Privacy policy

Dear Parents! This is where we keep our Privacy Policy. We take the privacy issues very seriously, so if you have any question or concern please send us a mail to privacy@toywheel.com.

Our Privacy Policy was last updated on March 21st, 2014.

1. Introduction
Please read the following to learn more about the Toywheel GmbH (“Toywheel”) Privacy Policy. The Toywheel website (www.toywheel.com) is intended for use by parents and Toywheel’s various related games, applications, features, content, widgets or services (collectively with the website, the “Service”) are intended for use by the whole family including young children with parental participation and supervision. Toywheel recognizes the importance of protecting any information collected from the users (each a “User” or collectively, “Users”) of its Service, and has adopted this Privacy Policy to inform its Users about the types of information Toywheel gathers about a User online while using Toywheel’s Service, how Toywheel may use that information, whether Toywheel discloses it to anyone, and the choices a User has regarding use of and correction of the information.

THIS PRIVACY POLICY IS PART OF THE TERMS OF SERVICE WHICH YOU, OR IF YOU HAVE NOT REACHED THE AGE OF MAJORITY IN YOUR JURISDICTION, A PARENT OR LEGAL GUARDIAN, MUST READ AND ACCEPT ON YOUR BEHALF.

Contact us at privacy@toywheel.com concerning anything you do not understand.

IF YOU, OR YOUR PARENT/GUARDIAN ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THE TERMS OF SERVICE, INCLUDING THIS PRIVACY POLICY, PLEASE EXIT THE SERVICE NOW AND DO NOT DOWNLOAD, ACCESS OR USE TOYWHEEL’s SERVICES.

2. Effective Date: The Privacy Policy detailed herein applies to any and all information that a User may have obtained from or provided to Toywheel. Toywheel reserves the right, at its full and complete discretion and without prior notice, to change, modify, amend, add, subtract, or otherwise remove portions of its Privacy Policy at any time and for any or no reason. Although Toywheel may attempt to email Users a copy of the revised Privacy Policy at the email address on file, if any, please periodically continue to check the Privacy Policy at www.toywheel.com/privacy for any changes. Such modifications will apply to disputes arising under the Privacy Policy from the date of posting forward. A User’s use of the Service after the posting of any amendments, deletions or other changes to the Privacy Policy will constitute acceptance, acknowledgment and agreement to the respective changes. If any such modification requires Toywheel to provide notice to a parent or receive parental consent, Toywheel will take the steps necessary to comply with those requirements at that time.

3. Types of Data: For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies a User as an individual. “Non-personal data” means information that does not directly identify a User. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Toywheel collects about the use of the Toywheel Service, from which any personally identifiable data has been removed.

4. Information You Provide to Toywheel: A User may make personal data available to Toywheel such as, for example: (i) when a parent subscribes to a newsletter or alerts through the parent section of the Service; (ii) when a parent contributes user generated content to the Service or participates in any support forums, community blogs or the like that Toywheel may establish; (iii) when a User requests technical support; or (iv) otherwise through use of the Toywheel Service where personal data is required for use and/or participation. The types of personal data collected may vary depending on the type of activity the User is engaged in. The personal data Toywheel may collect, process and use may include, but are not limited to the User’s name, screen/nick name, Toywheel or third party service ID, e-mail address, photo or other image, birthdate, gender, or avatar image.

5. Other Information Toywheel Collects and Uses: Toywheel may use tools or third party analytical software to automatically collect and use certain data including, but not limited to: (i) device properties, including, but not limited to IP address, Media Access Control (“MAC”) address and unique device identifier or other persistent or non-persistent device identifier (“Device ID”); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) game progress, time used playing, score and achievements; (v) other non-personal data as reasonably required by Toywheel to enhance the Service and other Toywheel products and services.

6. Use and Sharing of Personal and Non-Personal Data: Toywheel may use personal and non-personal data, and disclose personal and non-personal data, in accordance with applicable legislation and this Privacy Policy. Additionally, Toywheel may disclose personal data to its parent company and its subsidiaries in accordance with this Privacy Policy.

Toywheel may disclose personal and non-personal data to its partners and contractors for purposes of analyzing usage of the Service, providing customer and technical support, managing and providing the Service (including managing advertisement serving, where and how permitted by law), customizing Toywheel’s communications, and to further develop the Service and other Toywheel services and products. When Toywheel shares this information, it is with vendors and other service providers who are engaged by or working with Toywheel in connection with the operation of the services Toywheel provides to the User and/or for analytics purposes which may require the reproduction and display of such information in an aggregated and anonymized manner such that will not in any way identify the User.

