1. About this Policy
Turborilla AB, a Swedish corporation, with registered and business office at Östra Rådhusgatan 6, 903 26 Umeå, Sweden, and its affiliates (referred to as “Turborilla”, “Turborilla AB”, “us”, “our” or "we") are dedicated to protecting the privacy rights of our users (referred to as "user(s)" or "you"). For this reason, we are committed to protecting your personal data and using it only as appropriate to provide you with the best possible experience with all Turborilla games, the website turborilla.com, the merchandise shop, the forum, user support and all other channels for feedback and news (collectively referred to as "services").
2. Key terms
Affiliates: People or companies outside Turborilla staff, whom we cooperate with closely and regularly, that have access to your personal data in order for us to provide our services.
Personal data: information that you provide to us or we collect which personally identifies you, such as your name, username, email address or geographic region.
Processing: includes collection, registration, organization, storage, processing or modification, reading, use, transmission of, dissemination or otherwise providing, adjustment or assembly, restriction, erasure or destruction of personal data.
Data controller/controller: The controller is usually the legal person (such as a company, foundation, authority or association) that processes personal data and determines the purpose of processing.
Data processor/processor: The processor is the person (or company) who processes personal data on behalf of the controller.
Services: Collection term for all of our products, services and games.
Cookies: Cookies are small text files that are stored by your browser on your desktop computer or mobile device.
Terms of Service/agreement: The agreement we enter with you for you to use our services.
3. Our services
Games: Mad Skills BMX 2, Mad Skills Motocross 2
Web services: Main website (turborilla.com), forum, merchandise, support
Social media: Facebook pages, Twitter pages, Instagram pages, Youtube channels, Twitch channels
4. What personal data do we collect?
We always seek to collect the least personal data needed to provide you with the best possible experience when using our services. Most of the personal data we collect and use is required for us to provide our services (regulated in the Terms of Service).
Personal data collected when using our games
Information we collect, or you provide to us, when you are using our games.
When you download our games
When you download our games but don’t log in, some personal data is still stored locally on your device. The personal data is stored for you to keep your progress in the game while using it. If you uninstall the game without logging in, all your progress will be deleted.
Device and model: We collect and use this information to adjust for example screen size when you use our services.
Advertisement ID: This information is used to track if the user installed the game from an ad or not, and which ad it was. A user can delete this ID from their device in the operating systems settings.
When you log in and create an account
App specific ID/Game center ID/Google Play ID/Twitter ID/Game Circle ID: We collect and use this information for you to be able to log in via social media.
Game Center Alias/Google Play Alias/Game Circle Alias: We collect and use this information for support issues, in case you have forgotten which account you are logged in with.
Twitter Handle: We collect and use this information for support issues, in case you have forgotten which account you are logged in with. Your Twitter followers see this Alias in leaderboards and profile.
Global facebook ID: Discontinued but must still be saved to make it possible for some existing users to log in. This ID is the user's global Facebook ID and can be used to identify the user on Facebook.
User ID: We create a unique ID when you use our services to handle various online features and support functions.
Profile picture: If you log in with Facebook, Twitter, Game Center or Google Play Games, we automatically upload your profile picture when creating an account. This information is used on leaderboards, in your profile, and in other online features. It is visible to all other users and can be deleted in your account settings.
Facebook real name: We collect and use this information to show your real name to other users who are your Facebook friends.
Username: When you create an account you choose a username. We use this information to give other users something to remember rather than your user ID, and to find you on leaderboards. Your username is visible to all other users.
Nation and region: When you create an account you can choose nationality and region. This information is used for national and regional leaderboards and is visible to other users with a Jam profile.
Phone number: When you play Jam, you can fill in a Jam event phone number that we use to contact you if you win prizes in the event.
Email address: When you play Jam, you can fill in a Jam event email address that we use to contact you if you win prizes in the event.
When using our forum
Information we collect, or you provide to us, when you are using our forum.
Profile picture: You provide us with a profile picture that you select. We use this information in your forum profile. The profile picture is visible to all other users (in your profile) and on every forum post that you publish.
Username: You provide us with a username that you select. We use this information in your forum profile. The username is visible to all other users (in your profile) and on every forum post that you publish.
