Privacy

Effective Date: 1 September 2014

General

Your privacy is important to us. This Privacy Policy explains how we collect, store, use and disclose your information when you use www.gamewheel.co (the “Gamewheel Website”).

The Gamewheel website is owned and operated by Toywheel GmbH (registered with the commercial register of the local court of Charlottenburg under HRB 150873 B). The expressions “Gamewheel”, “we”, “us” and “our” mean Toywheel GmbH, whose registered address is Kemperplatz 1 c/o WeWork, 10785 Berlin, Germany.

By using the Gamewheel Website, and in particular by registering a Gamewheel account, you are consenting to the use of your information in the manner set out in this Privacy Policy.

If you do not agree to any of the provisions of this Privacy Policy, you should not use the Gamewheel Website. If you have any questions or concerns, you can contact us at info@gamewheel.co.

Collection and Use of Information

We collect information about you from various sources.

Information you give us

In order to use Gamewheel’s Services, you will need to register for a Gamewheel account. By doing so, you will provide us with certain information:

  • Essential information: when you register any kind of Gamewheel account, you will need to provide your email address and choose a password. In addition, if you purchase a enterprise account, you will also need to provide your real name, billing address and payment information
  • Profile information: you may also choose, at your discretion, to provide additional personal information for your Gamewheel profile, such as your full name, phone number, company name and profile picture

In addition, you you will also provide certain personal data if you contact us by email, use any of the webforms on the Gamewheel Website, or contact us by mail or other offline means.

Information we collect automatically

There is certain information that we collect automatically as the result of your use of the Gamewheel website, either ourselves or through the use of third party web analytics services. This information includes but is not limited to:

  • the Internet Protocol (IP) address of the device from which you access the Gamewheel website (this can sometimes be used to derive the country or city from which you are accessing the Platform)
  • the site that you visited immediately prior to visiting the Gamewheel Website
  • the specific actions that you take on the Gamewheel Website
  • the time, frequency and duration of your visits to the Gamewheel Website
  • your browser type and operating system
  • the nature of the device from which you are accessing the Gamewheel Website
  • information collected through cookies and similar technology
  • information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message
How we use your information

We use the information we collect about you for the following purposes:

  • To operate and maintain your Gamewheel account, and to provide you with access to the Gamewheel Website. Your email address and password are used to identify you when you log into the Gamewheel Website
  • To identify you as the creator of the graphics that you upload, the games that you build and/or other work you create using Gamewheel
  • To seek your participation in surveys, and to conduct and analyze the results of those surveys if you choose to participate.
  • To provide you with technical support.
  • To respond to you about any comment or enquiry you have submitted.
  • To prevent or take action against activities that are, or may be, in breach of our Terms of Use or applicable law.
  • If you subscribe to a enterprise account, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment
  • To send you service updates and notifications regarding your account
  • To analyze the use of the Gamewheel Website, and the people visiting the Website, in order to improve Gamewheel

We will also potentially use the information we collect about you for other purposes, provided we disclose this to you at the relevant time, and provided that you agree to the proposed use of your personal data.

Sharing Your Information and Content with Third Parties

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties, but we may retrieve, save, share and make any use of the information, including without limitation use for analysis or statistics, which is compatible with providing our services to you.

We may provide information and/or personal user content to service providers to help us provide the services we offer. Specifically, we may use third parties to facilitate our business, such as to host our service at a co-location facility for servers, to provide you with our community blog, to send out email updates about Gamewheel, to process payments for products or services and to provide you with our live chat services. In connection with these business operations, our service providers may have access to your personal information and/or content. When you sign up for our Services, we will share your personal information as necessary for the third party to provide that Service. This will be done securely and confidentially and only to the extent permitted under applicable data protection laws

We occasionally provide demonstrations of user created content that allow non-users a glimpse into the Gamewheel world. Such content is provided in a form which protects your content from any unauthorized editing and/or changing.

We may be required to disclose your personal information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information until we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards.

Additionally, we may share account or other information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Gamewheel Service or using the Gamewheel name, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies.

Cookies and other tracking technologies

Cookies are small text files that are placed on your computer by websites that you visit. Like most companies, we use cookies to help us understand how people use our website, so that we can keep improving Gamewheel. You can find out more about the way cookies work on www.cookiecentral.com andwww.allaboutcookies.org.

Most browsers allow you to turn off the cookie function. If you want to know how to do this, please look at the help menu on your browser. However, this may restrict the use of some parts of the Gamewheel Website.

We work with various third party companies and services to help us analyze how the Gamewheel website is used. The following companies and services help us achieve this through the use of cookies:

Google Analytics

Google Analytics is a service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use our website. The information generated by these cookies (including your truncated IP address) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your, and other users’, use of our website, compiling reports for us on website activity and providing other services relating to website activity and Internet usage. Please note that Google only receives your truncated IP address. This is sufficient for Google to identify (approximately) the country from which you are visiting our sites or accessing our players, but is not sufficient to identify you, or your computer or mobile device, individually.

