Privacy Policy

Introduction

Hello and welcome to the Wubu Apps Privacy Policy. This policy describes how Wubu Apps, and its other group companies (collectively described as “Wubu Apps”, “Wubu”, “we”, “us” or “our”), and its third party marketing and advertising partners collect, use, process and share information about you.

This Privacy Policy applies to all of our games, whether played on our website www.wubuapps.com, on mobile devices, PCs or on other platforms such as Facebook. It also applies to our Marketing and Advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games, websites, marketing and advertising activities and other services collectively as our “Services”.

By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to Wubu Apps’ and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. Those sections also explain how you can withhold or withdraw your consent to the use of your data for targeted advertising purposes. If you have any other concerns about providing information to us or it being used as described in this Privacy Policy you should not use our games or other Services.

This Privacy Policy was last updated on 2019/12/05.

Playing our games

By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of information about you by us. Most of this data comes directly from you or your device, such as device information, country and region, and game play information. We use this data to provide our games and Services to you, including for the purposes of optimisation, preventing fraud, customising in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising purposes.

Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. Broadly the information we collect about you relates to the type of device you are using, how you play our games (such as crosswords attempted and purchases made) and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our games or Services. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests. In more detail, depending on which of our Services you interact with we may collect and process the following types of information:

  • details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s) and what device you use to access our games)
  • information that you provide us with when you fill in forms, answer questions or complete surveys when using any of our Services, when you create an account with us or if you invite your friends to use our games and Services;
  • the content of messages sent using our chat and messaging systems;
  • if you contact us or respond to messages and communications that we send to you, we may keep a record of that correspondence;
  • your interactions with us on our social media channels;
  • information we collect via cookies and other similar technologies, as explained further below;
  • information as further set out in this Privacy Policy, including making an account and playing socially, Marketing, and Advertising;
  • information we collect about you from our other group companies or other third party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this Privacy Policy and subject to any limitations in the privacy policy of the company that collected the information from you.

We may also share your information with third-party publishers who develop and provide games and other Services to you on our behalf.

We analyse and use the information we collect on an anonymised or aggregated basis for product development, to analyse the performance of our games, troubleshoot issues, and improve and optimise the games to ensure the best player experience for our players as a whole.

A more detailed description of some of the ways that we use your information is set out below and in other sections of this Privacy Policy.

Providing and Optimising Our Services

We use your information to enable us to provide our websites, advertising, and other Services to you and to optimise all of them so that we can make them the best they can be for you and all our players. This includes the use and analysis of aggregated data to ensure our websites work properly on all devices and provide an enjoyable experience for all our players.

Customer Services

We use your information, including data you provide directly to us in communications, to offer you support through our customer service channels when needed. We may also use it to contact you, for example, as part of customer service or to send you updates about our games and Services. Additionally, we will use your data to manage your account and relationship with us, enhancing your experience when using our Services.

Analytics and Research

We use analytics tools, which may include third-party analytics tools, to collect information about how you play our games or use our Services. These tools may use cookies or similar tracking technologies. We may use your data to conduct research, surveys, or engage directly with you, for example, by sending you communications (including by email) for these purposes. We may also create reports, analyses, or similar services for our own research or business intelligence purposes, for example, to track potential issues or trends with our Services or test new game features and content.

Social and Community

We have several social and community channels to communicate with our players. If you choose to interact with those channels, we will receive your information and use it in connection with those channels, including engaging with you. We may also republish your posts to those channels.

Promotions and Competitions

Occasionally, we may run promotions or competitions where we collect certain personal information from you, such as your name, address, postal code, email address, or other information you submit to claim a prize. These competitions will have their own specific terms and conditions. However, we will use the personal information you provide for the purpose of running the competition and may publish the names and entries of competition entrants. This information may be stored and shared following this Privacy Policy.

Cheating, Crime, and Fraud Prevention

We may use personal data that we hold to prevent cheating, crime, or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention, such as the police.

Visiting Our Websites

When you visit our websites and forums operated by us (“Websites”), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimising the Websites, in connection with our advertising purposes, and for research or analysis.

Information Collected and Processed

  • Information you provide when filling in forms or creating posts on our Websites, or when you create an account with us.
  • Details of your use of the Websites and the resources you access (for example, information about how and when you use the Websites, or what device you use to access the Websites).
  • If you contact us or respond to messages and communications sent by us or other users of the Websites, we may keep a record of that correspondence.
  • Your interactions with us on our social media channels.
  • Information collected via cookies (small text files placed on your device), allowing us to collect data, such as your device’s model, operating system, screen size, and other information about how you use our Services. For more information, see Ad identifiers, cookies, and similar technologies below.

