Privacy Policy of KingsIsle Entertainment, Inc.
Kingsisle Entertainment, Inc. (hereinafter: “we,” “us”) respects
the integrity of personal data, protects privacy and ensures the
security of its customers’ personal data.
In this Privacy Policy, we want you to understand what
information we collect and process about you when you use our
games and other services and for what purpose we collect such
data. In addition, we would like to inform you about the rights
you are entitled to if you have entrusted us with your personal
data as part of our offers.
A) Data processing with respect to EU/EEA/UK/Brazil Residents
1. Controller
Kingsisle Entertainment, Inc.
301 Sundance Pkwy, Suite 100
Round Rock
TX 78681
United States of America
Telephone: +1 972 265 1900
(Not for support queries)
We are the controller within the meaning of Article 4 No. 7 of
the General Data Protection Regulation (GDPR) and other data
protection regulations. As the controller, we decide, if
necessary, jointly with third parties, on the purposes and means
of processing personal data. This is contingent upon the
processing being lawful.
If you're an EU/EEA/UK/Brazil resident you can contact our external Data Protection Officer by emailing to: privacy.kingsisle@gamigo.com.
You can contact our representative within the European Union by
writing a letter to
gamigo AG
Behringstr. 16b
22765 Hamburg
Germany
and by emailing: EURepresentative@gamigo.com
4. Definitions
Decisive for the definition of the terms used in this Privacy
Policy, such as the term personal data, is Art. 4 of the General
Data Protection Regulation (GDPR).
5. Handling Personal Data
The provision of personal data on the internet always carries
the risk of unauthorized processing by third parties who gain
unauthorized access to this data, as no technological system can
be fully protected against external attacks.
We take technical and organizational measures to protect your
data from misuse. We process your data in accordance with the
requirements of German and European data protection law and
continue to further educate ourselves. The data processing is
carried out according to the current state of the art.
6. Origin of Personal Data
We obtain personal data in the following way:
We receive personal data from you when you provide it in the
course of creating an account on the KingsIsle website or using
our games and other services. Providing this information is
always voluntary. However, some of our services may require
certain information from you in order to function properly.
Examples: Registration/update of user accounts, support and
community management requests, use of the social functions
offered by us; purchases in our shops, e-mail address,
self-chosen nicknames in our offers, name, date of birth,
address.
6.2. Automatically collected and generated data
When you use our games and other services, data is automatically
collected and generated.
Examples: Device information, game data in our games, user
account and character IDs, information from your support or
community management request
7.
Scope and Purpose of the Processing of Personal Data and
the Legal Bases for Processing
The scope and purposes of the processing of your personal data
will depend on which of our games and other services you use
from us, i.e., not every one of our games and other services
includes all of the personal data processing practices described
herein. In the following, we would like to give you an overview
of the personal data that we process in connection with all of
our services. Furthermore, we have listed the different
categories of data and examples of personal data that can be
processed when using the corresponding service.
Personal data is all information about you and your factual and
personal circumstances, for example name, address or age. Data
that cannot be assigned to a specific natural person is not
personal data. For example, this can be statistical data that
describes a group.
Regardless of which of our games and other services you use, we
will treat your personal data confidentially and in accordance
with the statutory data protection regulations. We will not
share it with third parties without your consent, unless
permitted by law (e.g., because it is necessary to perform the
contract).
In the following you can also read on which legal basis the
respective processing of the listed data is based.
The main legal bases in scope are regulated in Art. 6 para. 1
sentence 1 GDPR. These are, as far as relevant for us, the
following cases:
Art. 6 Para. 1 Sentence 1 lit. a) GDPR: Data processing is based
on a consent that you have granted us.
Art. 6 Para. 1 Sentence 1 lit. b) GDPR: The data processing is
necessary for the performance of a contract to which you are a
party or is necessary for the performance of pre-contractual
measures taken at your request.
Art. 6 Para. 1 Sentence 1 lit c) GDPR: Data processing is
necessary for the fulfillment of a legal obligation to which we
are subject.
Art. 6 para. 1 sentence 1 lit. f) GDPR: The data processing is
necessary to protect our legitimate interests or those of a
third party, unless your interests or fundamental rights and
freedoms requiring the protection of personal data, outweigh
these.
7.1. Use of our websites
7.1.1. Forums
Our websites offer you the opportunity to use our online forums.
There you can create a publicly viewable profile in which you
can voluntarily add additional information. In our forums you
can make public posts and send private messages to other users.
You can also have yourself included in public member lists.
Examples of processed data: content of the forum (version,
division, location, time zone, authorizations, forum user
account, posts), IP address, content written, name, date of
birth, address.
