Turning Wheel LLC Privacy
Last updated on June
the information we collect and the different ways we may use or share
This policy applies especially to your use of our games (eg Barony)
during online play. By
“online play” we mean any kind of in-game activity that links to this
page. Additional terms and conditions may also apply to your
relationship with Turning Wheel LLC, depending on how you choose to
us. Please read this entire policy to make sure you fully understand
it. You should also be sure to carefully review other terms potentially
applicable to your visit and your use of specific Turning Wheel games,
and confirm that you understand and agree to them, before using our
games or services.
Turning Wheel LLC is primarily situated in the state of Washington,
USA, and are subject to its laws and regulations regarding online
privacy. Please see “How to
Contact Us” below to learn more about sending us any
privacy-related questions or concerns you may have.
Information We Collect
We generally collect information in two ways: (1) you voluntarily
provide information to us, such as by making
purchases or signing up for email alerts on our website,
(2) other parties, such as
game consoles, Steam and Epic Games, and social networks, may provide
us about you, particularly when you play our games in conjunction with
those platforms. Each of these methods is described in more detail
(1) Information You Provide
You may provide your personal information to us when you choose to use
one of our games or online services. Because we change our offerings
and features from
time to time, the options you have to provide us with information also
may change. Some of the most common examples of situations in which you
may provide information to us include:
- Signing up on one of our community forums;
- Buying and playing one of our games (eg Barony);
- Using online social features connected to Barony (eg Steam
or Epic Games);
- Purchasing something from us or
otherwise engaging in a transaction with us;
- Entering online competitions or
registering for or participating in special events;
- Entering contests or sweepstakes,
participating in any of our promotions, or accepting any prizes from us;
- Signing up for email alerts or
subscribing to receive other information from us;
- Completing a survey;
- Using a mobile device, such as a phone,
to play our games or use our applications; and
- Contacting us for any reason, such as by
email, including for technical support or customer service.
The specific types of information you may be able to provide us will
often vary depending on the services or games you are using and how you
interact with them.
For example, you’ll need a Steam account to play our games on that
platform. If you’d like to create one, you may be asked to provide
basic registration details like your name, a public-facing display
name, password, country of residence, and email address. If you then
use your account to play one of our games on that platform, we can make
the information you provided to perform services such as connecting you
to other players online, sharing highscores, or facilitating
If you’d like to make a purchase, we may ask you to provide such things
as an email address for receiving your copy of the game after purchase.
information (like your card’s payment account number and expiration
date) will be handled with a third-party and not shared directly with
us. We’ll also collect information when you choose to share it with
us directly in any other way, including by sending it as part of a
communication with us (like through Player Support requests) or other
users of our services (like through in-game chat or forum posts).
(2) Information We Receive
Automatically from Others
In some cases, other parties provide us with information about you, or
allow us to collect information about you. We generally collect
information from other parties in three ways: (1) you play Barony
using a service that is not controlled by us, such as Steam or Epic
(2) you choose to play Barony online, or (3) you link accounts between
different services to facilitate cross-play in Barony. In some cases,
we are not able to control the amount or
type of information that other parties, like social networks, make
available to us. In those cases, we use only the data that we need to
provide the types of services we think our users want and expect.
Although we cannot control your privacy settings at those websites or
how those other parties protect your privacy, once we receive
information about you through those websites, we will treat it in
accordance with this policy.
We collect information mainly for purposes such as modifying or
improving game features, addressing technical
issues, and conducting data analytics. The type of
information that we automatically collect may vary, but any information
that could be used to identify a user will be treated as personal
information and handled with the appropriate level
When You Use Social
Features of Turning Wheel LLC Games
When you interact with Turning Wheel or one of our games (such as
Barony) on any website, app, or service platform not controlled by us,
we may be given access to certain information about
you. For example, social networks may provide us with information from
your profile on their services or other information that you agreed the
social network or other party could provide to us.
We may also receive information about you from the organizations that
sell our games or applications. Those parties may provide us with information regarding your
account or registration, but they do not give us your payment
information. Because those organizations determine what information
they will collect from you, it may vary according to their services,
but is likely to include details such as your display name and user ID
for those services, as well as device and region information.
When you choose to use some of our social features, you
allow us to receive information about you from third parties (primarily
the platform that the game is running on). Our social features promote
interaction among players, such as by allowing you and your friends to
work together to meet a shared challenge presented by one of our games.
You may be able to use these features to find out if your
friends are actively playing the game and using the feature, to find
out if they used it in the past, and to invite them to join with you to
meet a game challenge.
If you choose to use one of our social features, you may be asked to
log into a social network through our game or application. The social
network may then provide us with information such as your social
network user ID, your profile picture, and the user IDs and profile
pictures of your connections.
When You Link one Third
Party Account to Another via Barony
If you choose to link a third party account, such as a gaming console
or social media account, to another account, such as one created via
Steam or Epic Games, both parties may provide us with
your accounts. Because those
organizations determine what information they will collect from you, it
may vary according to their services, but is likely to include details
such as your third party account display name and user ID, as well as
associated device information, name, and possibly an email address.
How We Use and Share
As a general matter, we use and share the information we collect
(either individually or in combination with other information collected
as described in this policy) to help us provide, improve, customize,
analyze, and market our games and services where we have an
basis to do so.
We rely on several different legal bases to process personal
information for the purposes disclosed in this policy. These often
depend on the exact nature of your relationship with Turning Wheel LLC,
- To support our legitimate interests,
- To communicate with you, respond to your
requests, or provide you with updates and information;
- To better understand our users and their
- To personalize your experience, save
your preferences, authenticate our users, and provide similar
- To develop, deliver, and improve our
products, services, and other offerings, some of which may be offered
in partnership with other parties;
- To manage and customize advertisements
or promotional offers;
- For security purposes; and
- For internal purposes such as auditing
and data analysis.