Use of Information

We, our suppliers, and group companies may use this information:

  • As necessary to provide the Websites and related services to you.
  • For contacting you, for example, as part of customer service or to send you updates about the Websites.
  • For managing your account and relationship with us and enhancing your experience on the Websites.
  • For research, surveying, and engagement, for example, by sending you communications (including by email) for these purposes.
  • For marketing and promotion of Wubu Apps’ products, for example, by sending you communications (including by email) for these purposes on our, or a third party’s, behalf. For example, we might send you information about merchandise related to our games. If you do not want us to use your data in this way, please contact us at [email protected].
  • To create reports, analyses, or similar services for our use for research or business intelligence, such as tracking potential issues or trends with the Websites.
  • For preventing cheating, crime, or fraud. We may also need to pass your information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
  • As otherwise set out in this Privacy Policy or as required by law.

Playing Socially

You can choose to connect our Services using an account with a third-party network (such as Facebook). If you do this, then your personal information will be visible to other players, and we’ll also use it for the other purposes set out in this Privacy Policy, including for Marketing and Advertising.

Connecting with a Third-Party Network

You can choose to log in to your account using your account details with a third-party network, such as Facebook or Google. This will allow you to log in on multiple devices and synchronise progress across those devices. Where available, you’ll also be able to see which of your friends are playing the same game and their progress (and they will be able to see you and your progress) or access other functionality we make available in our games and other Services.

Information We Receive from Facebook

If you log in using your Facebook account details, we will receive some of your Facebook account information. If you play our games online on the desktop version of Facebook.com, your basic Facebook account information will automatically be associated with your account. The information we receive depends on your Facebook settings but typically includes your basic public profile information, such as your username, email address, age range, gender, chosen language, country, friends list, and other public information.

We will also collect the email address associated with your Facebook account. You can choose not to allow us to access your email address in the Facebook dialog box the first time you link your Facebook account with your Wubu account. If you provide us with your email address, we may occasionally use it to send you marketing emails about our other games and Services. You can opt out at any time – see Opting-out of direct marketing.

Logging in with Facebook will not allow us to post anything to your page without your permission, and we will not receive information about your Facebook friends who do not play our games. If you do not want your Facebook friends to see you and your progression in our games, you can prevent this by disconnecting from Facebook within our games and updating your app permissions in Facebook settings.

We recommend reading Facebook’s Privacy Policy and reviewing your privacy settings regularly to ensure you fully understand how your Facebook data is shared.

Information We Receive from Google

If you log in to our services using your Google account details, we will receive some of your Google account information. The information we receive depends on your Google account settings but typically includes your basic public profile information, such as your name, email address, and profile picture. If you grant us access to your Contact List, we will use and store this to help you find Google contacts who are already playing our games.

You can revoke future access to your information at any time by following the steps at Google Account Help.

We recommend reading Google’s Privacy Policy and reviewing your privacy settings regularly to ensure you fully understand how your Google data is shared.

Marketing

Unless you opt out as explained below, we and our third-party partners use information collected about you to send marketing communications about other Wubu games and related Services based on your interests. For example, we may send emails, serve ads within our Services, or place ads on third-party websites, apps, and Internet-connected devices.

Promoting Our Services

We may use the information that we hold about you to promote our own Services in a number of ways, which may include:

  • Advertising on third-party websites, apps, and Internet-connected devices;
  • Showing promotions for other Wubu games within the games you play; or
  • Sending marketing materials by email.

What Information Do We Use for Marketing?

We use information about you to try to ensure that you only see marketing that might interest you. This includes using information we may have about you, such as:

  • Ad identifiers and other non-personal information collected from your device. For more details, see Ad identifiers, cookies, and similar technologies;
  • The games you play and information about how you interact with our games and Services;
  • Your age, country or region, and gender; and
  • Other information we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

Marketing Partners

When we market our games in media published by other companies, we use various third-party marketing partners to assist us, and we may share information we have collected about you with such third parties for these purposes.

Our marketing partners may help us serve ads to you by combining this information with data they have collected about you elsewhere. They collect this information when you use their services or third-party websites and services. Our partners use this information to make assumptions about the kinds of advertising you might prefer. If they determine that you may be interested in an advert for Wubu’s games or Services, they will show you a Wubu ad while you are using other websites and services.

By accepting this Privacy Policy and downloading or continuing to play our games, and unless you opt out of interest-based advertising as explained in this section, you consent to our marketing partners collecting and using information about you to improve advertising, targeting, and measurement systems as described in their privacy policies.

This Privacy Policy does not apply to the collection of your information by our marketing partners. We recommend that you review our partners’ privacy policies for more information. A list of our marketing partners and their privacy policies can be found here.