The processing of personal data described above is legal under
Art. 6 para. 1 sentence 1 lit. b) GDPR.
7.1.2. Transactions
On our websites, you can deposit real money on your user account
and purchase virtual currency or items directly. You can also
buy items or unlock features (e.g., character transfer) from
previously purchased virtual currency on our websites. To do so,
you will usually have the option of using various payment
providers to pay for our games and other services.
The payment service providers process the data as a separate
controller. Please read the respective privacy policy of the
payment service provider carefully. You will find an overview of
our partners in the “Transactions” section:
Examples of processed data: IP address, order information
(especially time, product ordered and the quantity, transaction
number), subscriptions, chargebacks, refunds, gifts, payment
details (especially also payment method, voucher redemption),
shipping data (e.g., for CD shipping), location data (e.g.
street address, city, state), licenses for consumable goods in
games.
To make sure, that the payment information you provided is correct (e.g., typos), we use Google's Address Validation API together with the Google Maps API(s) to validate whether an entered address is a real location or contains any errors. For this, your IP address, and the information you have provided in the address field will be shared with Google Ireland Ltd. in Dublin. For more information about how Google is processing personal data, please consult the Google Privacy Policy.
For every transaction we use the services of Avalara, Inc.,
Seattle, Washington to determine the exact tax rate. Data shared
with Avalara includes location data and the user ID of the
buyer.
The processing of personal data described above is legal under
Art. 6 para. 1 sentence 1 lit. b) GDPR. The legal basis is Art.
6 para. 1 sentence 1 lit. c) GDPR in conjunction with Secs. 147
para. 1 no. 4, para. 3 AO (German Fiscal Code); Sec. 257 para. 1
no. 4, para. 4 HGB (German Commercial Code); Sec. 14b para. 1
UstG (German Vat Act), insofar as the transaction data are
posting documents.
7.1.3. Log files
We use log files to analyze and optimize the functionality of
our websites, to find errors, to ensure the security of our
systems (e.g., to fend off cyberattacks) and to ensure
compliance with the Terms of Use for our websites and our games,
the game rules and applicable law.
Examples of processed data: Connection type, IP address, URL of
the referring website from which the file was requested, date
and time of access, browser type and operating system as well as
hardware information, the page you visited, hardware features,
duration and frequency of use.
On the one hand, the described processing of personal data is
lawful according to Art. 6 para. 1 sentence 1 lit. b) GDPR,
because we need the data in order to fulfill the user agreement
concluded with you, and on the other hand according to Art. 6
para. 1 sentence 1 lit. f) GDPR, because our users and we have a
legitimate interest in our websites being secure and functional.
7.1.4. Downloads
You can download various programs, especially the game installer
on our websites. As part of this, personal data is processed so
that we can check whether the download is working, and if not,
where there are errors, in order to optimize our service
quality. Error sources can e.g., originate from a certain
region, emanate from a certain internet provider, or result from
only the partial transfer of the file.
Examples of processed data: Transferred data quantity, time of
download, access status (transfer file, file not found), IP
address, hardware features, speed.
The described processing of personal data is legal according to
Art. 6 para. 1 sentence 1 lit. b) GDPR, insofar as it concerns
our obligation from a user agreement concluded with you (e.g.,
for the provision of the game software) and according to Art. 6
para. 1 sentence 1 lit. f) GDPR, given that we have a legitimate
interest in providing our services safely and reliably, free of
technical errors.
7.1.5. Cookies
When you visit our websites, we want to make sure that you
always get the information that is most relevant to you. For
this reason, we use cookies on our websites.
Cookies are small text files that are stored on your local
device. They ensure that we recognize you the next time you
visit our websites and that we can offer you a personalized
experience on our websites.
There are permanent cookies, which remain stored for a longer
period of time and so-called session cookies, which are only
placed as long as your visit lasts and are deleted as soon as
you leave.
Sometimes we place cookies ourselves, other times, however, we
use cookies from third parties (so-called third-party cookies).
We use cookies so that we can show you our websites, you can
take advantage of comfort functions, we can carry out
statistical evaluations and for marketing purposes.
If cookies contain personal data that is required for the
operation of our websites, the legal basis for the processing of
your personal data is Art. 6 (1) p. 1 lit. f) GDPR. All other
cookies are only set if you give us your consent. If cookies
contain personal data, the legal basis in this case is Art. 6
para. 1 p. 1 lit. a) GDPR.
7.1.6. Advertising
In order to improve our advertising offer, we sometimes use
small images on our websites, which independently collect data.
This aims at only showing you advertising that is relevant to
you. It also allows us to see if you have clicked on our
advertisement.
Examples of processed data: IP address.
