Privacy Policy

Privacy Policy

 

General Information

 

1.                        Data Processor

FDG Entertainment GmbH & Co.KG (hereinafter referred to as „FDG“ or „we“), Romanstr. 7/9, 80639 Munich, Germany

 

2.                        Your rights

Under the GDPR you may have the following rights:

  • You may require access to personal data relating to you which is processed (Article 15 GDPR).
  • You may request the rectification, the erasure or the restriction of processing of personal data relating to you (Articles 16, 17 and 18 GDPR).
  • You have the right to data portability (Article 20 GDPR).
  • You may withdraw any consent you have given (Article 7(3) GDPR).

 

You may lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes data protection laws. The competent supervisory authority for us is: Bayerisches Landesamt für Datenschutzaufsicht, Promenade 27 (Schloss), 91522 Ansbach, Deutschland (https://www.lda.bayern.de/).

 

You may object, on grounds relating to your particular situation, at any time to processing of personal data concerning you (Article 21(1) GDPR). You may object at any time to processing of personal data concerning you for direct marketing (Article 21(2) GDPR).

 

For any inquires about our privacy policy or the processing of your data and in order to exercise your rights, please contact us at  http://www.fdg-entertainment.com/#contact .

 

3.                        Updates of the Policy

We may update this Privacy Policy from time to time to reflect changes to our information practices. We encourage you to periodically review our website for the latest information on our privacy practices.

 

Part I: Websites

 

1.                        Scope

This Part describes the processing of personal data in connection with the use of our website. For the processing of personal data in connection with our mobile applications and services, see Part II below.

 

2.        Collection and Processing of Personal Data

You may visit our website without registering or otherwise submitting personal data.

We only collect personal data in order to process a support query, which you can submit at http://www.fdg-entertainment.com/#contact . In this case, we collect your name, company, email address and your query. The legal basis for the processing is point (b) of Article 6 (1) GDPR.

We will not use your personal data for other purposes than processing your query. We will not transmit your personal data with third parties unless we are legally required to do so, for example to criminal prosecution authorities. Your data will not be processed outside Germany or the EU.

 

3.         Cookies and pseudonymous user profiles

“Cookies” are pieces of information that a web site transfers to an individual’s hard drive for record-keeping purposes. Cookies allow the web site to remember important information that will make your use of the site more convenient. Like most web sites, FDG uses cookies for a variety of purposes in order to improve your on-line experience. For example, we track the total number of visitors to our site on an anonymous aggregate basis.

We may also employ cookies so that we remember you when you return to the site and to help customize your FDGs web experience. We may associate personal information with a cookie file in those instances. Your user profile, however, will always be pseudonymous, that means a random number is used for the cookie. We will not associate other personal data (like your name, address etc.) with your user profile.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing a user-friendly website and optimising our services.

Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this web site.

 

4.                        Links to Other Sites

We may offer links to sites that are not operated by FDG. If you visit one of these linked sites, you should review their privacy and other policies. We are not responsible for the policies and practices of other companies, and any information you submit to those companies is subject to their privacy policies.

 

5.                        Analytics Software

 

Our website uses Google Analytics, a service provided by Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, to collect information about the use of our web site. Google Analytics uses cookies and collects information on users visiting the web site, on what pages users  access, etc. The information collected about your use of our web site will be transmitted to and processed by Google on servers in the United States. Google collects only the IP address assigned to you on the date you visit this site. Your IP address will be truncated within the area of the European Union/European Economic Area. Only in exceptional cases the whole IP address will be first transferred to a Google server in the USA and truncated there. The data collected by Google Analytics will not be associated with any other data held by Google.

Google will use this information in order to evaluate your use of the web site, to compile reports on website activities and to provide other services relating to our web site. The legal basis for the processing is point (f) of Article 6(1) GDPR. Our legitimate interests are to analyse our web site traffic to improve the user experience and to optimise the website in general. The transfer of data to Google is based on a data processing agreement.

