Privacy Policy

FELGO GmbH (“Felgo”, “we” or “us”) offers a variety of products and services. The following Privacy Policy explains the manner in which Felgo collects, uses, maintains, protects and discloses information collected on the website domains felgo.com, v-play.com & their subdomains (“Site”) and from services & products available through the Site, referred to as “Service” (or “Services”).

Felgo will only collect, use and store Personal Information in a secure way in order to ensure confidentiality. Felgo will not share Personal Information with other parties without prior consent and unless it is necessary to provide our services. It may also be necessary to share Personal Information to comply with the law or protect our rights.

Furthermore, you have the right to be informed at your request about Personal Information Felgo collected, as well as its origin and the purpose of storage. In addition, you have the right to have such Personal Information corrected or deleted.

With this Privacy Policy, Felgo provides detailed information about how information is collected in concise and clear language wherever possible. If there are any questions about this Privacy Policy or the practices of this Site or Services, please contact us.

Definitions

Felgo offers Services for different groups of individuals, which are explained here:

• Website visitors: Each, a “Visitor”, referring to a person browsing the website.
• App & game developers: Each, a “Developer”, referring to a Felgo account holder using “Services”.

An app or game (“App”) is a computer program designed to run on a device such a mobile phone or desktop system.

Personal Information is data which relates to a specific identifiable person.

Non-personal Information is data that does not relate to a specific person. Felgo may combine personal and non-personal information, in which case Felgo will treat this bundle of information as Personal Information for as long as it remains combined.

What Information Is Collected

When you use Felgo Services, you trust us with your data. Felgo receives information about Visitors or Developers, their devices or interactions with provided Services in two ways:

• Things Provided: When Visitors or Developers actively provide information. For example, when a Developer creates a Felgo account, he or she will type in a first name and E-mail address.
• Things Done & Things Created: When our systems automatically collect information about browsers and devices and certain activity within the Services.

Visitors may access the Site anonymously. Felgo will collect personal identification information from Visitors or Developers only if they voluntarily submit such information by creating a Felgo account or providing the information within an App. Visitors or Developers can always refuse to supply personally identification information, except that it may prevent them from engaging with Felgo provided Services.

Felgo may collect and process both Personal Information and Non-personal Information. Felgo however does not ask for, collect or process any “Sensitive Personal Information”.

When registering for a “Felgo Account”, you give consent to have personalized data processed for the purpose of Felgo’s legitimate interests according to section How Information Is Used.

Things Provided

As a Visitor

Felgo does not ask for any information when browsing our Site before creating a Felgo account as a Developer.

As a Developer

When you sign up for a Felgo account, basic information is requested. Felgo only asks for required information that is needed to run Services and tries to keep that information as small as possible. This includes:

• E-mail address and a randomly chosen password: To link an account to a person and secure it with a password. Providing an E-mail address is required to authenticate an account and to reset the password for it.
• First name: the first name is used for E-mail communication to make it more personal. Feel free to provide a pseudonym if you want to.

Note: If signing up with a social network account like Facebook, Gmail or GitHub, Felgo does not ask for, or store additional information except the stated above. Especially Felgo does not read or process the birthdate, gender, Facebook/GitHub account ID, friend lists or anything similar.

During sign-up Felgo may also ask for information about interests and experience. This includes: The interest in App or game development, the role in and size of a team, a website and others. Providing this information is fully optional.

When subscribing to a paid license, the last name, the product purchased and the revenue from it is stored.

When using Felgo Cloud Builds, we ask you for a project name, repository credentials and optional code signing assets. All of those information is stored encrypted on our systems.

Things Done & Things Created

When using the Services – for example, browse the online documentation or work on an App or game in the development IDE – data is collected to make these services work for you. This is done by using industry-standard tracking mechanism (including cookies, JavaScript snippets and server logs) implemented on our own or provided by listed Data Sub Processors.

As a Visitor

As a visitor, information from what is done includes:

• Website pages visited, referring pages and actions performed on the Site in an anonymized way.
• Messages to Felgo’s support system or E-mail address, including information about the sender E-mail & IP address and date & time.
• Log information: When accessing Services, a variety of technical information is logged, including:
  • IP address and Cookie information
  • Device information, like hardware model, operating system and version
  • Browser information
  • Date/time of access

As a Developer

As a Developer, information from what is done includes:

• Website pages visited and actions performed on the website and its subdomains.
• Information provided when participating in community and forum pages, like new questions or answers to the community.
• How Felgo’s development IDE is used: Data about used version and operating system and used modes (e.g. debugger, designer, documentation) are collected.
• Login & registration status: date of registration, date of last login. From a signup, the country of residence is concluded to pay attention to regional characteristics like communication on holidays.
• Other information: Additional information from third parties may be obtained and combined with information that is collected.