The users name: You provide us with a name (or an alias) that you select. We use this information in your forum profile. The name (or alias) is visible, only if you choose it to be, to all other users (in your profile) and on every forum post that you publish.
Last login time: We collect the time when an account was last logged in. This information is used to make it possible for other users in the community to check when a fellow community user was last logged in. The last login time is visible to all other users (in your profile).
Login types: The type of login methods you have decided to use. When using your Google account login we collect the email address connected to your Google account. When using your Twitter account login we collect your Twitter Handle. When using your Facebook account login we only collect the login type (Facebook).
Login ID: We collect a generated login ID. This information is used to identify which user is logged in on the forum. It also gives the user the rights to post as the identified user and change the user settings.
Email address: We collect an email address provided by you. This information is used for login and reset password and for forum administrators to contact the users about beta testing or provide a reason for banning the user from the forum.
User Agent: We collect basic user agent, such as what browser is used. This information is used for DDOS protection and administration of the forum site.
IP address: We collect what IP address is used to visit the forum site. This information is used for DDOS protection.
Registration IP address: We collect the IP address that was used to create the forum account. This information is used for DDOS protection and administration of the forum site.
Last used IP address: We collect the last IP address used for the account. This information is used for DDOS protection and administration of the forum site.
When contacting our support
Information we collect, or you provide to us, when you are contacting our support.
Advertisement ID: We collect and use this information to identify the user’s device between sessions and to identify if multiple user support messages are sent from the same user. A user can delete this ID from their device in the operating system's settings.
Email address: We collect the email address that you provide us with and use this information in our support-related communication with you.
Name: We collect the name you provide us with and use this information in our support-related communication with you.
When visiting our website
Our main website, turborilla.com, uses two cookies:
RecentRedirect: prevents redirect loops if a site has custom URL redirects. A redirect loop is when “A points to B and B points back to A”. Such a redirection will keep browser in an infinite loop and the webpage will never be displayed. This information is saved for 30 minutes.
Crumb: prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in. This information is saved for the session time.
5. What do we use your personal data for?
Our main purpose of processing your personal data is to provide you with our games and other services to fulfill our agreement in Terms of Service.
We may use your personal data to identify your age for data protection purposes, for example to determine the legal requirements for processing of personal data. We do not knowingly collect personal data from children under the age of 13 in any of our services. Age-limitation is regulated in our Terms of Service.
We use your personal data for the following purposes in accordance with applicable laws:
To provide, operate, improve and maintain all our services and your account(s) ; personalize all content of our services; send technical notices, updates and security alerts; support and troubleshooting reasons; send support and administrative messages; provide news and information about our services; monitor the activities of users playing our games and using our services; facilitate sharing on social networks; provide adults with advertising in accordance with given consent and/or applicable laws; identify, fix, and troubleshoot bugs and service errors, provide software updates etc; resolve disputes, investigate and help to prevent fraud and illegal behavior, comply with the law, and to enforce our agreements and policies; survey users opinions about our services and related matters through surveys, social media channels or questionnaires; communication reasons related to our services; manage our services and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties; present offers and/or information relating to our services and other games that you might like; make recommendations to you; personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
6. What legal basis do we have for processing your personal data?
We collect and process your personal data in order to fulfill the agreement (Terms of Service) that is necessary for you to use our services.
Balancing of interest
When we have important information or news to share with you. It can be special offers in game or information about an event that you might be interested in. We may use your email address that you provided to us or send you a notification. If you do not want to receive this information or news, you can turn off notifications in the game or notify us by mail at: firstname.lastname@example.org
Some types of processing need your consent, for example direct marketing ads for European and EES country citizens. If you get direct marketing ads and are an European and EES country citizens even though you have not given your consent, please email us and we will correct it immediately: email@example.com
Complying with legal obligations
We will process your personal data when we have a legal obligation to do so.
7. For how long do we store your personal data?
We do not keep your personal data for longer than is necessary for the purposes of performing the agreement unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules.