The processing of personal data described above is lawful as per
Art. 6 para. 1 sentence 1 lit. f) GDPR, as our partners and we
have a legitimate interest in determining the success of
services and campaigns.
7.2. Use of our games
If you want to play our games, you will need to create a
KingsIsle user account on the KingsIsle games websites.
After registering a KingsIsle user account, you can login into
and play any of KingsIsle’s games (“game registration”).
A KingsIsle user account is created when you register on any of
KingsIsle’s game websites. You need your account in order to
write forum posts on our game pages, or to participate in online
games and make payments. You can enter some information under
the user account manually, and some information is generated
automatically. You can view most of the data when you log in and
update it in the user account management pages.
Examples of processed data: Account name, your name, age,
gender, email address and former email address, account region,
preferred language, date of birth, home address, shipping
address, account links, opt-in and opt-out details.
The processing of personal data described above is legal under
Art. 6 para. 1 sentence 1 lit. b) GDPR.
7.2.2. Log files
We use log files to analyze and optimize the functionality of
KingsIsle game services, to find errors, to ensure the security
of our systems (e.g., to fend off cyberattacks) and to ensure
compliance with the Terms of Use for our websites and our games,
the game rules and applicable law.
Examples of processed data: Connection type, date and time of
access, IP address, and operating system as well as hardware
information, hardware features, duration and frequency of use.
On the one hand, the described processing of personal data is
legal according to Art. 6 para. 1 sentence 1 lit. b) GDPR,
because we need the data in order to fulfill the user agreement
concluded with you, and on the other hand according to Art. 6
para. 1 sentence 1 lit. f) GDPR, because our users and we have a
legitimate interest in our websites being secure and functional.
7.2.3. Downloads
For the most part, you must download our games and other
services offered in order to use them. Our games are updated
regularly, so updates are provided and must be installed. As
part of this, personal data is processed so that we can track
whether the download (and thus our offered game or other
service) works, and if not, where there are errors. Error
sources can e.g., originate from a certain region, emanate from
a certain internet provider, or result from only the partial
transfer of the file.
Examples of processed data: Transferred data quantity, time of
download, access status (transfer file, file not found), IP
address, hardware features.
The described processing of personal data is lawful according to
Art. 6 para. 1 p. 1 lit. b) GDPR and because of the need to
ensure a safe operation of our games, according to Art. 6 para.
1 p. 1 lit. f) GDPR.
7.2.4. Gaming data
When you play our games, data is generated that stores your game
progress. Among other things, we keep records of game licenses,
progress, history, statistics, in-game purchases and
interactions with other users.
On the one hand, we process this data to enable us to provide
support for the affected user in the event of an error. On the
other hand, we must ensure that the user is compliant with our
Terms of Use, the rules of the game and applicable law (e.g.,
data protection and criminal regulations) in order to guarantee
a flawless gaming experience. In particular, the maximum
permitted user accounts per person according to our Terms of Use
(“multi-accounting”) must not be exceeded, and the use of fraud
software which is used to gain in-game advantages or for attacks
on technical systems must be prevented. For this purpose, we use
various protection programs that also process personal data.
Examples of processed data: Purchased items (e.g., skins,
portraits, gold, boosters), other unlocks, character names,
social exchanges, connected games, chat logs, progress, game
history, tasks in progress, game statistics, guild information,
in-game messages, friend lists, inventory items (equipment,
skills, etc.), screenshots, technical user data such as browser
data, IP address, user account information.
The processing of personal data described above is legal under
Art. 6 para. 1 sentence 1 lit. b) GDPR. The processing of
personal data for the purpose of preventing fraud and
manipulation is also legal under Art. 6 para. 1 sentence 1 lit.
f) GDPR, as we and our users have a legitimate interest in
ensuring that the services, we offer are free from manipulation
and that the general terms and conditions, rules of the game and
applicable law are complied with.
7.2.5. Use of “Social Logins”
We don’t support social logins to play our games.
7.2.6. Support
We are happy to support our users and are always happy for you
to contact us. If you create a ticket for our games and other
services, or contact us via contact form, mail or e-mail, we
need information to help you with your request and to answer it.
We also use this information to optimize our services. Please
contact us for your support requests primarily via our ticket
system (https://eu.wizard101.com/CustomerSupport/game) - login required.
You can also reach and contact us via social media (e.g.
Facebook) Personal data is collected by the provider of the
respective service. Please review their privacy policy before
contacting us. We only receive the data that is generally
required when contacting us (such as the user name).
Examples of data processed: problems encountered, experiences,
sanctions (ban, mutes), contact details, contact methods
(ticket, e-mail, contact form, post, social networks),
description of the problem in the service ticket, notes on the
user account, ticket chat log, documents used to authenticate
user accounts (e.g. information on the user account, screenshots
of invoices).