If signed in with a Felgo Account, Felgo stores and protects what’s created using provided Services. This includes:

• Felgo license keys created and used Apps
• E-mails sent to and received from Felgo
• Apps created on Felgo Game Network service
• Interact with other Developers via forum pages on the website or through other provided Services
• License, download, install or use Felgo software development kits (“Felgo Engine”) and Apps
• Use Felgo Services like Felgo Cloud Builds, Felgo Cloud IDE or Felgo Game Network

How Information Is Used

Felgo uses the collected information to provide, administer, operate and improve Services. This covers the following purposes:

Operations

• Sign-Up & Account: To create, administer and troubleshoot accounts and Services, and to link to or combine with other gathered information.
• Terms of Service: To prevent fraud, enforce the relevant Terms of Service or licenses, and protect you and others.
• License Purchase: To credit or accept payments when placing an order with Felgo in a direct manner. In any ways, Felgo does not share this information with outside parties except to the extent necessary to provide the service. Entered credit card numbers, security codes or other payment-relevant information for transactions processed by our payment provider Bright Market, LLC d/b/a FastSpring, 801 Garden Street, Santa Barbara, CA 93101, USA, is never visible to or transferred to Felgo.

Improvements

• Analytics & Product Improvements: To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of products and services that Felgo and Developers provide. Felgo also uses information in the aggregate to understand how users as a group or as individuals use provided Services.

Communications

• Customer Service & Support: To provide & improve technical support and respond to inquiries.
• Forums & Community: To enable user-to-user communications.
• Information & Contact: To inform Developers of new products and services, including promotional offers and to contact you with information that are of potential interest. If you decide to opt-in to our mailing list, you will receive E-mails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future E-mails, you can do that on the profile page as a Developer or optional unsubscribe links at the bottom of an E-mail.

How Information Is Shared

In general, Felgo does not sell, trade, or rent collected information to others. Information might however be shared for the following reasons:

How collected or received information might be shared:

• Data Sub Processors: Felgo provides information to other companies to help operating our business and Services or to administer activities on Felgo’s behalf.
  • Non-personal Information is collected from or shared with:
    • Google Analytics platform provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For more information about how Google Analytics works, please visit http://www.google.com/policies/privacy/partners/
    • When using Felgo Cloud Builds: CircleCI provided by Circle Internet Services, Inc., 201 Spear Street, Ste 1200, San Francisco, CA 94105, USA. Fore more information about how CircleCI processes data and CircleCI sub-processors, please visit: https://circleci.com/privacy/
  • Non-personal Information and Personal Information is collected from or shared with:
    • Amplitude platform by Amplitude, Inc, 501 2nd Street, Suite 100, San Francisco, CA 94107, USA
    • Customer.io platform by Peaberry Software Inc., 921 SW Washington St, Suite #820, Portland, OR 97205, USA
    • Segment platform by Segment.io, Inc., San Francisco, CA 94111, USA
    • HubSpot platform by HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, USA
    • Help Scout platform by Help Scout, 131 Tremont Street, 3rd Floor, Boston, MA 02111-1338, USA
• E-Mail: E-Mails delivered to E-mail-addresses sent either directly to Felgo addresses or via the contact form are stored on servers of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When sending a message to Felgo’s domain E-mail addresses or using one of the contact forms, you consent to the disclosure of the Personal Information contained therein to Google, Inc.
• Safety, Security, and Legal Compliance: Information may be shared
  • To satisfy any applicable laws or regulations
  • If there is evident indication that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • When there is a good faith belief that Felgo is required to disclose the information in response to legal process (for example, when receiving a court order or similar legal process) or that there is a meaningful risk that poses a threat to the safety of you, another person or the public generally.
  • In order to protect the rights or property of Felgo, including to enforce the terms and licenses that govern the use of the Services.
• Anonymized and/or aggregated information: In case information is shared with third parties, it is anonymized.

How actions can result in sharing with others:

Sharing can happen within provided Services and outside it when taking certain actions. For example:

• As a Developer, when posting to support forums, the comment, first name and profile photo will be visible to other Visitors and Developers, which means that they can see that information.
• When commenting on a blog post on the Site, this will be visible to other Visitors & Developers.