8. Who do we share your personal data with?
We use a number of external services to provide you with a forum to connect with other users, a support channel, chat functionality, etc. We also cooperate with associate partners in order to fulfill our agreement in Terms of Service. We do not share your personal data with any company, organizations or persons outside Turborilla except when the following applies:
You’ve given consent
If you have given your consent to receive direct marketing ads, we will share personal data with our associate advertising network (only applies for European and EES country citizens).
Affiliates, third party agents and contractors
Where our services are accessed and/or provided through social networks.
Courts, law enforcement agencies, legal authorities etc.
When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of Turborilla, our services, users etc.
Other end users
In order to provide functionality in our services.
We may share your personal data with advertising networks in order to serve direct or indirect marketing ads to you.
For legal reasons
We may keep and/or share your personal data if necessary to comply with legal requirements or to protect Turborilla’s legal interests, for example in case of an ongoing legal process.
We use or may use the following platform/service providers in our services:
Apple Appstore: https://www.apple.com/legal/privacy/
Google Play: https://policies.google.com/privacy
Chat functionality: Discord https://discordapp.com/privacy
User support system: Helpshift https://www.helpshift.com/legal/privacy/
Ad network: Appodeal https://www.appodeal.com/privacy-policy
Internal documentation contractor: Google https://policies.google.com/privacy
Internal communication: Slack https://slack.com/privacy-policy
User Acquisition: Twigeo
E-sport: Gloot https://www.gloot.com/privacy-policy/
9. Payment information
In order to access certain premium game functions (i.e. levels, content, items or features) or to order items from our merchandise shop you are required to pay certain fees. When purchasing such features and functions you may be asked by the platform/service providers to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 18 or older to make purchases in our games or other services.
Once you have successfully entered valid credit card information and completed the order process, a purchasing account will be created and maintained for them. The platform/service providers will use the information provided to process your order and to send order confirmations via email, as well as to make future purchases easier for you. We do not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with our third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate our business (e.g. processing orders and payments).
We have taken reasonable steps to ensure that the personal data we collect is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the personal data collected from our users. Personal data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the personal data under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personal data, we cannot ensure or warrant the security of any personal data transmitted to us through or in connection with our services, that we store on our systems or that is stored on our service providers systems.
Please note that we may provide links to other games and websites that are operated and hosted by third parties who may have their own personal data collection practices. Those other games and websites are governed by their own privacy policies, which may be substantially different from our policy. Visitors to other games and websites are encouraged to review the privacy policies and personal data collection practices of those websites.
Any improper collection or misuse of user content or personal data provided in our services is a violation of the Terms of Service and should be reported to us at firstname.lastname@example.org.
11. International Data Transfers
We may transfer and share your personal data to third parties (including service providers operating on our behalf) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. If your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur based on the following safeguards: i) If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (see Privacy Shield at www.privacyshield.gov), or ii) If we have entered into EU Commission-approved standard contractual clauses with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.
12. Your rights
You have the following rights regarding your personal data:
The right to request access
You may request access to your personal data. This includes confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following:
The purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the intended period for which the personal data will be stored or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from you, any available personal data as to the source; the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing affecting you.
When personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer.
You shall be provided a copy of the personal data undergoing processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. When you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Please note that the access may be restricted due to intellectual property or trade secrets.
The right of correction
You have the right to have inaccurate personal data rectified.
The right of erasure
You have the right to have your personal data erased where one of the following grounds applies:
The Personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, if you have withdrawn your consent and there are no other legal grounds for the processing, if you have objected to the processing and there are no overriding legitimate grounds for the processing, the personal data have to be erased for compliance with a legal obligation in Union or Member State law, the personal data have been unlawfully processed or the personal data have been collected in relation to the offer of information society services.
Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims. If you exercise this right, you will not be able to use our services and note that we can not recreate erased data.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances. If you have the right to restriction, we will only process your personal data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.
The right to data portability
You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, when possible. However, we do not have the technical capability for any direct transmission of your personal data.
The right to object
You have the right to object to the personal data processing on grounds relating to your particular situation when the data are processed based on the balancing of interest rule. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection. Please note that if you exercise this right, your user license to use our services may cease automatically (stated in Terms of Service).