The processing of personal data presented is lawful under Art. 6
para. 1 sentence 1 lit. b) GDPR to the extent that the contact
is necessary for the performance of the contract or the
implementation of pre-contractual measures. Insofar as the
contact is made for the other purposes mentioned, the processing
is lawful according to Art. 6 para. 1 sentence 1 lit. f) GDPR,
as our users and we have a legitimate interest in helping our
users with (technical) problems and supporting them within the
scope of our services.
7.2.7. Transactions
In our games, you can purchase items or unlock features (e.g.
character transfers) for virtual currency or, in some cases,
real money.
The payment service providers process the data as a separate
controller. Please read the respective privacy policy of the
payment service provider carefully. You will find an overview of
our partners in the “Transactions” section:
Examples of processed data: IP address, order data (in
particular time, product ordered and the quantity, transaction
number), subscriptions, chargebacks, refunds, gifts, payment
details (in particular also payment method, coupon redemption,
delivery address), location data (e.g. street address, city,
state), licenses for consumer goods in games.
For every transaction we use the services of Avalara, Inc.,
Seattle, Washington to determine the exact tax rate. Data shared
with Avalara includes location data and the user ID of the
buyer.
The processing of personal data presented is legal under Art. 6
para. 1 sentence 1 lit. b) GDPR. The legal basis is also Art. 6
para. 1 sentence 1 lit. c) GDPR in conjunction with Secs. 147
para. 1 no. 4, para. 3 AO (German Fiscal Code); Sec. 257 para. 1
no. 4, para. 4 HGB (German Commercial Code); Sec. 14b para. 1
UstG (German Vat Act), insofar as the transaction data are
posting documents.
7.2.8. Push messages
Some of the games and other services allow you to stay up to
date using push messages. They inform you about important events
or remind you of certain events. The device token allows us to
identify the phone based on the app-device combination issued by
the providers of push notification gateways. This enables
gateway providers to forward messages and ensure that the
notification is only sent to devices that have the unique
app-device combination.
Examples of processed data: Content of the sent message, date of
the sent message, user account, device tokens.
The above processing of personal data only takes place if you
have consented to being contacted via push messages. The legal
basis is on Art. 6 para. 1 sentence 1 lit. a) GDPR.
7.3. Transfer to users or the public
When you use our games or other services, your personal
information (e.g. character name, nickname, e.g. in forums) may
be visible to other users or the public. This is the case, for
example, when you post in our forums, post messages in the
public chat of our games, participate in competitions or use
leader boards (Competition Boards).
Examples of processed data: Name of the game figure, nickname,
e.g. in forums.
The processing of personal data described above is legal under
Art. 6 para. 1 sentence 1 lit. b) GDPR. In addition, the
processing is legal as per Art. 6 para. 1 sentence 1. lit. f)
GDPR, having in mind that our users and we have a legitimate
interest in an open exchange between our users about our games
and services and other topics.
7.4. Participation in competitions
We will be hosting competitions at irregular intervals where you
can win physical or digital prizes. The task that needs to be
accomplished to participate in the respective competition can be
found in the announcement of the competition. Depending on the
nature of the prize and the required task, different
corresponding personal data will be processed to run the
competition. The announcement of the respective competition will
also include information about what kind of personal data will
be used. Please read the announcement of the competition as well
as the terms of participation carefully before participating in
the competition.
Examples of data processed: E-Mail Address, Address
This processing of personal data is legal according to art. 6,
para. 1, sentence 1 b) of the GDPR. In the case that a different
legal basis is relevant, this will be stated in the competition
announcement.
7.5. Participation in surveys
You have the opportunity to participate in our surveys. In these
surveys, we would like to learn more about how you use our
services and our games and how you feel about them. The results
of the surveys will be used to improve our services and games.
Examples of data processed: E-Mail Address, your answers
This processing of personal data is legal according to art. 6,
para. 1, sentence 1 f) of the GDPR. In the case that a different
legal basis is relevant, this will be stated in the respective
survey or in the announcement of the respective survey.
7.6. Case records
We keep case records for legal disputes with which we are
confronted.
Examples of processed data: Name, address, correspondence
The described processing of personal data is lawful according to
Art. 6 para. 1 lit. f) GDPR, as we have a legitimate interest in
protecting and asserting the rights of third parties and our
rights.
