Last updated on June 28th, 2020

The Turning Wheel LLC Privacy Policy is designed to help you better understand the information we collect and the different ways we may use or share it.

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 interact with 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 information to us about you, particularly when you play our games in conjunction with those platforms. Each of these methods is described in more detail below.

(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 use of the information you provided to perform services such as connecting you to other players online, sharing highscores, or facilitating cross-platform play.

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. Billing 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 Games, (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 of confidentiality.

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 and facilitate 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 information about 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 Information

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 appropriate basis to do so.

(1) Use

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, but common examples include:

• To support our legitimate interests, such as:

• To communicate with you, respond to your requests, or provide you with updates and information;

• To better understand our users and their preferences;

• To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;

• 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 to fulfill the purposes for which it was collected. For example, if you purchase a game through the Humble widget on our website, any personal information associated with your purchase may be stored for up to several years, which enables us to provide customer support, provide the products you purchased, enforce any 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 we retain to determine whether continued storage is proper.

(2) Sharing

Service Providers.We share personal information with service providers 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 securing our 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.

Social Features.We may share, or provide you with opportunities to share, information about you with other users of our games and services as 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 applications.

Legal Obligations.We may disclose information about you:(i)if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials,(ii)when we 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 consent.

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:

• 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.

EEA and UK Residents.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.

California Residents.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.

Sales of Information.Turning Wheel LLC only uses the personal information we 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 parties.

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.

Children’s Privacy

Our games and services are intended to be appropriate for general audiences and are not directed to children (usually considered to be under 13, depending on where you reside). Turning Wheel LLC does not intentionally collect 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 (“COPPA”).

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 be 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 Policy

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 sure that you have reviewed the most recent version.

How to Contact Us

If you have general questions or concerns about Turning Wheel LLC or our privacy policy, please reach out to us via:

privacy [at] baronygame [dot] com