170 Edmund Street
United Kingdom, B3 2HB
Valid as of: January 1st, 2021
Personal data is all information relating to a specific or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using additional information available to us.
Controller of the GAWOONI Services and the responsible body within the meaning of data protection law is GAWOONI PLC, 170 Edmund Street, Birmingham, United Kingdom, B3 2HB (hereinafter: “we” /”us”).
You can access this information at any time on our websites.
Information on data processing
Basic user data
Disclosure of data to third parties
Where is the data stored?
How do we protect your personal data?
Use of GAWOONI Services by minors
Information on data processing by GAWOONI
1. Basic user data
a) What basic user data is collected and stored?
The use of some of the GAWOONI Services requires you to register a user account (hereinafter: “GAWOONI Account”). During the registration process, you will be asked to give us the following information, namely:
For the purposes of UK / EU GDPR (General Data Protection Regulation), your email address is the only information which will be defined as personal data, from the list above.
When registering a GAWOONI Account you should choose a username which does not allow conclusions to be drawn about your al identity as other users can use your username to see the information contained in your player profile as well as your game statistics.
We provide users with the possibility of sending us support requests. In connection with such support requests, we shall require your email address solely to allow us to allocate the requests, processing the requests and/or resolve underlying technical problems. Your email address may then be stored for the above purposes and allocated to the corresponding GAWOONI Account (if stated) until such time as permission to use that information is revoked..
b) For what purposes do we collect, process and use basic user data?
We require this information as a lawful basis for processing purposes including the basis of a legitimate interest to perform the GAWOONI Services.
We use the data you provide during registration in order to open an individual GAWOONI Account for you to enable you to use the GAWOONI Services, to play our games, to satisfy your requests, to fulfil your orders and to send you confirmation of purchases and other account and use related information. In addition to that, we use the data for statistical purposes in order to improve the user experience. We use the information related to your GAWOONI Account for the following purposes in particular:
- to keep you informed about games and/or particular game-specific events (e.g. competitions);
- to inform you about our promotions;
- to offer customer service and to process user requests;
- to subscribe you to newsletters, including newsletter advertising, insofar as you have given us your prior express consent;
- to analyze the performance of our services;
- in order to ensure the proper operation of our services and to identify and remedy software errors and security risks; and
- to improve our services according to our users’ requirements.
c) How long is basic user data stored?
The data will be stored to the GAWOONI Account until the account is deleted.
d) Legal basis
The legal basis for the collection and processing of your personal data is Article 6 paragraph 1 lit. a of the GDPR if you have granted us explicit consent, Article 6 paragraph 1 lit. b of the GDPR if the data processing is necessary for the performance of our contract, and Article 6 paragraph 1 lit. f of the GDPR if we can assert a legitimate interest in the data processing.
2. Usage data
In addition to the information you actively provide us with, we automatically collect a range of data as users use our websites and other GAWOONI Services, in particular on the manner and extent of the use of our services, which requires no action on the part of the user.
a) What data is automatically collected?
Automatically collected data only includes data, (which is not directly related to you personally nor does it fall within the definition of personal or sensitive data under UK / EU GDPR), such as the IP address allocated to you at the time of access (in anonymised form), the duration of the access, the pages displayed and other data automatically conveyed by your PC, e.g. in the form of log files with information, in particular, on the hardware you are using, your operating system, browser information, language settings, your screen resolution and your internet service provider.
In the course of the use of our GAWOONI Services we also collect a range of service related data, e.g. on the functions of a service used by you, game statistics, number of points and achievements attained, user rankings and the time which you spend on our games as well as the pages and links which you visit in the course of using our services. This information will be stored and allocated to your GAWOONI Account and used for the statistical evaluation of your use (see below).
b) For what purposes do we collect, process and use usage data?
We use your data to facilitate your use of our services, to correct technical problems, to ensure the continuous functioning of our products and services and to improve and further develop these according to the needs of our users. We use the automatically collected usage data, which is stored without being linked to your GAWOONI Account, for the following purposes:
- to assess the success of marketing measures, in particular conversion rates for advertisements and newsletters;
- to fulfil your orders and to send you an order confirmation;
- to authenticate your software and verify your rights of use;
- to ascertain your approximate location in order to offer country and language specific services and functions as well as statistical evaluations on the use of our services; and
- to tailor the advertisements displayed within our services to your specific interests by assigning you to certain interest groups on the basis of this information.
In addition, your game statistics aid the evaluation of your skill level and the creation of a ranking in relation to other users. Insofar as you participate in tournaments or other online game events, the statistical data generated by your participation (such as, for example, your results, placings and successes) will be visible, under your username, to other users of our services. We use this information for the creation and publication of rankings and comparison lists to highlight the competitive nature, which is an essential factor of our Services.
3. How is data automatically collected?
For the automated collection of usage data, we use technologies such as cookies, in order to collect passive usage data from our website without your active input. These include, in particular:
Cookies are small text files which are stored on your computer, or other end device, when you use our services. Usage data can be stored in these cookies, in order to record your preferences, log-in details and settings for future visits, to identify illegal usage of our services or to personalise the advertisements displayed within our services, or on the websites of other providers, to the respective user.
