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RubyWhirl offers free-to-play social games for adults only.

Privacy Policy

Last updated: 26 November 2025

Introduction

This Privacy Policy explains how RubyWhirl ("we", "us", "our") collects, uses, shares, and protects personal data when you visit and use rubywhirl.games (the "Site"). We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Site.

1. Data Controller

The data controller responsible for your personal data is:
RubyWhirl
123 Gaming Street
London, UK
EC1A 1BB
Email: privacy@rubywhirl.games

2. What Data We Collect

We collect the following types of personal data:

2.1 Data You Provide Directly

  • Age Verification: Confirmation that you are 18 years or older (stored locally in your browser)
  • Contact Information: If you contact us via email or phone, we collect your email address, phone number, and any information you provide in your message

2.2 Data Collected Automatically

  • Technical Data: IP address, browser type and version, operating system, device type, time zone setting, browser plug-in types and versions
  • Usage Data: Information about how you use the Site, including pages visited, time spent on pages, links clicked, and navigation patterns
  • Cookies and Similar Technologies: We use cookies, local storage, and similar tracking technologies. See Section 8 for more details.

2.3 Data We Do NOT Collect

Because RubyWhirl is a free-to-play platform with no real-money involvement, we do NOT collect:

  • Payment information (no credit cards, bank details, etc.)
  • Financial data
  • Identity documents
  • Account passwords (we don't have user accounts)

3. How We Use Your Data

We use your personal data for the following purposes:

  • To Provide the Service: To enable you to access and use the Site and its games
  • Age Verification: To ensure only adults aged 18+ access the Site
  • Analytics and Improvement: To understand how users interact with the Site and improve user experience, functionality, and content
  • Communication: To respond to your inquiries, feedback, or support requests
  • Legal Compliance: To comply with legal obligations and protect our legal rights
  • Security: To detect, prevent, and address security issues, fraud, or technical problems

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under UK GDPR:

  • Legitimate Interests (Article 6(1)(f)): We have a legitimate interest in operating the Site, improving our services, and ensuring security. We balance these interests against your privacy rights.
  • Consent (Article 6(1)(a)): Where we use cookies and tracking technologies, we obtain your consent via our cookie banner.
  • Legal Obligation (Article 6(1)(c)): To comply with applicable laws and regulations.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share your data with:

5.1 Service Providers

We may share data with third-party service providers who assist us in operating the Site, such as:

  • Web hosting providers
  • Analytics services (e.g., Google Analytics)
  • Content delivery networks (CDNs)

These providers are contractually obligated to protect your data and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your data if required to do so by law or in response to valid requests by public authorities (e.g., court orders, law enforcement).

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity.

6. Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

  • Age Verification Data: Stored locally in your browser until you clear your browser data
  • Analytics Data: Typically retained for 26 months, anonymized after 14 months
  • Contact Correspondence: Retained for up to 3 years after last contact
  • Server Logs: Retained for 90 days

7. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

  • Right of Access: Request a copy of the personal data we hold about you
  • Right to Rectification: Request correction of inaccurate or incomplete data
  • Right to Erasure: Request deletion of your personal data in certain circumstances
  • Right to Restriction: Request that we restrict processing of your data in certain situations
  • Right to Data Portability: Receive your data in a structured, commonly used format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent for processing based on consent (e.g., cookies)

To exercise these rights, contact us at privacy@rubywhirl.games. We will respond within one month.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on the Site.

What Are Cookies?

Cookies are small text files stored on your device by your browser. They help us remember your preferences and understand how you use the Site.

Types of Cookies We Use

  • Essential Cookies: Required for basic Site functionality, including age verification (stored in browser local storage)
  • Preference Cookies: Remember your cookie consent choices
  • Analytics Cookies: Help us understand Site usage and improve user experience (e.g., Google Analytics)

Managing Cookies

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of the Site. You can manage your cookie preferences via our cookie banner or by adjusting your browser settings.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit using HTTPS/SSL
  • Secure server infrastructure
  • Access controls and authentication
  • Regular security assessments

However, no method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

10. International Data Transfers

Your data is primarily stored and processed within the United Kingdom. If we transfer data outside the UK, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses approved by the UK authorities
  • Transfers to countries with an adequacy decision
  • Binding Corporate Rules

11. Children's Privacy

RubyWhirl is intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected data from someone under 18, we will delete it promptly.

If you believe we have collected data from a minor, please contact us at privacy@rubywhirl.games.

12. Third-Party Links

The Site may contain links to third-party websites (e.g., responsible gaming resources). We are not responsible for the privacy practices of these external sites. We encourage you to read their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on this page with a new "Last updated" date. Significant changes will be communicated via a notice on the Site.

We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

This Privacy Policy is part of our commitment to transparency and protecting your privacy. For more information about your data protection rights, visit our GDPR Information page.