7.7. Marketing and newsletters
We can inform you by newsletter about similar goods and services
according to Sec. 7 para. 3 UWG (German Unfair Competition Act),
for example about other games from us. You can unsubscribe from
receiving further newsletters at any time free of charge using
the link contained in the newsletter (“Unsubscribe button”). In
addition, we inform you by newsletter about all offers, services
and other activities by us or the other companies in the gamigo
group and about all other offers, services and other activities
by third parties in connection with the offers, services and
other activities of one or more companies in the gamigo group
(so-called gamigo group newsletter) if you have previously
consented to this newsletter being sent to you. You can also
unsubscribe from this newsletter free of charge at any time
using the unsubscribe button contained in the newsletter.
Newsletters are sent at our request by our service provider.
Your e-mail address, which receives our newsletter, and other
personal data are temporarily stored on the service provider’s
servers. This information is used to send and evaluate the
newsletter. For this purpose, so-called tracking pixels are
used, i.e. in our newsletter there is a non-visible image file
which transmits technical information to the service provider
when the newsletter is opened (e.g. whether the newsletter has
been opened). Your data will not be used by the service provider
independently to send the newsletter.
We also place banner ads on websites, i.e., we provide our
partners with a graphic that they can integrate on their
website. The banner contains a hyperlink so that the user can
reach one of our websites. In order to enable a statistical
evaluation, an ID is generated using a pixel-code to determine
how users became aware of our products and, if applicable,
whether they have completed a payment transaction.
Examples of processed data: IP addresses, the language used,
hardware, how the newsletter was handled, i.e., when it was
read, and which links were clicked on.
The described processing of personal data, i.e., the sending of
newsletters, has as its basis Art. 6 para. 1 sentence 1 lit. f)
GDPR in conjunction with Sec. 7 para. 3 UWG for the advertising
of our own similar goods and services, on the other hand, Art. 6
para. 1 p.1 lit. a) GDPR in connection with Sec. 7 para. 2 no. 3
UWG if you have consented to the gamigo group newsletter being
sent to you. We base the use of the pixel-code on Art. 6 Para. 1
S.1. lit. f) GDPR, as we have a legitimate interest in
customizing our information according to the recipient.
We collect contact details of journalists in order to provide
them with specially prepared information about our services.
Examples of processed data: Name, company, email, phone number.
The above processing of personal data is lawful under Art. 6
para. 1 lit. a) GDPR.
7.9. Processing for legal reasons
We pass on personal data insofar as we are legally obliged to do
so. This can happen, for example, as a result of a court or
public prosecutor’s order. In doing so, strict attention is paid
to ensuring that all statutory requirements are met before
passing on the data. In general, only certain data is requested
(e.g., technical user data), but in principle the obligation to
pass on data may apply to all data collected. Before each
transfer of personal data, we critically check whether we are
obliged to do so.
We also pass on personal data in the context of legal
proceedings (e.g., to external lawyers) if this is necessary to
assert our rights (e.g., to protect intellectual property
rights).
Examples of processed data: Contact details, user account
information.
We will only process personal data for legal reasons as
described above if it is compliant with the applicable law. The
legal basis is by Art. 6 para. 1 sentence 1. lit. c) GDPR for
the fulfillment of a legal obligation or under Art. 6 para. 1
sentence 1. lit. f) GDPR because we have a legitimate interest
in ensuring that our rights are safeguarded or enforced.
8.
Storage Duration and Deletion of the Collected Data
We store personal data only as long as there is a concrete
purpose for this. The duration of the storage depends on the
purpose of the processing, the requirements of the processing,
as well as on your and our interests and rights and, if
applicable, the interests and rights of third parties. We always
store personal data as briefly as possible (principle of data
economy data/minimization), but at the same time we observe the
statutory requirements which stipulate a minimum retention
period (e.g., in commercial and tax law of up to 10 years, Sec.
257 para. 4 of the German Commercial Code, Sec. 147 para. 3 of
the German Fiscal Code).
In any case, the following shall apply: If the purpose of
processing has ceased to exist or if data is no longer required
to achieve this purpose and there are no further statutory
storage obligations to the contrary, we delete the relevant data
(e.g., we delete support tickets at the latest 9 months after we
have processed your request).
9. Recipient of Personal Data
To achieve the processing purposes described above, we pass on
personal data to various categories of recipients. The concrete
passing on of personal data about you depends largely on which
of our services you use.
We share personal data with the following categories of service
providers as processors: service providers in the context of
fraud and manipulation prevention, , to service providers to
conduct surveys, to service providers for analysis services, to
payment service providers, to service providers for sending
newsletter, to service providers for advertising services, data
centers, as well as to subsidiaries and affiliated companies
within the meaning of Sec. 15 AktG (German Stock Corporation
Act). The transfer of the personal data to the respective
recipient as processor is lawful under Art. 28 GDPR.
We pass on personal data to the following categories of service
providers as independent controllers: Lawyers, authorities, the
police, payment service providers, and providers of “social
logins.”
