal Information
Our purposes for collecting and sharing Personal Information are described below (with examples). These details are also described in our Privacy Notice:
● To Operate Our Site and Apps. We use personal information to:
a. Enhance, test, update, and verify our own data and data-related services;
b. Develop new products or services; or
c. Operate, analyze, enhance, and secure our services.
● Other Internal Business Purposes.
a. Internal Research/Compliance: We use personal information for internal research or operations, auditing, detecting and responding to security incidents, debugging, short-term and transient use, quality control, and legal compliance. Information we collect from our Site and Apps may be used for this purpose, among others.
b. Sharing for Purposes of Legal Compliance: We may share personal information with third parties for purposes of: (1) compliance with official legal process or a regulatory investigation (for example, a valid subpoena or court order); (2) enforcing our Terms of Service, this Privacy Notice, or other agreements, including investigation of suspected violations of the same; (3) responding to claims that certain content violates the rights of third parties; or (4) protecting the rights, property or personal safety of us (or our platform), our Clients, our affiliates, our agents, our platform users, or the general public. Similarly, we may share personal information with other entities to detect or prevent fraud, to prevent spam or malware, or other similar purposes.
c. Sharing In Connection With a Corporate Transaction: In the event of a major corporate transaction (such as a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets), we may share personal information in connection with that transaction, including for purposes of associated due diligence.
d. Sharing With Our Service Providers: We may share any personal information we collect with our service providers. Our service providers may include, for example, providers of: technology; support for our Clients; business operations; web or database hosting; billing; accounting; physical or information security; marketing and advertising; data management, validation, enhancement or hygiene; or providers that otherwise assist us with providing, developing, maintaining, or improving our Services.
e. Aggregate Information: We may use personal information to create aggregate information, or may de-identify any personal information we collect to make it such that it cannot be linked to you or your device (“Aggregate or De-Identified Information”). We may use Aggregate or De-Identified Information for any purpose, including, but not limited to, for research and marketing purposes. We may also share Aggregate or De-Identified Information with third parties, who may include advertisers or marketers, promotional partners, our sponsors, or otherwise at our discretion.
C. Rights and Choices under the CCPA
Pursuant to the CCPA, California residents have the right to request (1) that we disclose what personal information we collect from you; (2) to delete such information; and (3) to opt out of our sale of their personal information. These rights are subject to certain limitations, although you will not be discriminated against for exercising any of these rights. In certain circumstances, we may request additional information from you to verify your identity and/or charge a reasonable fee to process your request, to the extent permitted by law.
○ California residents may opt out of the “sale” of their personal information. We do not “sell” personal information, as defined by the CCPA. However, certain of our authorized third parties that directly collect End User information may sell information. You can exercise your right to opt out of such sale by visiting the applicable third party’s privacy policy. Please see Section 2.C above for information on how to access each third party’s privacy policy.
○ If we have collected personal information from you, you may request that we delete such personal information. A request to delete is distinct from a request to “opt out” of our sale of your personal information. You may contact us via email at privacy@roaringtiger.net
○ If you choose to exercise your right to deletion, there are certain circumstances under which we many nevertheless retain personal information as permitted by law, such as:
a. To defend against fraudulent activity directed towards our business, systems, or users.
b. To detect and fix technical issues that affect existing system functions (e.g., for de-bugging).
c. As necessary for the protection of the free speech or other rights of us (or others).
d. To assist with law enforcement requests made pursuant to lawful process.
e. For certain scientific or historical research purposes.
f. For our own internal purposes, provided they are reasonably related to your relationship with us.
g. To comply with our legal obligations.
○ Please note that we require certain information in order to provide our Site and Apps to you. If you ask us to delete that information, it may prevent you from being able to access or use our Site or Apps.
○ To exercise your CCPA rights or learn more about how to do so, California residents may contact us using any of the following means:
a. Sending an email to privacy@roaringtiger.net.
○ In certain circumstances, we may not disclose some personal information to you in response to an access request where doing so presents too great a risk to you or our business. We may also withhold such information where we cannot verify your identity in connection to such personal information.
○ In the event we are not able to comply with your requests fully for any of the reasons described above, we will still explain the reasons why we could not fulfill your request.
○ If you elect to exercise your CCPA rights, we will not deny, charge different prices for, or provide a different level of quality of goods or services for that reason.
○ We do not knowingly collect personal information pertaining to minors younger than 16 years old who reside in California. In the event we learn that we have collected personal information regarding such California residents, we will take reasonable steps to remove such information from our database (or we will obtain any legally required consents).
○ You may exercise your rights under CCPA as described above by designating an agent to make requests on your behalf. If you choose to designate an agent, we will take steps to verify both (1) your identity; and (2) that your designated agent has been authorized to make a request on your behalf by providing us with a written authorization signed by you or a copy of a valid power of attorney.
In the event we make material changes to this Privacy Notice that may affect you, we will post prominent notice of any such changes on our Site and/or Apps for not less than 30 days prior to the effective date of the changes. We suggest that you check this Privacy Notice frequently in order to stay informed of any such changes.
To ask questions about the information in this Privacy Notice or for more information about how we use information we collect, or to exercise any of the rights outlined in Section 5, you may contact us at:
support@roaringtiger.net