Opting-Out of Direct Marketing from Wubu

You can exercise choices over the direct marketing we send you in the following ways:

  • You can withhold your consent for us to send you direct marketing emails by opting out when we collect your email address or by choosing not to share your email address with us when you first create an account using your Facebook details.
  • You can remove yourself from receiving email marketing from us at any time by clicking the unsubscribe link in any direct marketing email we send you or by sending an email to [email protected].
  • To disable interest-based advertising, please see How to adjust your preferences for interest-based advertising below.

Note that if you opt out of receiving interest-based or targeted advertising, you will still see advertising and may see advertising for Wubu products, but that advertising will not be targeted using your personal information.

Advertising

Our games may include advertising for third-party products and services. By accepting this Privacy Policy and downloading or continuing to play our games or use our Services, and unless you opt out of interest-based advertising as explained in this section, you consent to us and our advertising partners collecting and using information about you to improve advertising, targeting, and measurement systems so that we can show you relevant third-party ads in our games.

Targeted Advertising

We use information that we hold about you to better target ads for third-party goods and services to people who might be most interested in them. These ads may be shown to you within our games or Services.

What Information Is Used for Advertising?

We use ad identifiers and other information that we collect about you, as described in this Privacy Policy, to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:

  • Ad identifiers and other information collected from your device. For more details, see Ad identifiers, cookies, and similar technologies;
  • The games you play and information about how you interact with our games and Services;
  • Your age, country and region, and gender; and
  • Other demographic and interest-based information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

Advertising Partners

When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.

Our advertising partners may combine this information with information they have collected about you when you use their services (or the websites or services of third parties) to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.

You consent to the collection and use of your data for targeted advertising purposes by our advertising partners as set out in this section and as further described in their privacy policies. We recommend reviewing our advertising partners’ privacy policies for more information. A list of our advertising partners and their Privacy Policies can be found here. You can refuse or withdraw your consent to such use at any time – for more information, see How to adjust your preferences for interest-based advertising.

Opting-Out of Interest-Based Advertising

You can choose to prevent your device’s ad identifier from being used for interest-based advertising by updating the settings on your device. For more details, see How to adjust your preferences for interest-based advertising below.

Please note that if you opt out of interest-based advertising, you will still be able to play our games, and you may still see advertising in our games, but those ads will not be targeted using information that we hold about you. However, they may still be delivered based on contextual criteria, such as the game in which the ad is displayed or the region in which your device is located.

Ad Identifiers, Cookies, and Similar Technologies

To provide our games, Websites, and interest-based advertising, we use ad identifiers, cookies, and similar technologies. This section describes our use of these technologies and how you can manage your preferences.

Purpose of Ad Identifiers, Cookies, and Similar Technologies

Ad identifiers, cookies, and similar technologies are used by us to provide our Services to you and collect data from your device. These technologies allow us and our third-party advertising partners to:

  • Recognise you and your device;
  • Provide interest-based advertising to you;
  • Allow our Services to interact with a third-party social network or platform (where you have chosen to allow such interaction);
  • Understand how you interact with our websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
  • Allow our payment processors to process your payment instructions; and
  • Enable us and third parties to provide you with more customized services, for example, to provide our Services in the correct language.

How Do Ad Identifiers, Cookies, and Similar Technologies Work?

Ad identifiers are non-permanent, non-personal identifiers, such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Cookies are small text files stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser.

How to Adjust Your Preferences for Interest-Based Advertising

You can choose to prevent your device’s ad identifier from being used for interest-based advertising, or you can reset your device’s ad identifier, by changing the settings on your device. Settings vary from device to device, but you will usually find the ad identifier settings under "privacy" or "ads" in your device’s settings.

If you live in the USA, Europe, or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting aboutads.info/choices (for US users), youronlinechoices.com (for European users), or youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).

If you choose to adjust your preferences to prevent these technologies, you may find that you cannot enjoy the full use of our Services.

Adjusting your preferences as described in this section does not mean you will no longer receive adverts; it only means the adverts you do see will be less relevant to your interests. We will also still use your device’s ad identifier to serve you with ads; for example, we may use this for frequency capping (to control the maximum number of times you see the same ad from us).

Your Rights

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

Your Rights Include:

Right of Access

You have the right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us specifying the information you would like to receive. We may request reasonable evidence to verify your identity before providing any information. Please note that we may not be able to provide all requested information, especially if it includes another person’s personal information. We will respond as soon as possible and within 1 month of receiving your request and verifying your identity.

Right to Correct Personal Information

We aim to keep the information we hold about you accurate and up-to-date. If you find that any information we hold about you is incorrect, please contact us at [email protected], and we will correct it as soon as possible.

Data Deletion

In certain circumstances, you have the right to request the deletion of personal information we hold about you. To request deletion, please Contact Us. Note that you must delete our games from your devices and clear our cookies from any browsers where you have played our games. We may still retain some information for specific reasons, such as legal requirements, technical security, or anonymized records.