9.1.
Disclosure to third parties in the context of the use of
non-essential cookies
Where you consent to us setting non-essential cookies (see the
“Cookies” section), we share personal data with third parties.
This includes advertising partners, IT service providers, social
media providers and partners to analyze our website for
performance (i.e., measuring visits, traffic sources, and usage
patterns).
In the following sections, we will explain in more detail the
Google services that we use:
9.1.1. Google Analytics
Google Analytics is a widely used web analytics
service from Google Ireland Ltd. in Dublin. The methods provided
by Google Analytics enable a cross-device analysis of
website usage by placing cookies. The information generated
while using the website is usually transferred to a Google
server in the United States of America and also stored there.
Google uses the collected information to analyze the use of
websites on our behalf, to create reports and to provide
services for the purposes of market research and website
optimization. The anonymous IP address automatically transmitted
to Google is not combined with other Google data and is only
used by us for statistical analysis. The processing of the data
by Google can be prevented by a suitable browser add-on. If you
use a mobile device, it is possible to deactivate Google
Analytics using the following link. This prevents activity data
from being shared with Google Analytics via the
JavaScript (gtm.js) executed on
websites. For more information about Google Analytics,
please consult the Google privacy policy.
9.1.2.
Google “Remarketing and similar target groups
function”
We use the remarketing feature of Google Ireland Ltd. in Dublin,
which allows us to target visitors to a website with
personalized and interest-based advertising as soon as they
visit another Google Display Network site. For this purpose,
Google uses cookies that perform an analysis of website usage,
which forms the basis for creating interest-based online
advertising. To carry out this process, Google places a short
file with an identification number on your end device, through
which website visits and anonymized data on the use of the
respective websites are recorded. To the extent that visitors
have agreed to have their web and app browsing histories linked
by Google to their Google Account, and information from their
Google Account is used to personalize ads displayed, Google will
use data from these logged-in users along with Google Analytics
data to create and define target audience lists for cross-device
remarketing. This allows visitors to the website to be addressed
with personalized, interest-based advertising across devices.
Subsequent visits to other sites on the Google Display Network
will display advertisements that most likely reflect the product
and information areas previously viewed by the site visitor. If
you do not wish to use Google’s remarketing function, you can
deactivate it by adjusting the corresponding settings at
http://www.google.com/settings/ads. Google’s use of cookies can also be permanently disabled by
accessing the following links to the cookie management settings:
http://www.google.com/policies/technologies/managing/
http://www.google.com/policies/technologies/ads/
For more information about Google Remarketing, please consult
the Google privacy policy.
9.1.3.
Additional Google Analytics functions for display
advertising
The following Google Analytics functions are used on our
websites to display advertising:
- Report editor in Google Display Network
- Integration of Double Click Campaign Manager,
-
Google Analytics reports on performance by demographic
features and interests
The aforementioned reporting functions serve to evaluate and use
the data collected by Google in the context of interest-based
advertising as well as visitor data from third-party providers
in Google Analytics, such as age, gender and
interests. The end customer can deactivate Google Analytics for
display advertising at any time and adjust the ads in the Google
Display Network under the display settings at
https://www.google.de/settings/ads.
For more information about functionalities of Google analytics
for display advertising, please consult Google’s privacy policy.
9.1.4. Facebooks Ads
We use the remarketing feature of Meta Platforms Ireland, Ltd,
Dublin which allows us to target visitors to our Facebook pages
with personalized and interest-based advertising. For this
purpose, Facebook uses cookies that perform an analysis of
website usage, which forms the basis for creating interest-based
online advertising. To carry out this process, Facebook places a
short file with an identification number on your end device,
through which website visits and anonymized data on the use of
the respective websites are recorded. To the extent that
visitors have agreed to have their web and app browsing
histories linked by Facebook to their Facebook Account, and
information from their Facebook Account is used to personalize
ads displayed, Facebook will use data from these logged-in users
along with Facebook Ads data to create and define target
audience lists for cross-device remarketing. This allows
visitors to Facebook to be addressed with personalized,
interest-based advertising across devices. You can change your
ad preferences in your Facebook account under “Facebook Settings
& Privacy”.
We use the remarketing feature of Choozle, Inc., Denver,
Colorado which allows us to target visitors to a website with
personalized and interest-based advertising. For this purpose,
Choozle uses cookies that perform an analysis of website usage,
which forms the basis for creating interest-based online
advertising. To carry out this process, Choozle places a short
file with an identification number on your end device, through
which website visits and anonymized data on the use of the
respective websites are recorded. Subsequent visits to other
sites using Choozle will display advertisements that most likely
reflect the product and information areas previously viewed by
the site visitor. If you do not wish to receive ads from Choozle
you may
You can also configure your web browser to delete and/or control
the use of cookies.