You can prevent the collection and use of data (cookies and IP address) by Google by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout?hl=en. Further information concerning data privacy can be found at https://policies.google.com/privacy. Alternatively, you can use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features of this web site.

 

Privacy Policy (Part II: Apps and Services)

 

1.                        General

 

1.1.                    Scope

This Part II describes the processing of personal data in connection with the provision of our mobile applications and services (together “our Services”).

The processing of personal data in connection with our website is described in our website privacy policy in Part I above. The Policy also does not apply to your participation in sweepstakes or contests unless provided through our Services. We are not responsible for the actions of third party people or companies, the use of information you provide to them, or any products or services they may offer.

 

1.2.                    Consent

Before using the service, you are required to agree to the processing of personal data described in the Policy. If you do not agree to the terms of the Policy, please do not use our Services.

 

1.3.                    Children

We do not knowingly collect personal information from children under 16 years of age. If we become aware that we have inadvertently collected personal information from a child under 16 years of age, we well promptly delete such information. We do not allow our partners to collect personally identifiably information on children under 16 years of age. However, we and our partners collect information that is not personally identifiable, such as IP-based geolocation to ensure that our Services comply with applicable laws.

 

2.            Purpose of the Processing of Personal Data

We use information collected through our Services for the purposes described in the Policy or disclosed to you in connection with our Service. For example, we may use your information for the following purposes:

 

2.1.                    Registration, i.e. to

create game accounts and allow users use our Services or participate in sweepstakes and contests. The legal basis for the processing is point (b) of Article 6 (1) GDPR.

 

2.2.                    Providing our Services, i.e. to

– identify and suggest connections with other users of our Services and enable you to communicate with other users;

– operate and improve our Services;

– respond to your comments and questions and provide customer service;

– provide and deliver products and services you request.

Whenever you use our Services, we collect data about all of your interactions with the application and with the other players inside the game via server log files.  This information may be associated with your player ID, IP address or device ID for the purpose of providing you our Services and improving them. The legal basis for the processing is points (b) and (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing user-friendly Services and optimising our Services.

 

2.3.                    Marketing, i.e. to

– send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. The legal basis for the processing is point (b) of Article 6 (1) GDPR.

– communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Us and our selected partners. The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are advertising our Services and financing our Services.

 

2.4.                    Developing our Services, i.e. to

– understand you and your preferences to enhance your experience using our Services;

– link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing user-friendly Services and optimising our Services.

 

2.5.                    Retention of Information

We will retain personal data for as long as your account is active or as it is needed to provide you our Services.  If you wish to cancel your account or request that we no longer process your information, contact us at http://www.fdg-entertainment.com/#contact .  We will retain and continue to use your information, however, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The legal basis for the processing is points (c) and (f) of Article 6 (1) GDPR. The legitimate interests that we pursue is the establishment, exercise or defence of legal claims.

 

3.                        Disclosure of information

We do not share your personal information except as approved by you or as described below.

With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies.  If you no longer wish to allow us to share your information with third parties, please contact us at http://www.fdg-entertainment.com/#contact .  If you no longer wish to receive such communications from third parties, please contact that third party directly.

We may engage other companies and individuals to perform services on our behalf.  This includes analyzing data and providing customer support.  These agents and service providers may have access to your personal information in connection with the performance of services for Us.

We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others.  This includes exchanging information with other companies and organizations for fraud protection.

We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company.  You will be notified via email and/or notice on our site of any change in ownership or users of your personal information.

We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

 

4.                        Sign-in Services

You can log in to our Services using sign-in services such as Facebook Connect, Google+, Google Play Game Services, or Apple Game Center. These services will authenticate your identity and provide you the option to share certain personal information with Us such as your name and email address to pre-populate our sign up form.

We may collect and record information through the Sign-in Service in accordance with the policies and terms of the respective Sign-in Service.  The information we collect when you connect your user account to an Sign-in Service may include: (1) your name, (2) your Sign-in Service user identification number and/or user name, (3) locale, city, state and country, (4) sex, (5) birth date, (6) email address, (7) profile picture or its URL, and (8) the Sign-in Service user identification numbers for your friends that are also connected to our Services.

