Privacy Policy

1. Introduction

Gumwall lets Creators and their communities co-create a persistent, interactive canvas made up of individually owned digital spaces, optionally connected to third-party gaming accounts to verify playtime, rank, and achievement data. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights available to you. It applies to everyone who uses the Service - Viewers, Creators, and visitors to public Gumwall pages. It should be read together with our Terms of Service. By using Gumwall, you acknowledge that you have read this Privacy Policy. If you do not agree with it, please do not use the Service.

2. Information We Collect

2.1 Information You Provide Directly

• Account information: username, email address, password (stored in hashed form), profile photo, and date of birth (used solely to verify age eligibility and apply the correct protections under Section 9).
• Payment-related information: billing name and billing address. Full card numbers and other sensitive payment credentials are collected and processed directly by our third-party payment processor(s) - we do not store complete card numbers on our own servers.
• User content: any text, artwork, images, memes, or other media you upload to a Tile, your profile, or elsewhere on the Service.
• Communications: messages you send to support, feedback you submit, and information you provide when reporting content or disputing a Tile.
• Creator information: if you register as a Creator, we additionally collect payout details (e.g., bank or third-party payout account information), tax identification information (e.g., Form W-9, W-8BEN, or the equivalent for your country), and channel details.

2.2 Information From Connected Gaming Accounts

Gumwall lets you optionally link accounts from supported third-party gaming platforms, currently including Steam, PlayStation Network, Xbox Live, Riot Games, Epic Games, GOG, and Ubisoft Connect. Linking is always something you initiate - we never connect an account without your action and authorization through that platform's own sign-in process. When you link a Connected Gaming Account, we receive certain data made available through that platform's official API or authentication flow, which may include:

• Your public gamer tag, display name, and avatar;
• Total or per-title playtime;
• In-game rank, skill rating, or competitive tier;
• Achievement, trophy, or completion data; and
• Other public gameplay statistics the platform makes available to us.

We only request the categories of data needed to power Gated Real Estate (prerequisite verification), Verified Gamer Cred display, and Automated Stream Triggers. We do not receive your gaming platform password, payment details stored on that platform, or your private messages on that platform. Important: each linked platform's own privacy policy also governs how that platform collects, uses, and protects your data before it ever reaches us. We encourage you to review those policies directly. Gumwall is not responsible for the privacy practices of third-party gaming platforms.

2.3 Information Collected Automatically

• Device and log data: IP address, browser type, device identifiers, operating system, and referring/exit pages.
• Usage data: features used, Tiles purchased or upgraded, Faction participation, pages viewed, and similar interaction data.
• Cookies and similar technologies: see Section 5.

2.4 Information Generated Through Your Use of the Service

Your Tile placement, canvas content, Faction affiliation, gating/verification status, and public activity on Creator pages are generated as you use the Service and are described further in Section 4.1.

3. How We Use Your Information

We use the information described above to:

• Provide, maintain, and improve the Service, including rendering the Wall and processing Tile transactions;
• Verify Gated Real Estate prerequisites and display Verified Gamer Cred badges;
• Power Automated Stream Triggers and related broadcast overlay effects;
• Facilitate Faction and Turf War features and resolve disputes over contested Tiles;
• Process payments and pay Creator commissions;
• Communicate with you about your account, transactions, and - where you have not opted out - product updates and promotions;
• Detect, investigate, and prevent fraud, abuse, cheating, and violations of our Terms of Service;
• Comply with legal obligations and enforce our rights; and
• Produce aggregated or de-identified analytics to understand and improve the Service.

We do not use children's personal information for purposes beyond what is described in this Policy, and we do not use it to serve targeted advertising.

4. How We Share Your Information

4.1 Public Display Is Core to the Service

Gumwall is built around persistent, public visibility. Unless a Creator's page or specific feature is configured otherwise, the following are designed to be publicly visible to anyone who views a Creator's channel page: your Tile content, Tile placement and history, Verified Gamer Cred badges, Faction affiliation, and milestone participation. Do not upload or link anything to your Tile or profile that you do not want to be publicly visible. Your account email address, payment details, and precise date of birth are never displayed publicly.

4.2 Service Providers

We share information with vendors who perform services on our behalf, such as payment processing, cloud hosting, content delivery, customer support tooling, and analytics. These providers are contractually bound to use your information only to provide services to us and to protect it appropriately.

4.3 Connected Gaming Platforms

We communicate with linked gaming platforms only as needed to authenticate your account and refresh the data described in Section 2.2, consistent with your authorization.

4.4 Creators

Creators can see information relevant to their own channel, such as who owns which Tile on their Wall, gating/verification status, and public profile information. Creators do not receive your email address, payment information, or private account data.

4.5 Legal and Safety

We may disclose information where required by law, legal process, or government request, or where we believe disclosure is necessary to protect the rights, property, or safety of Gumwall, our users, or the public - including reporting apparent child exploitation to the National Center for Missing & Exploited Children (NCMEC) or equivalent authorities, as legally required.

4.6 Business Transfers

If Gumwall is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to standard protections.

4.7 With Your Consent

We share information in other circumstances only with your consent. We do not sell your personal information for money. See Section 8 regarding "sale" and "sharing" as those terms are specifically defined under California law.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to keep you logged in, remember preferences, understand how the Service is used, and (where applicable) measure the performance of promotions. These generally fall into: (a) strictly necessary cookies, (b) functional cookies, (c) analytics cookies, and (d) advertising/measurement cookies. Where required by law (for example, for users in the UK/EEA), we will request your consent through a cookie banner before setting non-essential cookies. You can control cookies through your browser settings; disabling some cookies may affect Service functionality.

