Thank you for using Tootly Music! This Privacy Notice explains what personal data Tootly Enterprises (“we” in this notice) collect about you and how we use your personal data, as well as the choices you have about your personal data. 

This Privacy Notice applies to all Tootly’s services (such as our online music learning app Tootly Music), websites like www.tootly.in and related services and properties we control and which we collectively here call the “Services”. We may update this Privacy Notice from time to time by posting a new version of the Privacy Notice on www.tootly.in.

This Privacy Policy is an electronic record in the form of an electronic contract formed under the information Technology Act, 2000 and the rules made thereunder and the amended provisions pertaining to electronic documents / records in various statutes as amended by the information Technology Act, 2000. This Privacy Policy does not require any physical, electronic or digital signature. 

CONTACT US 

If you have any questions about this Privacy Notice or the ways we use your data, please contact us at [email protected] . 

For the activities described in this notice, the data controller (i.e. the entity that determines how and why personal data is processed) is Tootly Enterprises. Our address is 20047, Prestige Shantiniketan, Whitefield, Bengaluru (560048), Karnataka, India.

When we operate the Services, we may share your data with the partners we work with. Some of the partners are data controllers independently of us and they can determine how and why they process your data. 

WHAT PERSONAL DATA WE COLLECT AND WHERE WE GET THE DATA

Personal data that you provide us:

• Contact information, such as your name, phone number, email address or other contact information, if you have provided them to us (for example, if you create an account in our Services or subscribe to our communication),
• Your date of birth and gender,
• Your username and password (if you create an account in our Services),
• Your comments, feedback or other info you provide, if you participate in our surveys or other research,
• Other data you choose to give us through our Services or otherwise,
• With your consent, other information explained to you when asking for your consent. 

Services collect certain data automatically when you use them:

• Information on your use of the Services, such as your data about your use of our Services (e.g. progress, songs played, levels, session length, visits to our websites), and your interactions in the Services (such as data on or purchases you make or content you choose to share) as well as crash logs and other information related to bugs, errors and other issues in our Services
• Your IP address to bring our product to your device, but also to get an idea of your general location through IP geolocation data (on city, state or country level) so that we can manage the content available in the Service in your territory or to show you pricing in your own currency and also to analyse our Service and its usage. 
• Device related information related to the devices from which you access its services. This information includes the device model, operating system of the device, preferred languages, type of browser, nature of data connectivity i.e. mobile data or WiFi, advertising identifiers that are provided by third party providers. This information may be collected through cookies, pixel tags from Facebook or other technologies provided by third parties that help us maintain unique identification of our Users.
• Your browser and mobile device allow you to enable or disable cookies at any time. If you choose to disable cookies Tootly may not be able to fully personalize your experience on its app and / or website. Tootly cannot control the use of cookies by third parties and it is not covered by our Privacy Policy.
• We may also generate and assign a user ID when you access or use our Services

Providing data to us is not mandatory, but we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this notice, depending on the Services you decide to use and your choices when using them. You have a number of options to control the extent to which we process your data, such as whether or not to connect your third party accounts to our Services, resetting or limiting the use of your advertising IDs in your device settings, or disable the use of cookies in our cookie banner and/or your browser settings. 

We do not intend to collect or process any data relating to you belonging to special categories, such as data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership, genetic, biometric or health information, or data concerning person’s sex life. Please do not provide this type of information to us or make it available to others in the Services.

WHY WE PROCESS YOUR PERSONAL DATA

We will use your personal data for the following purposes on these legal basis: 

To make the Services work.

In order for us to perform our contract with you, we process your data necessary to

• set up and maintain your account in our Services (where applicable) and allow you to use our Services
• operate the Services 
• provide you the Services and products you request 
• process transactions and verify and confirm payments
• send you service-related communications (for example confirmations, administrative messages, technical notices)

To make the Services more suitable to our users. 

In order to provide great Services to our users and to provide you the best user experience possible, we have a legitimate interest to process necessary data to 

• analyze, develop and improve our Services and the user experience, and customize it for you 
• manage our customer relationship with you 
• provide social features as part of the Services (for example, leaderboards) 
• provide user support and respond to your questions and comments
• analyze your use of our Services, for example to understand what type of content you are interested in, and customize your service experience 
• send you updates, alerts, news and other information related to our Services or other operations
• troubleshoot or debug any errors or other issues in our Services
• create data that is not identifiable to you (for example, aggregated data) 
• conduct surveys or other research to learn more about our Services or users

To make sure that we reach interested audiences.