Most browsers are automatically set to accept cookies when visiting a website. You can deactivate cookies or set your browser to display a warning as soon as cookies are sent. However, when cookies are deactivated some sections of our websites will not function properly. You can set your web browser to warn you when there is an attempt to place cookies on your computer or to limit the range of cookies permitted by you.
b) Analytical metric tool and other technologies
GAWOONI uses an own analytical metric tool and third party analytics technologies (see more detailed information below), to collect data when you play our games. These tools and technologies collect information about your computer, browser, your operating system, your use of features and pages, any application software used and information about the manner and extent of use of our games, including game metrics and statistics and your purchasing behaviour.
c) Google Analytics
We sometimes use Google Analytics on our websites, a web analytics tool from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies” which are stored on your PC and which enable an analysis of your use of the website. The information obtained by the cookies about your use of this website will generally be transmitted to a server in the USA and stored there. We use Google Analytics on our websites, however, with an IP anonymisation tool, with which your IP address, when collected by Google Analytics, will, in member states of the European Union or in other states which are party to the Agreement on the European Economic Area, be masked beforehand and thus will be exclusively transmitted by Google in anonymised form. Google uses the collected information to statistically evaluate your use of our website for us, to create reports on website activities and to provide further services related to the website and the internet usage for us. The IP address transmitted by your browser in the scope of Google Analytics will not be combined with other data from Google.
If you are on one of our websites, you can deactivate the Google Analytics function by clicking on the following link:
Alternatively, you also can deactivate the Google Analytics function with a browser add-on, which you can download at https://tools.google.com/dlpage/gaoptout. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.
4. Disclosure of data to third parties
We do not pass on any personal user data to third parties.
5. Where is the data stored?
We store and process data collected in relation to the use of GAWOONI Services, exclusively on servers located in UK and in the European Union.
6. How do we protect your personal data?
We undertake reasonable efforts to protect your personal data and to ensure the security of our systems using the relevant latest technology. To this end, we use, among other things, state of the art encryption methods. At the same time, it should be noted that no type of transmission via the internet or method of electronic data storage is 100% secure. We can therefore offer no guarantee against unauthorised access to our servers and systems.
7. Use of GAWOONI Services by minors
Many GAWOONI Services are intended for a wide range of ages in their user base. We do not intentionally collect personal data of minors. To the extent we request information on age for the use of our services and a user identifies themselves as under the age of 16, we will either collect no data from this user or ensure that we have the consent of their parents for the collection, use, processing and disclosure of the personal data of the child.
Please note as a parent or legal guardian that in consenting for your child to use GAWOONI Services this can also include access to internal communication services and forums, in which posts by your child may be available to a wide public and through which your child may potentially communicate with users of all ages and give out personal details to these users.
Parents can change or revoke the consent granted and, with an email to the address above, view, edit or apply for the removal/deletion of the personal data of their child.
In the event of a material change to this Privacy and Cookies Policy with the effect that the collection, use, processing or disclosure of the personal data of the child, for which consent was granted, is expanded we shall notify the relevant parent promptly.
We would encourage you to talk with your child about communication with strangers and giving out personal information online. We will in no way make the participation of a child in an activity – such as a tournament – dependent on giving us more personal data than would reasonably be seen as necessary for participation.
8. User rights
According to the provisions of the GDPR and in accordance with the relevant provisions of Union and national law, you are entitled to the following rights within the scope of the respective regulation.
a) Right to information (Art. 15 of the GDPR)
You may request confirmation from GAWOONI as to whether personal information relating to you is collected, processed and stored by GAWOONI. If such collection, processing and storage exist, you may request from GAWOONI (inter alia) any information on the purpose for which your personal data is collected and processed as well as information on the planned duration of the storage of your personal data. Please address your written request for information by post to GAWOONI PLC, 170 Edmund Street, Birmingham, United Kingdom, B3 2HB or by email at email@example.com.
b) Right to rectification and completion (Art. 16 of the GDPR)
If the collected, processed and stored personal data relating to you is inaccurate or incomplete, you have the right with respect to GAWOONI to the rectification and/or completion of your personal data.
c) Right to the restriction of processing (Art. 18 of the GDPR)
You may request to restrict the processing of the personal data relating to you.
d) Right to erasure (Article 17 of the GDPR)
You may request of GAWOONI that the personal data relating to you be erased immediately. GAWOONI is required to erase this data immediately, where necessary, if the personal data relating to you is no longer necessary for the purpose for which it was collected or otherwise processed, or if you have revoked your consent to that which the collection, processing and storage refers. There is no right to erasure if, inter alia, the processing is necessary to fulfil a legal obligation which requires the collection and processing under the law of the Union or of the Member States to which GAWOONI is subject, and also if the collection and processing is necessary for the assertion, exercise or defence of legal claims.
e) Right to data portability (Art. 20 of the GDPR)
You have the right to receive personal data relating to you—which you had submitted to us as the controller for the data collection—in a structured, commonplace and machine-readable format. You also have the right to transfer this data to another data controller without interference from the data controller to whom the personal data had been provided.
f) Right to object (Article 21 of the GDPR)
For reasons that arise from your particular situation, you have the right to object at any time to the collection and processing of the personal data relating to you which is carried out pursuant to Article 6 paragraph 1 lit. F of the GDPR.
g) Right to revoke the declaration of consent (Article 7 of the GDPR)
If you have consented for us to collect and process your personal data, you have the right to revoke your data protection consent declaration at any time.
h) Right to complain to a supervisory authority (Article 77 of the GDPR)
You have the right to complain to a regulatory authority, in the Member State of your place of residence, your place of work or the place of the alleged infringement, if you believe that the collection and processing of the personal data relating to you is in breach of the GDPR.
i) Rights regarding direct advertising (Article 21 of the GDPR)
If we process your personal data in order to pursue direct advertising, according to Art. 21 para. 2 of the GDPR you have the right to object at any time to the processing of the personal data relating to you for the purposes of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising. In the case that you object to the processing for the purpose of direct advertising, we shall no longer process your personal data for these purposes.
To assert your rights or for questions on the topic of data protection, you can contact us at any time by post at GAWOONI PLC, 170 Edmund Street, Birmingham, United Kingdom, B3 2HB or by email at firstname.lastname@example.org.