9.1.6. Microsoft’s Advertising
We use the remarketing feature of Microsoft Corporation,
Redmond, Washington which allows us to target visitors to a
website with personalized and interest-based advertising as soon
as they visit another site on the Bing, AOL, and Yahoo Network.
For this purpose, Microsoft uses cookies that perform an
analysis of website usage, which forms the basis for creating
interest-based online advertising. To carry out this process,
Microsoft places a short file with an identification number on
your end device, through which website visits and anonymized
data on the use of the respective websites are recorded. To the
extent that visitors have agreed to have their web and app
browsing histories linked by Microsoft to their Network Account,
and information from their Network Account is used to
personalize ads displayed, Microsoft will use data from these
logged-in users along with Microsoft Advertising data to create
and define target audience lists for cross-device remarketing.
This allows visitors to the website to be addressed with
personalized, interest-based advertising across devices.
Subsequent visits to other sites Bing, AOL, and Yahoo Network
will display advertisements that most likely reflect the product
and information areas previously viewed by the site visitor. If
you want to opt out of Microsoft’s tracking, you can change the
settings in your web browser.
9.2.
Transfer to third parties outside of the EU or the
EEA
Compliance with Art. 44 et seq. GDPR is ensured if data is
transferred to a third country, i.e., before any personal data
is transferred to third parties in a country outside the EU or
the EEA (Norway, Iceland, Liechtenstein), we check whether these
countries offer an adequate level of protection. This can be
ensured by the fact that an adequacy decision by the EU
Commission has been made or that third country transfers are
permitted under other instruments regulated in Art. 46 et seq.
GDPR.
10. Your rights
In this section, we inform you about the rights you have in
relation to the processing of your data. You will find the exact
scope of the law mentioned in each case in the corresponding
article of the General Data Protection Regulation (GDPR). To
exercise your rights, please let us know you are an
EU/EEA/UK/Brazil resident and email us at
privacy.kingsisle@gamigo.com.
10.1.
Right of access by the data subject to Art. 15 GDPR
You have a right to access your data pursuant to Art. 15 GDPR
stored by us.
10.2.
Right to rectification pursuant to Art. 16 GDPR
You have a right pursuant to Art. 16 GDPR to have incorrect
personal data rectified or correct personal data completed.
10.3. Right to erasure pursuant to Art. 17 GDPR
Pursuant to Art. 17 GDPR, you have the right to have your
personal data stored by us erased. Please note that we cannot
undo an erase, i.e., all your game scores and progress are
permanently lost.
10.4.
Right to restriction of processing pursuant to Art. 18
GDPR
You have the right to restrict the processing of your data
pursuant to Art. 18 GDPR if you dispute the accuracy of the
data, if the processing is unlawful but you refuse to erase it,
if we no longer need the data but you need it for the assertion,
exercise or defense of legal claims or if you have lodged an
objection to the processing in accordance with Art. 21 GDPR.
10.5.
Right to data portability pursuant to Art. 20 GDPR
You have the right to data transfer pursuant to Art. 20 GDPR,
i.e., the right to receive selected data stored by us about you
in a common, machine-readable format, or to request the transfer
to another controller,
10.6. Right to object pursuant to Art. 21 GDPR
You have a right to object processing of data pursuant to Art.
21 GDPR.
10.7.
Right to withdraw the granted consent under data protection
law
If we process data on the basis of a consent given by you, you
have the right to withdraw the consent given at any time. The
withdrawal of consent does not render invalid the data processed
on the basis of the consent until the time of withdrawal.
10.8.
Right to lodge a complaint with a supervisory authority
pursuant to Art. 77 GDPR
You have the right to lodge a complaint with a supervisory
authority pursuant to Art. 77 GDPR. To consult the contact
details of the supervisory authorities in the German federal
states, please access the following link:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
11. Final Provisions
This Privacy Policy is merely to inform you and does not require
your agreement. We can and must adapt the Privacy Policy in the
event of a change in circumstances, i.e. other data protection
processes, and will inform you thereof by appropriate means.
B) Data Processing with respect to California Residents
California Privacy Notice
Personal Data
The following is a list of the categories of personal
information which we collect, or have collected, in the twelve
months prior to the effective date of this Privacy Policy, the
categories of sources from which such category is collected; and
the categories of third parties with whom we share such
information.
Categories we collect: User account
information, support information, gaming information,
transactions and purchases, posts in forums, email addresses,
mobile advertising identifiers, session and persistent cookies,
IP addresses, apps used or downloaded, web sites visited,
browser and operating system type, type of devise used,
information actively provided by users responding to a form in
an ad, randomly assigned identifiers, precise and general
location information and system information that our SDK may
collect about your device or network provider.