- To provide services that are subject to
terms you have accepted, such as enforcing our licenses, agreements,
and terms of service, which may include reasonable monitoring to detect
and prevent misuse or fraud, keep our games fair for all users, and
otherwise protect and defend our services.
- When you give consent, which you can
withdraw at any time.
- To comply with legal obligations.
We may keep personal information for as long as we reasonably need it
fulfill the purposes for which it was collected. For example, if you
purchase a game through the Humble widget on our website, any personal
associated with your purchase may be stored for up to several years,
which enables us to provide customer support, provide the products you
applicable terms that govern your use of our products and services, and
maintain appropriate records to reflect our delivery of
services to you. We periodically review any personal information
retain to determine whether continued storage is proper.
We share personal information with
that we’ve engaged to help support our services by performing
certain services on our behalf and under our instructions. Common examples include partners that assist with
cloud storage, email marketing, support ticketing, and monitoring and
services. These service providers are not authorized by us to use or
disclose personal information except as necessary to perform services
on our behalf or comply with legal requirements.
We may share, or provide you with opportunities
share, information about you with other users of our games and services
described in this policy. We also provide services that allow our users
to communicate with us and each other, in which case personal
information may be shared and account IDs may be displayed. For
example, we may share information about you with your social contacts
when you and they use the same social features of our games and
We may disclose information about
we are required to
do so by law, legal process, or a reasonable request from law
enforcement authorities or other government officials, (ii)
believe disclosure is necessary or appropriate to prevent physical harm
or financial loss or in connection with an investigation of suspected
or actual illegal activity, or (iii)
if necessary to protect the vital
interests of another individual (such as to prevent death, bodily harm,
or serious damage to property). We reserve the right to transfer
information about our users in the event we sell or transfer all or
substantially all our business or assets.
Your Choices and Controls
We seek to provide you with meaningful choices about the personal
information you share with us, as well as the ways we may use or
share that information. We’ll generally only ask you for personal
information that is necessary to provide the services you request.
You can choose not to give us personal information we request, but if
you decide not to, you may not be able to access certain parts of our
games and services and some features may not work as intended.
We may also seek your prior consent to process your information in
certain ways. You aren’t required to provide consent if you do not want
your personal information to be processed for the requested purposes,
and may withdraw your consent at any time. Any withdrawal of consent is
only effective on a going-forward basis and will not impact processing
we undertook while relying on your
We provide you with the ability to request access to, and correction or
deletion of, your personal information. If you would like to request
access to any personal information we have collected from you,
please see the “How to Contact Us” section below.
Other examples of your choices include:
EEA and UK Residents.
- You can browse our website without
providing any personal information.
- You may opt out of receiving our
marketing messages at any time by using the opt-out mechanism provided
in the message.
- You can change your privacy settings on
other parties’ websites, such as social networks, which will stop or
limit our receipt of information from those other websites. You also
may choose not to use social features we make available. If you choose
to use these features, you should refrain from posting personal
information that will be visible to others, such as including your
email address in a forum or during a chat.
- You may change your browser settings or
take other steps to block, manage, or delete cookies.
- You may also exercise and amend your choices by sending an
email to us
as detailed in the “How to Contact Us” section below.
If you are an EEA or UK resident,
you may have
the right to access your information, the right to correct your
information, the right to request deletion of your personal
information, the right to request restricted processing of your
personal information, the right to a portable copy of the personal
information you have provided, and the right to object to processing of
your personal information, such as for direct marketing. For more
information about exercising these rights, send an email to the address
specified in the “How to Contact Us” section below.
If you are a California resident and are not a
job applicant, employee or employee of another company interacting with
us in your job, you have the right to ask us what personal information
we have collected and shared about you, the right to request deletion
of your personal information, and the right not to be discriminated
against for exercising any of these rights. For more information about
exercising these rights, send an email to the address specified in the
“How to Contact Us” section below.
Turning Wheel LLC only uses the personal
collect to help provide, support, and improve our games and services as
described in this policy, and we do not sell this information to third
How We Protect Information
We maintain appropriate administrative, technical, and physical
safeguards to protect your personal information from accidental,
unlawful, or unauthorized destruction, loss, alteration, access,
disclosure, or use and other unlawful forms of processing. In some
cases, your information is accessible when you log into a feature we
offer, and in those cases you need to keep your user credentials and
password confidential and secure so that your information is protected.
Our games and services are intended to be appropriate for general
and are not directed to children (usually considered to be under 13,
depending on where you reside). Turning Wheel LLC does not
personal information from children without seeking any required
parental approval in accordance with applicable legal and regulatory
obligations, such as the U.S. Children’s Online Privacy Protection Act
Transfers of Information
Turning Wheel LLC is a company with operations around the world. By
using our services, you acknowledge and agree that your information may
processed outside your country of residence, including in other
jurisdictions (like the United States) that may have different data
protection frameworks than your region. Any questions about our data
collection procedures in other regions should be forwarded to the email
address specified in the
“How to Contact Us” section below.
Updates to Our Privacy
This policy may be updated periodically to reflect changes in our
personal information practices or relevant laws. We will indicate at
the top of this policy when this policy was last updated. Please review
this policy every time you access or use our games and services to make
that you have reviewed the most recent version.
How to Contact Us
reach out to us via:
privacy [at] baronygame [dot] com