The right to withdraw consent
If we have asked for your consent to our processing of your personal data, you have the right to withdraw your consent at any time. If you withdraw your consent, we will cease processing of the personal data for which you have withdrawn consent, unless we have a legal obligation for processing your data. Please note that if you withdraw your consent to any processing required in Terms of Service (i.e. terminate the agreement), your licence for using our services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.
Changing or deleting account information
You can access, change and delete some of the personal data through you profile(s). Information will be updated as soon as possible. Deleted information may persist in backup copies for a reasonable period of time but will not be generally available to other users or visitors of the services. You cannot however remove communications made in any communication features, which might have been shared with other users (for example sending personal messages to another users).
When you want to invoke any rights
If you wish to invoke any of the rights described above, you may contact us at any time by emailing us at email@example.com. We will process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months.
Disputes between you and Turborilla
Our goal is to resolve disputes fairly and quickly. For all disputes against Turborilla, you agree to first contact us and try to resolve the dispute informally by sending a written notice of the claim (“notice”) to us. The notice must be sent via registered letter to the address listed below or by email to firstname.lastname@example.org with confirmation of receipt. The notice must (a) include your name, your residential address and email address and/or mobile phone number associated with your account registered with us and/or the platform/service provider; (b) describe the type and reason for the claim; and (c) specify specific compensation sought, if any. If we cannot agree on a solution to the dispute within 60 days of receiving such a notice, either party may initiate legal proceedings.
You are solely responsible for your interactions with other users of our services. We reserve the right, but have no obligation, to monitor disputes between you and other users.
If you are located within the United States of America, the following applies to you: Any claim (excluding claims for injunctive or other equitable relief) where the total amount of the award sought by either party is less than $10,000 shall be resolved via binding non-appearance-based arbitration initiated through the American Arbitration Association (“AAA”). The AAA Rules are available online at www.adr.org or by calling the AAA at 1-800-778-7879. In any such arbitration, the parties and AAA must comply with the following rules: (a) the arbitration shall be conducted by telephone, online and/or be solely based on written submissions, the specific manner shall be chosen by the party initiating the arbitration; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; (c) the arbitrator may award injunctive or declaratory relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim; and (d) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Nothing in this Agreement shall prevent either party from seeking remedies in small claims court of competent jurisdiction.
The right to refrain from arbitration. You may choose to waive this arbitration term. Then neither you nor Turborilla can demand that the other party take part in arbitration proceedings. In order to refrain, you must inform Turborilla in writing about this within 30 days of obtaining notice of this Arbitration section. You must provide the name and address, the email address associated with your account associated with the service (if you have one) and a clear wording that you want to waive the arbitration terms. All requests to refrain from arbitration must be sent to: Turborilla AB, Östra Rådhusgatan 6, 903 26 Umeå, Sweden and marked “Waiver of Arbitration”. If you do not waive this arbitration section it will continue to apply to you.
15. Class action waiver
You agree that any and all claims must be made in your individual capacity, and not as a plaintiff or class member in any purported class or representative proceeding.
17. Governing law
(a) If you are located outside of the United States of America this Agreement shall be governed by and construed in accordance with the laws of Sweden, without giving effect to any principles of conflicts of law, and the parties hereby consent to the sole and exclusive jurisdiction of the courts of Sweden, with the district court of Umeå (Umeå Tingsrätt) as first venue, to resolve any disputes arising out of or relating to this Agreement.
(b) If you are located within the United States of America, and unless otherwise required by a mandatory law of any jurisdiction, this Agreement shall be governed by and construed in accordance with the laws of the state of New York, without giving effect to any principles of conflicts of law. You agree that any action arising out of or relating to these Terms of Service that is not subject to mandatory arbitration as set forth above shall be filed only in the state or federal courts in and for New York County, New York and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action.
(c) Notwithstanding anything to the contrary, Turborilla may apply to any court of competent jurisdiction for injunctive or other equitable relief.
Turborilla AB, Östra Rådhusgatan 6, 903 26 Umeå, Sweden
or by email:
About this policy: email@example.com
About legal claims: firstname.lastname@example.org
Last Updated: June 1, 2018