Toywheel may use a parent’s personal data provided in the parent section to send messages to the parent with informative and/or commercial content about Toywheel’s services or third party products and services Toywheel thinks may be of interest to the User, such as new features and services, special offers and updated information. In addition, if a User has agreed to receive push notifications, and appropriate consent to receive them has been given, Toywheel will use the data collected and share it with its vendors for the purpose of delivering approved push notifications.

If a User contacts Toywheel by email, Toywheel will use the personally identifiable email address information only to respond to the specific inquiry.

The Service may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Toywheel treats information collected by cookies and similar technologies as non-personal data.

Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user’s computer. Toywheel’s cookies do not include personal data and are typically used to quickly identify a User’s device and to “remember” the User. Users can disable cookies or set their browsers to alert them when cookies are being sent to their device; however, disabling cookies may affect their ability to use the Service.

Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image that allows Toywheel to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Toywheel sends to a User may contain pixel tags that enable Toywheel to track a User’s usage of the communication, including whether the communication was opened and/or what links were followed, if any.

From time to time, Toywheel may hire agents and contractors to collect and process personal data on Toywheel’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Toywheel. These agents and contractors may not use a User’s personal data for their own marketing purposes. Toywheel may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Toywheel has the right to share Users’ personal data as necessary for the aforementioned third parties to provide their services for Toywheel. Toywheel is not liable for the acts and omissions of these third parties, except as required by law.

Toywheel may disclose a User’s personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose a User or Toywheel to legal liability. Toywheel may also disclose a User’s personal data to third parties when Toywheel has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Toywheel’s rights, property, operations, Users or others who may be harmed or may suffer loss or damage, or Toywheel believes that such disclosure is necessary to protect Toywheel’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Toywheel. To the extent permitted by applicable law, Toywheel will make reasonable efforts to notify affected Users of such disclosure through Toywheel’s website or in another reasonable manner.

Toywheel may store and/or transfer User personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. Toywheel may disclose User personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Toywheel’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.

When a parent discloses data about him or herself in the course of contributing user generated content or participating in support forums, community blogs or the like, the information disclosed is public information, and there is no expectation of privacy or confidentiality. Toywheel is not responsible for any personal data a User makes public in any of these forums.

7. Third Party Terms and Conditions: A User’s access to and use of the Service may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. Toywheel is not liable for any such third party terms and conditions and their use of Users’ personal data.

Toywheel may in its discretion make available links through advertisements or otherwise enable Users to access third party products or services. Toywheel is not responsible for the actions of such third parties, the content of their products or services, the use of information a User provides to them, or any products or services they may offer. Toywheel’s linking to those products or services does not constitute its sponsorship of, or affiliation with, such third parties.

8. Data Retention and Accuracy: Toywheel retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Toywheel deletes all aforementioned data in its possession within a reasonable timeframe. Toywheel does not verify the accuracy of personal data. Toywheel may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Toywheel user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.

9. Security: Toywheel follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Toywheel’s possession. Only those persons with a need to process Users’ personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to Users’ personal data in Toywheel’s possession. Personal data collected by Toywheel is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Toywheel maintains data within a fire-wall protected environment. While Toywheel exercises reasonable care and due diligence in providing a secure conduit of information between a User’s computer or other device and its servers, Toywheel cannot and does not guarantee the security of materials or information transmitted to Toywheel or other Users over the Internet or wirelessly. Therefore, while Toywheel will attempt to protect the transmission of any information using methods which comply with the industry standards, Toywheel does not accept liability for any unintentional disclosure of same.

10. Further Information: Users that wish to opt-out from receiving communications (such as any newsletters or offers) from Toywheel, should contact privacy@toywheel.com.

Toywheel makes good faith efforts to enable Users to review, update or correct any personal data in Toywheel’s possession. Users should contact Toywheel at privacy@toywheel.com. Toywheel will need sufficient information from the User to establish the User’s identity and to verify the User’s access, and also to assist in handling the User’s request. Even if personal data is changed or deleted according to a User request, Toywheel may still retain some of User personal data to resolve disputes, enforce Toywheel user agreement(s), and comply with technical and legal requirements and constraints related to the integrity, security and operation of Toywheel Services.

Notice to California Residents:

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Toywheel to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California. To make such a request, please send an email to privacy@toywheel.com or write us:

Toywheel GmbH
Straße der Pariser Kommune 29
10243 Berlin, Germany