Sources: All the information above is collected
at our web sites and apps when you visit, register, play games
or from your mobile device when you are using an app and is
provided to us from the advertiser or publisher partners users
interact with by using their app or viewing an ad. We also
acquire this information from partners or from advertising or
data exchanges.
Location information: We acquire location
information when you provide it to an app which shares this
information with us.
Each Category is collected for the following business purposes:
providing games, processing transactions, supporting forums and
newsletters, delivering ads on publisher sites, reporting on ad
delivery, securing, protecting, auditing, bug and fraud
detection, debugging and repair of errors and the detection,
protection and prosecution of security incidents or illegal
activity; enforcing our terms and policies; complying with law.
Each Category is also collected for uses that advance our
commercial interests including creating profiles to target ads
on behalf of advertisers, using data collected from publishers
and from other third parties.
Sale/Sharing Information: Do Not Sell My Personal
Information rights
We may disclose the categories of information described above to
vendors, such as analytics companies and may sell the
information to advertisers, ad networks, other partners, and
third parties. Please let us know you are a California resident
and email us at privacy.kingsisle@gamigo.com for instructions
for how you can exercise your California access, deletion and Do
Not Sell rights.
Do Not Sell signal
If a partner has transmitted to us a Do Not Sell signal, we
will limit our use of information from that partner and we
will act only as a service provider as defined in the
CCPA.
Access and Deletion
Subject to certain exceptions and restrictions, the CCPA
provides California Residents the right to submit requests to a
business which has collected their personal information: (i) to
provide them with access to the specific pieces and categories
of personal information collected by the business about such
California Resident, the categories of sources for such
information, the business or commercial purposes for collecting
such information, and the categories of third parties with which
such information was shared; and (ii) to delete such personal
information.
If you are a California Resident, please let us know and email
us at privacy.kingsisle@gamigo.com for instructions for how
you can exercise your California access, deletion and Do Not
Sell rights.
California Residents may designate an authorized agent to make
California Requests on their behalf.
We do not discriminate against you
You also have the right to not be discriminated against (as
provided for in applicable law) for exercising certain of your
rights. We do not discriminate against California Residents for
exercising their rights.
We do not sell the personal information of minors under 16
years of age without affirmative authorization.
For questions or further information please contact
privacy.kingsisle@gamigo.com
C) Data Processing with respect to Residents of other
States/Countries
Personal Data
The following is a list of the categories of personal
information which we collect, or have collected, in the twelve
months prior to the effective date of this Privacy Policy, the
categories of sources from which such category is collected; and
the categories of third parties with whom we share such
information.
Categories we collect: User account
information, support information, gaming information,
transactions and purchases, posts in forums, email addresses,
mobile advertising identifiers, session and persistent cookies,
IP addresses, apps used or downloaded, web sites visited,
browser and operating system type, type of devise used,
information actively provided by users responding to a form in
an ad, randomly assigned identifiers, precise and general
location information and system information that our SDK may
collect about your device or network provider.
Sources: All the information above is collected
at our web sites and apps when you visit, register, play games
or from your mobile device when you are using an app and is
provided to us from the advertiser or publisher partners users
interact with by using their app or viewing an ad. We also
acquire this information from partners or from advertising or
data exchanges.
Location information: We acquire location
information when you provide it to an app which shares this
information with us.
Each Category is collected for the following business purposes:
providing games, processing transactions, supporting forums and
newsletters, delivering ads on publisher sites, reporting on ad
delivery, securing, protecting, auditing, bug and fraud
detection, debugging and repair of errors and the detection,
protection and prosecution of security incidents or illegal
activity; enforcing our terms and policies; complying with law.
Each Category is also collected for uses that advance our
commercial interests including creating profiles to target ads
on behalf of advertisers, using data collected from publishers
and from other third parties.
Sharing Information
We may disclose the categories of information described above to
vendors, such as analytics companies and may sell the
information to advertisers, ad networks, other partners, and
third parties.
Access and Deletion
Applicable law may provide you the right to submit requests to
us (i) to provide you with access to the specific pieces and
categories of personal information collected by us about you,
the categories of sources for such information, the business or
commercial purposes for collecting such information, and the
categories of third parties with which such information was
shared; and (ii) to delete such personal information. If
applicable law does not provide you these rights, we will
nevertheless do our utmost to fulfil your requests.
To send us an access and deletion request, or for questions, or
further information please let us know where you are from so we
can process your request and contact us under
privacy.kingsisle@gamigo.com
Version: 2023-06-02