Privacy
Policy

1. Scope

This policy covers the Wheeler Dealer marketing website at carwars.co.uk (the “Website”) and the Wheeler Dealer mobile game (the “Game”). Wheeler Dealer and CarWars.co.uk are trading names of Selloo Ltd. This policy does not govern Apple, Google, Cloudflare or other third-party services acting for their own purposes; their own notices apply when you use those services.

The Website is designed to work without advertising cookies, behavioural tracking, account creation, forms or newsletter sign-up. The Game is designed to remain playable offline and without a Wheeler Dealer account.

2. Who is responsible

The data controller is:

The publisher determines why and how personal information is used for the Website and the Game. A data protection officer has not been appointed unless the published contact details state otherwise.

3. Information we use and why

We do not ask for special-category information, precise location, contact lists, photos, microphone data or payment-card details. We do not use personal information to make decisions producing legal or similarly significant effects.

4. Cookies and local storage

The Website does not currently set first-party analytics, advertising or personalisation cookies and does not use browser local storage. Cloudflare may use strictly necessary security or load-balancing technologies to deliver and protect the Website. These are not used by Wheeler Dealer for behavioural advertising.

If non-essential cookies, pixels, analytics or similar technologies are added later, they must remain blocked until valid consent is obtained where required, with an equally easy way to refuse or withdraw consent. This policy and any cookie controls will be updated before that change goes live.

The Game stores the local data described above on your device because it is necessary to save play and remember your choices. You can remove local Game data using available in-app controls or by removing the Game, subject to operating-system behaviour and any platform-synchronised records.

5. Lawful bases

• Contract: to provide requested Game, Website, save/resume and support features.
• Legitimate interests: to secure and operate the services, prevent abuse, diagnose faults, maintain evidence of requests, and improve the product using proportionate aggregate information. These interests are balanced against your rights.
• Consent: for optional analytics, non-essential device access, advertising consent choices, and any non-essential cookies where required. Consent can be withdrawn without affecting earlier lawful processing.
• Legal obligation: to respond to lawful requests, protect rights, keep required records and comply with regulators or courts.

6. Sharing and processors

Information may be shared only where necessary with:

• Cloudflare, which hosts, delivers and protects the Website and processes network/security logs.
• Google Firebase, for operational configuration and, only after opt-in, Firebase Analytics.
• Google and consented advertising partners, for the controlled rewarded ads described above, only where the released configuration and applicable consent/age treatment permit a request.
• Apple Game Center and Google Play Games, when you choose to use native identity or leaderboard features.
• Professional advisers, authorities or courts, where reasonably necessary to establish, exercise or defend rights, protect users, or comply with law.
• A buyer or successor, if the relevant business or assets are reorganised or transferred, subject to confidentiality and applicable transparency requirements.

We do not sell personal information. The Website does not use cross-context behavioural advertising. In the Game, any personalised or targeted advertising treatment is governed by consent, age and platform/provider controls; where those choices do not permit it, the request uses a non-personalised treatment or is not made.

7. International transfers

Some service providers may process information outside the UK or European Economic Area. Where restricted transfers occur, the publisher will use an available lawful mechanism, such as UK adequacy regulations, an EU adequacy decision, the UK International Data Transfer Agreement or Addendum, EU Standard Contractual Clauses, and appropriate supplementary safeguards. You may request information about the applicable safeguards using the contact details below.

8. Retention

• Website security logs: retained only for the period reasonably required for delivery, security, abuse prevention and investigation, then deleted or aggregated in accordance with the hosting configuration and provider contract.
• Local Game data: kept on your device until you reset/delete it, remove the Game, or the operating system removes it.
• Analytics: event-level and user-level data is configured for a maximum retention period of 14 months in Google Analytics, after which it is deleted or aggregated in accordance with Google’s controls. Standard aggregated reports may be retained for longer.
• Advertising/consent records: retained for the period needed to honour and evidence choices, comply with advertising rules, prevent excessive frequency and resolve disputes.
• Leaderboard records: retained by Apple or Google under their platform rules and your platform account choices.
• Support and rights correspondence: retained while the request is active and afterwards only as needed for follow-up, legal limitation periods, security and compliance.

9. Your rights

Depending on your location and the circumstances, you may have rights to be informed; request access, correction, deletion, restriction or portability; object to processing based on legitimate interests or direct marketing; withdraw consent; and complain to a supervisory authority.

Requests can be sent to the privacy contact in section 14. We may need proportionate information to verify identity and scope. Rights are not absolute, but any refusal will be explained. UK users may complain to the Information Commissioner’s Office. EEA users may contact the data protection authority where they live, work or believe an infringement occurred.

Analytics consent can be changed in the Game’s settings. Advertising privacy choices, when required, are available through the in-app privacy-options entry point. Platform identity and leaderboard controls are managed through Apple or Google account settings.

10. Children

Wheeler Dealer is a general-audience game intended for players aged 13 and over. It is not directed to children under 13 and is not submitted to Apple’s Kids category or Google Play’s Families programme. It does not require a Wheeler Dealer account, public profile, chat, custom biography, photo upload or precise location. Core play remains available offline.

Players aged 13 to 17 still receive high-privacy defaults: no personalised-advertising or cross-app tracking consent is assumed, no precise location is requested, advertising creative is restricted to Google’s general-audience rating, ineligible rewarded ads are not requested, and optional analytics remains off until chosen. The Game does not claim to know an individual player’s age; Google child-directed and under-age-of-consent request tags therefore remain unspecified unless a future reviewed age-assurance flow can set them accurately. The publisher applies the UK Children’s Code and other age-appropriate requirements where they apply. If you believe a child has provided personal information directly to the publisher, contact us so it can be investigated and deleted where appropriate.

11. Regional rights

Residents of jurisdictions with additional privacy rights—including certain US states—may request the rights available under their local law. Where applicable, these may include confirmation, access, correction, deletion, portability, appeal and the right to opt out of sale, targeted advertising or certain profiling.

Wheeler Dealer does not sell personal information and does not currently use the Website for targeted advertising. We will not discriminate against you for exercising a privacy right. An authorised agent may submit a request where local law permits, subject to verification. If a request is denied, you may appeal by replying with “Privacy appeal”.

We do not offer a financial incentive in exchange for personal information. Browser “Global Privacy Control” signals will be honoured for any future processing to which an applicable opt-out right attaches.

12. Security

We use proportionate technical and organisational measures designed to protect information, including encrypted transport, restricted administrative access, data minimisation, service-provider controls, safe default configuration and separation of local Game data from optional analytics. No system is completely secure; please do not send unnecessary sensitive information in support messages.

13. Changes

This notice will be reviewed when the Website, Game, providers, legal requirements or data practices change. Material changes will be highlighted through the Website, Game or store listing as appropriate. The date at the top identifies the current version.

14. Contact

Questions, privacy requests and complaints should be sent to:

Selloo Ltd
Company number 07816159
Trading as Wheeler Dealer and CarWars.co.uk
privacy@selloo.com