Google AdWords

We use the online advertising program Google AdWords operated by the company Google Inc. (“Google”). For measuring conversion with Google AdWords, a conversion tracking cookie is placed when a user clicks on a Gamewheel advertisement delivered by Google (“Ads”). Conversion tracking cookies expire after 30 days and are not used for personal identification. Google uses a different cookie for each Google AdWords customer and there is no consolidation of the cookie data with other data. If you click on one of our Ads and proceed to a page equipped with a conversion tag and the cookie has not yet expired, the conversion is documented. With the help of the conversion tracking cookie we see the total number of conversions and are able to review the performance of our Ads. You can find more information about Google AdWords here.

Mixpanel

We work with Mixpanel, a service offered by Mixpanel Inc. (“Mixpanel”), to collect user data from the Gamewheel website, so that we can better understand how users interact with our website. Mixpanel is used to understand and improve activities within the app, such as creating a game or uploading new graphics. This non-personal information is stored on Mixpanel servers in the United States. More information on the Mixpanel Privacy Policy can be found here:https://mixpanel.com/privacy/.

Facebook Conversion Tracking          

The Gamewheel Website utilizes the Conversion Tracking Pixel service of Facebook Inc. (“Facebook”). This tool allows us to follow the actions of users after they are redirected to our website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. We will share information regarding your visit to our website with Facebook but this will not include any personal information. Facebook will use this information to monitor on our behalf the effectiveness of our advertising and applications.

The information we share with Facebook will only be used in accordance with Facebook’s data use policy, which is available underwww.facebook.com/about/privacy. Facebook Conversion Tracking may also enable us and our partners to serve ads on and off Facebook.

Social Media Widgets

Our Website includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share button or interactive mini-programs that run on our site. These Features may collect information such as your IP address or which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Location of Personal Information

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of our services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

In relation to information of visitors to websites incorporating games built by Gamewheel users through its Website (“Users’ Visitors Data”), Gamewheel serves as a data “Processor” (due to the technical hosting thereof) and not as a data “Controller” (as both such capitalized terms are defined in the European Data Protection Directive). The users controlling and operating such websites shall be considered the controllers of such Users’ Visitors Data and are responsible for complying with all laws and regulations as may be applicable to the collection and control of such Users’ Visitors Data including privacy or data protection laws of all relevant jurisdictions. Gamewheel cannot provide legal advice to Users, but Gamewheel recommends that all Gamewheel Users that create and maintain websites on the Gamewheel platform should maintain clear and comprehensive privacy policies complying with the applicable laws and regulations. Please see below for additional information on how Users’ Visitors Data may be handled in connection with your use of the Gamewheel Services which may require you to provide specific notice to and/or obtain consent to your users.

Communications from the Website

By registering on the Gamewheel Website and providing your email address, you expressly agree to receive promotional content from Gamewheel, by email, from time to time. If you provide Gamewheel with your phone number (at any stage of use of the Gamewheel Services), Gamewheel shall be entitled to call you or send you promotional SMS notices from time to time. If you wish not to receive such promotional content / notices, you may notify Gamewheel at any time or follow the unsubscribe instructions contained in the promotional communications which you receive.

Newsletter

Our newsletter gives you information about us and what we offer.

If you would like to receive the newsletter, we need your valid email address. We also generally require your prior, express consent. This data is used only to send the newsletter and will never be given to third parties.

When you register for the newsletter, we save your IP address and the date of registration. The data is saved as evidence in the event that a third party misuses an email address by registering for the newsletter without the owner’s knowledge.

You can revoke your consent to the storage of your data and email address at any time, as well as the use of this information to send you the newsletter. To revoke your consent, simply click the link in the newsletter itself, or let us know by using the contact information at the bottom of this page.

Links

The Gamewheel Website contains links to other websites. Please note that we are not responsible for the privacy practices of such other websites, and we recommend you read the privacy statements immediately on entering other websites. This Privacy Policy applies only to information collected through the Gamewheel Website.

Changing or Removing Content

If your personal information changes, or if you no longer desire our services, you may correct, update, or deactivate it by emailing us at info@gamewheel.co. If you wish to access your personal information, please also email us at the address above. We will retain your information for as long as your account is active or as needed to provide you with our services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

Gamewheel takes precautions to protect its Users’ information and content. We have reasonable physical, electronic, and procedural safeguards that are designed to protect your account information and uploaded content. However – regardless of the measures taken by Gamewheel, we cannot and do not guarantee the protection and security of your data or your site visitors’ data. If you have any questions regarding the security of the Website, please contact us at info@gamewheel.co.

Contests

From time to time, we may provide you the opportunity to participate in contests or on our Website. If you participate, we will request certain personal information from you. Participation in these contests is completely voluntary and you therefore have a choice whether or not to disclose this information.

The requested information typically includes contact information (such as name and email address). We use this information to notify contest winners and award prizes, to monitor site traffic and to provide notices to participants.

Terms of Use, Notices and Revisions

Your use of Gamewheel and its services, and any disputes arising from it, is subject to this Privacy Policy as well as our Terms of Use and all of its general provisions including warranty disclaimer, limitation of liability, indemnity and choice of law. We may update this privacy policy to reflect changes to our information handling and storage practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Unless stated otherwise, our current privacy policy applies to all information that we have about you or any of your accounts on www.gamewheel.co.

Contacting Us

If you have any questions about this privacy policy, please contact us by email at info@gamewheel.co or write to us at Toywheel GmbH Kemperplatz 1 c/o WeWork, 10785 Berlin, Germany.