Account Deactivation

If you have created an account with us, you can request deactivation by contacting us. We may ask for additional information, such as device details. Additional steps include disassociating your Facebook account from our games and deleting our games from your devices. Note that deactivating your account will result in the loss of game progress and any unspent virtual items, such as coins, which may not be restorable.

Data Portability

In certain circumstances, you may have the right to request the data you have provided to us to be made available to you for transfer to another data controller.

Restriction of Processing

You may have the right to request a restriction of the processing of your personal data, for example, if you are disputing the accuracy of the data we hold about you.

Right to Object

You have the right to object to the processing of personal data about you, particularly if the processing is based on legitimate interests.

Direct Marketing Opt-Out

If you have opted to receive direct marketing communications from us, you can change your preferences at any time by following the opt-out link in any marketing email we send. If you are subscribed to multiple types of communications, you may need to opt-out from each one individually. Please allow a few days for the update to take effect.

Additional Control Over Your Information

There are other ways to control the personal information we collect about you. You could:

  • Disconnect your Facebook or other social network account from our games;
  • Delete our games from your mobile device;
  • Reset your mobile advertising identifier or limit ad tracking using your device settings;
  • Limit or prevent the use of cookies in your web browsers.

More information on these options is provided elsewhere in this Privacy Policy.

Children

You must be over 13 to play our games and use our Services. For the full list of age restrictions by country, please see below. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.

General

Our Privacy Policy contains further details about:

  • Who we share your information with and the reasons for sharing it;
  • Measures we take to keep your information secure;
  • The legal bases under which we process your data;
  • How long we retain your information and where we store it;
  • When and why we share your information with third parties, including transfers outside of the European Economic Area (the “EEA”); and
  • Changes or updates to our Privacy Policy.

Sharing

In addition to the other disclosures described in this Privacy Policy, we will also share your information:

  • Where we have your consent to do so (including as set out in this Privacy Policy);
  • As reasonably necessary to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
  • Where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to our payment processors);
  • Where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
  • As we reasonably believe is permitted by law or regulation or as is necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Wubu, our users, or others; and
  • If there is a sale of the assets of Wubu, corporate restructuring, or as a result of a change of control of Wubu or one of its group companies, or in preparation of any of these events. Any third party to which Wubu transfers or sells Wubu’s assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

We may also share your information with our service providers if necessary to enable them to provide services to us.

Security

Wubu Apps takes appropriate security and technical measures to protect your information from unauthorised access, loss, and misuse. We also require our suppliers who process personal information on our behalf to take security measures designed to help protect your personal information. However, as the Internet is inherently insecure, we cannot guarantee the absolute security of your information online and offline. You should always take care when sharing information online.

Legal Bases

We process your information lawfully in accordance with one of the legal bases set out under European data protection law. The legal bases we rely upon include:

  • Contractual Necessity: Data used to provide you with Services that you have requested, such as games, customer services, chat functionality, and third-party social network connectivity;
  • Legal Obligation: Data used to comply with a legal obligation, such as maintaining tax records or responding to valid legal requests;
  • Legitimate Interests: Data used for purposes that do not harm your privacy, such as Marketing, Advertising, analytics, research, and optimisation of our games and Services; and
  • Consent: Data used based on your consent, for example, device information, ad identifiers, IP address, and other data. Consent can be withdrawn at any time as described in this Privacy Policy.

Retention

We will retain your information as long as your account is active or as necessary for the purposes described in this Privacy Policy. We also retain and use your information as required to comply with legal obligations.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time and will post the updated Privacy Policy on this page. Please check back periodically to ensure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, including exercising any of your rights, you can reach out to us in several ways:

For information collected under this Privacy Policy, the data controller is Wubu Apps Limited. Our Data Protection Officer can be contacted here: [email protected].

Fair Information Practices

In line with Fair Information Practices, we will take the following responsive actions should a data breach occur:

  • We will notify users via email within 7 business days.

We also agree to the individual redress principle, which ensures individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to comply with the law. This principle grants individuals enforceable rights against data users, as well as recourse to courts or government agencies for investigating and prosecuting non-compliance by data processors.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, grants recipients the right to have emails stopped from being sent to them, and outlines penalties for violations.

We collect your email address to:

  • Communicate important information and updates related to our services.

In accordance with CAN-SPAM, we agree to the following:

  • If you wish to unsubscribe from future emails, you can contact us at [email protected], and we will promptly remove you from all correspondence.

Contacting Us

If you have any questions regarding this privacy policy, you may contact us using the information below:

20 Newerne Street
Lydney, Gloucestershire GL15 5RA
UK

Email: [email protected]