Privacy policy

Who we are

Speedy Tortoise Games Ltd is responsible for the personal data described in this policy. In data protection law, that makes us the controller.

We are a private limited company registered in England and Wales, company number 17470897.

Our registered office, and our postal address for privacy matters, is:

For anything about this policy or your data, email support@speedytortoisegames.com.

What this policy covers

This policy covers the personal data we handle as a company:

• when you visit our website, speedytortoisegames.com
• when you contact us
• our games and apps

Websites we link to, such as the Information Commissioner’s Office, have their own privacy policies.

When you visit our website

Hosting

Our website is hosted by Cloudflare. To send a page to your browser, Cloudflare has to receive some technical information from it:

• your IP address
• the page you asked for, and the date and time
• your browser’s “user agent”, which describes your browser and operating system
• the page you came from, if your browser sends it

Cloudflare uses this to deliver the website and to protect it from attacks and abuse. It does this for us under its data processing agreement. Cloudflare keeps its own operational and security logs for periods it sets. See Cloudflare’s privacy policy.

We do not receive these logs and cannot see individual visitors in them. We only see totals, such as the number of requests the site has served.

Visitor statistics

We use Cloudflare Web Analytics to count visits. It is a small script on each page. When a page loads, it sends Cloudflare:

• the page you visited
• the site you came from (the “referrer”), if there is one
• your browser, operating system and type of device (for example, phone or desktop)
• how long the page took to load

Cloudflare also works out which country you are in from your IP address.

We see only totals, for example “40 visits from the UK this week, mostly to the home page”. The script does not set cookies. It does not use local storage or any other browser storage. It does not follow you across other websites, and we cannot use it to identify you.

Many ad and tracker blockers stop the script, so our figures undercount. That is fine with us.

If you would rather not be counted, you can block static.cloudflareinsights.com in a content blocker, or turn off JavaScript. The website works fully without it.

Cookies

We do not set any cookies, and we do not use local storage, session storage or similar technology. That is why there is no cookie banner.

In some situations, Cloudflare may set a security cookie. This happens when it needs to check that your browser is not an automated bot, for example during an attack on the site. These cookies are named __cf_bm or cf_clearance. They are used only for security, not for tracking or advertising. __cf_bm expires after 30 minutes of inactivity. See Cloudflare’s cookie list.

When you contact us

You can contact us by email, for example at support@speedytortoisegames.com. When you do, we receive your email address, your name if you include it, your message and any attachments.

We use this to read your message, reply to you and keep a record of the conversation.

Email to our addresses passes through Cloudflare Email Routing, which forwards it to our mailbox. Cloudflare says it does not store the content of forwarded email. Our mailbox is provided by Google (Gmail), so Google stores our correspondence.

We keep correspondence for 2 years after our last message with you, then delete it. We keep it longer only if we need it to deal with a legal claim, or the law requires us to keep it.

Please do not send us sensitive information, such as health details, unless we need it to help you.

Our games and apps

We have not released any games or apps yet. Before we release one, we will update this policy to describe exactly what it collects and why. The updated version will apply from the date it is published.

Who we share data with

We use these service providers to run our website and email:

• Cloudflare: website hosting and security, visitor statistics, and forwarding email
• Google: our email mailbox (Gmail)

We do not sell your personal data, and we do not share it with anyone for advertising.

We would disclose personal data if the law required us to, for example to comply with a court order, or if we needed to in order to establish or defend a legal claim.

Data stored outside the UK

Cloudflare runs a global network, so your data may be handled outside the UK, including in the United States. Cloudflare’s data processing agreement relies on the UK Extension to the EU–US Data Privacy Framework. Where that does not apply, it uses the International Data Transfer Addendum issued by the Information Commissioner’s Office.

Google may store our email in the United States and other countries. Google states that it complies with the UK Extension to the EU–US Data Privacy Framework.

Why we are allowed to use your data

UK data protection law says we need a “lawful basis” for each use of personal data. Here is ours.

Where we rely on legitimate interests, we have weighed our interests against yours. You can object at any time (see Your rights).

We do not make automated decisions about you that have legal or similarly significant effects, and we do not build profiles of visitors.

Your rights

Under UK data protection law, you have the right to:

• access: ask for a copy of the personal data we hold about you
• rectification: ask us to correct data that is wrong or incomplete
• erasure: ask us to delete your data
• restriction: ask us to limit how we use your data
• object: object to our use of your data where we rely on legitimate interests
• data portability: receive your data in a machine-readable form. This applies only where we rely on your consent or a contract with you. At the moment we rely on neither.

To use any of these rights, email support@speedytortoisegames.com. It is free. We may need to ask you for information to confirm who you are. We will reply within one month. If your request is complex, we may need up to two more months. If so, we will tell you why within the first month.

Visitor statistics do not identify individuals. So in most cases we cannot find, send or delete website data about you in particular. We can for email.

Complaints

If you are unhappy with how we have handled your personal data, please tell us first at support@speedytortoisegames.com. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection:

• online: ico.org.uk/make-a-complaint
• by phone: 0303 123 1113
• by post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Changes to this policy

We will update this policy when what we do changes, for example before we release a game or if we change email provider. The version number and dates at the top show when it last changed.

If a change is significant, we will say so clearly at the top of this page, with a short summary of what has changed.

We keep every earlier version so you can see what we said and when.

Earlier versions

None. This is the first version.