International Privacy Laws

If visiting the Services from outside the United States, you might send information (including Personal Information) to the United States where used Data Sub Processors are located. For personal data received from the EEA, listed Data Sub Processors have certified their compliance to the EU-US Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union countries and therefore obliged themselves to comply with data protection principles similar to those governing within the EEA.

How Information Is Protected

Felgo adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information, password, transaction information and data stored on the Site or Services.

Servers, on which information is stored, are located within the European Economic Area (EEA). Felgo cannot ensure or warrant the security of any information transmitted or guarantee that information on Felgo Services may not be accessed, disclosed, altered or destroyed by breach of any used industry standard physical, technical or managerial safeguards.

For clients from the EEA, Felgo complies with the GDPR as set forth by the European Union regarding the collection, use and retention of personal data from the European Union member countries and Switzerland.

Sensitive data provided as a Visitor or Developer are stored encrypted on our systems. Sensitive and private data exchange between the Site and its Visitors or Developers (like logging in) happens over an SSL or similar secured and encrypted communication channel.

Accessing & Updating Information

Felgo respects privacy rights and provide with reasonable access to the Personal Data that may have been provided through use of the Services.

Felgo provides Developers to access and update their information by logging to your Felgo account and opening the profile page.

If you wish to access or amend any other Personal Information not included in the listed options above, or to request to delete any information obtained from Service usage, you can file a Data Subject Access Requests according to GDPR. Since DSAR is inherently a sensitive operation, such requests are handled by Felgo on a case-by-case basis and require the subject to proof identity of the requested account information. For a DSAR or more information on that, please contact us.

Your Choices About Collection and Use of Information

As a Visitor

• Cookies Opt-Out: Please see “Web Browser Cookies” section.

As a Developer

• You have the option to refrain from using the Service or to discontinue using the Service if you do not want information collected. To do so, open the profile page and submit an “Account Termination Request”. In case of termination, Personal Information will be deleted within a defined period of 30 days, unless further storage of such Information is required for a valid purpose (see Data Retention).
• You can opt out of communications like E-mail, by following the instructions in any marketing message you receive. However, Felgo reserves the right to send a message confirming the opt out and Developers who opt-out of marketing messages may still receive administrative, relationship, or transactional messages (for example, Felgo might send a notice about changes to these Terms of Service).

Data Retention

Personal Information is not stored longer as absolutely necessary to provide the Service and to fulfill the purposes for which initially collected, as listed in How Information Is Used, unless otherwise required by law. Please be aware that the encrypted storage in backup systems might be necessary for technical reasons for a period of up to 12 months from the termination of the Service.

Felgo retains and uses information as necessary to comply with legal obligations, resolve disputes, and enforce agreements as follows:

• Billing information is retained for a period of seven years as of their transaction date in accordance with the Austrian accounting and taxation laws.
• Information on legal transactions between Developers and Felgo is retained for a period of up to 10 years as of their transaction date, depending on the specific legal transaction.

Web Browser Cookies

Felgo uses cookies for the purpose of analytics information used by Data Sub Processors as listed under “How Information Is Shared” and to improve experiences within the Service. As a Visitor, the used web browser places cookies on the hard drive for record-keeping purposes. In order to control the collection of data for analytical purposes, you can install existing Cookie Opt-out Browser Add-Ons or set web browser to refuse cookies at all. If done so, note that some parts of the Site may not function properly.

Third Party Websites & External Links

Visitors may find content on our Site that links to the sites and services of our partners, suppliers, advertisers, licensors and other third parties. Felgo does not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Policy Changes

Felgo may update this Privacy Policy from time to time. If any change materially reduces your rights or the obligations of Felgo under this Privacy Policy, Felgo will post a prominent notice on this page notifying users when it is updated.

Felgo encourages Visitors & Developers to frequently check this page for any changes to stay informed about how Felgo is helping to protect collected information.

Legal Entity

Felgo processes Personal Information and Non-Personal Information both as a Controller (from Visitors and Developers) and as a Processor (from Visitors and Developers and from users of Felgo Game Network), as defined in the Directive of the GDPR. The legal entity as Controller and Processor is:

FELGO GmbH
Kolonitzgasse 9/11-14
1030 Wien, Austria

Contact

If there are any questions about this Privacy Policy or the practices of this Site or Services, please contact us.

This document was last updated on Jan 13, 2022 by FELGO GmbH, Kolonitzgasse 9/11-14, 1030 Wien, Austria