Based on our legitimate interest to promote our Services and to make sure we reach relevant, interested audiences, we process necessary data to

• provide you with our offers in the Services, in other websites and services, and by email 
• send you communications about our events, or other news related to our Services and operations 
• keep track on installations of our applications (including the source of each install)
• serve, target, deliver, measure and improve our advertising and the Services (including our advertising outside of our Services) 

To keep services fair and safe. 

In order to ensure acceptable, safe and fair use of the Services and to safeguard our operations, we have legitimate interest to process necessary data to 

• monitor that the use of the Services is acceptable and to prevent activity in the Services we determine to be misconduct, against our terms and conditions, or potentially illegal and take action against such use or otherwise exercise or defend our legal rights
• audit our operations or processes.

To analyse and segment.

For all of the above purposes, we can analyse and segment all collected data. 

With your consent.

If we wish to process your personal data for any other purpose where we are not able to rely on any other legal basis for processing under applicable law, we will ask your consent. 

We also may process your data as necessary to comply with legal obligations we consider to apply to us (including cooperating with authorities upon due request and for accounting and tax requirements). We can also process your data for additional purposes compatible to any of the purposes listed above. 

We do not use your personal data to make any automated decisions (meaning decisions without any human involvement) which significantly affect you.

WHO CAN SEE YOUR DATA

Instead of doing absolutely everything on our own, we need help from others. We have partners that provide services and data processing for us for the purposes described in this notice. We share your data with the following types of recipients:

Social Features.

We have social features in our Services, which means that other users may, for example, see your  profile data and your leaderboard position or other activities in the Services, and read or comments or questions you post in our forums.

Partners working for us. Persons or companies outside of the Tootly that process personal data on our behalf and according to our instructions and control. These Tootly processor partners include for example providers of hosting services, payment processors that actually deal with billing, banks and credit card companies on behalf of us, analytics services that enable us to gain insight into how we should improve our Services, user support and other services that help us to operate and develop our Services.

Advertising and social media partners who use advertising identifiers, cookies, APIs, and/or SDKs in our Service to enable them to collect and analyse user and device related data and information. Such partners may be for example, our advertising partners or partners providing social media tools allowing sharing of content from our Services. These partners collect and process personal data separately from us under their own privacy policies. We encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies. The opt-out instructions for these Partners’ services are also included in their privacy policies.

Public authorities and other entities. 

• competent law enforcement bodies or courts of law where we find it necessary as a matter of applicable law or regulation, 
• potential or actual buyers or their advisors in connection with a planned or actual corporate acquisition or other business restructuring or a similar arrangement.
• to any person or entity where we find disclosure necessary to combat fraud or illegal activity, or to exercise or defend our legal rights or to protect your vital interests or those of any other person.

DATA RETENTION

We retain your data as long as your user account is active or as needed to provide the Services. You may end this relationship by deleting your account. We will then delete all your personal data from our own and our partners’ systems, including backups within 30 days, unless there is a legitimate business interest to retain the data, such as to comply with our legal obligations, to enforce our agreements or to resolve disputes. We also periodically review and delete or de-identify inactive user accounts that have been inactive for five years or other data.

YOUR RIGHTS

You have the right to access your personal data we store about you. If you request, we will provide you a copy of your personal data in an electronic format. You also have the right to have your data deleted. If you choose to delete your profile, this will erase all personal data we have collected of you through the application thereby also anonymising all analytics data based on such personal data, unless we, for a legitimate reason, have the right to retain the personal data. You can also demand the restriction of processing in accordance with the legal requirements.

You also have the right to correct or update your information. You may do this by editing your personal details on your profile if your information changes or happens to be incorrect. Or you can contact us at [email protected].

You also have the right to object to our processing your information to the extent our processing is based on legitimate interests.

Any consent that you might have provided can be withdrawn at any moment.

HOW DO WE KEEP YOUR DATA SECURE

 The information collected by Tootly or generated over the course of usage of its services is securely stored in our databases and we use standard, legally compliant and commercially reasonable security measures such as firewalls, SSL (Secure Socket Layers) and encryption for protecting your information. Although these measures are robust our system is not impenetrable thus despite our best efforts towards the same we cannot guarantee the security of the databases nor can we guarantee that the communication between a User and Tootly via an app, website or any other means cannot be intercepted by a third party. We recommend that you do not share your Tootly account details with others and keep your device secure at all times.