6. Data Retention

We retain account and transaction information for as long as your account is active and as needed to provide the Service, comply with legal and tax obligations, resolve disputes, and enforce our agreements. We maintain a written data retention schedule and do not keep personal information longer than reasonably necessary for the purposes described in this Policy. Persistent Wall content and account deletion. The Wall is designed around persistent, collaborative content, including group Faction artwork that combines contributions from many Users. Where you submit a valid deletion request under Section 7 or 9, we will delete or de-identify the personal information associated with your account and Tiles (for example, disassociating your identity, gaming data, and account details from a Tile). Where technically and legally feasible, and where the content itself does not constitute your personal information, we may retain the non-personal creative content of a Tile as part of the collective Wall/Faction artwork, rather than removing your specific contribution from shared community art, unless applicable law requires full removal. We're happy to walk through the specific mechanics of this if it affects your product design.

7. Your Privacy Rights

7.1 EEA/UK Users (GDPR / UK GDPR)

If you are located in the European Economic Area or United Kingdom, you have the right to: access your personal data; correct inaccurate data; request erasure; restrict or object to processing; receive your data in a portable format; and withdraw consent at any time where processing is based on consent. We process your data on the basis of contract performance, your consent, our legitimate interests (such as fraud prevention and product improvement), and legal obligations. You may lodge a complaint with your local data protection supervisory authority. Where we transfer personal data outside the EEA/UK, we rely on appropriate safeguards such as Standard Contractual Clauses.

7.2 California Users (CCPA/CPRA)

If you are a California resident, you have the right to: know what personal information we collect, use, and disclose; request deletion; request correction of inaccurate information; opt out of the "sale" or "sharing" of personal information (as those terms are defined under California law, which can include certain advertising-related data sharing even without an exchange of money); limit use of sensitive personal information; and not be discriminated against for exercising these rights. [Confirm before publishing: if Gumwall uses third-party advertising or analytics pixels that could constitute "sharing" under the CPRA, include a "Do Not Sell or Share My Personal Information" link and honor Global Privacy Control signals.]

7.3 Other U.S. State Privacy Laws

Residents of states with comprehensive consumer privacy laws - which as of 2026 include Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and a growing list of others - may have similar rights to access, correct, delete, and opt out of certain processing. This list changes as more states pass legislation; we will honor applicable rights based on your state of residence.

7.4 Everyone Else

Regardless of location, you can request access to, correction of, or deletion of your information by contacting us using the details in Section 13, and we will respond consistent with applicable law.

8. "Sale" and "Sharing" of Information (California)

We do not sell personal information in exchange for money. [If Gumwall uses interest-based/third-party advertising cookies or pixels: to the extent any data sharing with advertising or analytics partners qualifies as a "sale" or "share" under the CPRA, we provide the opt-out mechanism described in Section 7.2.] We do not sell or share the personal information of Users we know to be under 16 years old without opt-in consent, consistent with California law.

9. Children's Privacy

Protecting young users is a priority, and this area of law is active and evolving - please treat this section as a starting framework, not a finished compliance program. Minimum age. The Service is not directed to children under 13, and our general minimum age to create an account is 13. Users between 13 and 17 need permission from a parent or guardian to use the Service, and specifically need parent or guardian involvement to make any purchase (see the Terms of Service). COPPA. If we obtain actual knowledge that a Service or portion of it is directed to children under 13, or that a specific user is under 13, we apply the protections required by the Children's Online Privacy Protection Act (COPPA) and its 2025 amendments (compliance-mandatory as of April 22, 2026), including:

• Providing direct notice to, and obtaining verifiable parental consent from, a parent or guardian before collecting personal information from a child under 13;
• Obtaining separate verifiable parental consent before disclosing a child's personal information to third parties for purposes that are not integral to providing the Service (for example, before enabling public display of a child's Tile, gaming stats, or Verified Gamer Cred badge to other Users);
• Maintaining a written information security program and a written data retention policy specific to children's personal information, and not retaining it longer than reasonably necessary;
• Giving parents the ability to review, request deletion of, and refuse further collection of their child's information; and
• Not conditioning a child's participation in an activity on disclosing more personal information than is reasonably necessary.

If we learn that we have collected personal information from a child under 13 without the required consent, we will delete it promptly. Parents who believe their child has provided us information without consent should contact us at [privacy contact]. State age-appropriate design laws. A growing number of U.S. states (including, as of 2026, Nebraska, Vermont, South Carolina, and others, with additional states' laws enacted but enjoined or pending) impose "age-appropriate design" obligations - such as high-privacy default settings for minors and restrictions on design features that encourage excessive engagement - on online services likely to be accessed by minors. Because this area is unsettled and rapidly changing (several state laws are currently subject to active litigation), Gumwall should confirm current obligations with counsel on an ongoing basis rather than relying solely on this Policy.

10. Data Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit, access controls, and a written information security program. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We encourage you to use a strong, unique password and enable any available multi-factor authentication.

11. International Data Transfers

We are based in India and may process and store information in the United States and other countries. If you access Gumwall from outside India, your information will be transferred to, stored, and processed in countries that may have different data protection laws than your own, using appropriate safeguards as described in Section 7.1.

12. Third-Party Links and Services

The Service links to or integrates with third-party platforms, including the gaming platforms listed in Section 2.2. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. Review their policies directly before linking an account.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by posting a notice on the Service, updating the "Last Updated" date, and - for material changes affecting how we handle children's information - providing additional notice as required by law. Continued use of the Service after changes take effect constitutes acceptance of the updated Policy.