We may offer you the opportunity to invite your contacts from a Sign-in Service so that those contacts can be located in our Services games and/or you can invite them to join you in our Services.  The contact information will not be used for other purposes. You or the addressee may request us to remove this information.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interest that we pursue is providing user-friendly Services.

 

5.                        Push Notifications

We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you.  You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interest that we pursue is providing user-friendly Services.

 

6.                        Sweepstakes and Contests

We may provide you the opportunity to participate in a sweepstakes or contest through our Services. If you participate, we will request certain personal information from you.  Participation in these sweepstakes and contests are voluntary and you therefore have a choice whether or not to disclose this information.  The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code).

We use this information to notify winners and award prizes, to monitor traffic or personalize our Services.  We may use a third party service provider to conduct these sweepstakes or contests; that company is prohibited from using your users’ personal information for any other purpose.

The legal basis for the processing is point (b) of Article 6 (1) GDPR.

 

7.                        Analytics

 

7.1.                    Cookies

A cookie is a small text file that we transfer to your device, to identify a user’s device and to remember things about your visit, such as your preferences or a user name and password.  Information contained in a cookie may be linked to your personal information, such as your user ID, for purposes such as improving the quality of our Service, tailoring recommendations to your interests, and making our Services easier to use.  You can disable cookies at any time, although you may not be able to access or use features of the Service.

We may feature advertisements served by third parties that deliver cookies to your device so the content you access and advertisements you see can be tracked.  Since the third party advertising companies associate your computer/device with a number, they will be able to recognize your device each time they send you an advertisement.  These advertisers may use information about your visits to our Service and third party sites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing user-friendly Services and optimising them.

 

7.2.                    Mobile Analytics Software

We use mobile analytics software to allow us to better understand the functionality of our Services on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing user-friendly Services and optimising them.

 

8.                        Third Party Services

 

8.1.                    Analytics and tracking

Our Services may contain third party analytic and tracking tools from our service providers, including Flurry (flurry.com) and Hockey App (hockeyapp.net). Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, and IP address for the purpose of providing their services under their respective privacy policies. Our privacy policy does not cover the use of tracking tools from third parties.  We do not have access or control over these third parties.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interests that we pursue are providing user-friendly Services and optimising them.

Please refer to the privacy policies of our analytics partners for information on how to opt out at:

– http://hockeyapp.net/privacy/

– https://policies.yahoo.com/us/en/yahoo/privacy/index.htm

Our Services may use Google Analytics, a service provided by Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, to collect information about the use of our Services. Google Analytics uses cookies and collects information on users using our Services. The information collected about your use of our Services will be transmitted to and processed by Google on servers in the United States. The data collected by Google Analytics will not be associated with any other data held by Google.

Google will use this information in order to evaluate your use of the Services, to compile reports on Service activities and to provide other services relating to our Services. The legal basis for the processing is point (f) of Article 6(1) GDPR. Our legitimate interests are to analyse our Services to improve the user experience and to optimise the Services in general. The transfer of data to Google is based on a data processing agreement.

Further information concerning data privacy can be found at https://policies.google.com/privacy.

 

8.2.                    Ad Networks

We may feature advertising within our Service.  The advertisers may collect and use information about you, such as your Service session activity, device identifier, MAC address, IMEI, geo-location information and IP address.  They may use this information to provide advertisements of interest to you.

The legal basis for the processing is point (f) of Article 6 (1) GDPR. The legitimate interest that we pursue is financing our Services.

Please refer to the privacy policies of our advertising partners for more information on how to opt out at:

– https://answers.chartboost.com/en-us/articles/200780269

– https://home.tapjoy.com/legal/#privacy-policy

– http://www.vungle.com/privacy

– http://www.inmobi.com/privacy-policy

– https://www.adcolony.com/privacy-policy/

– http://www.google.com/policies/privacy

– http://www.millennialmedia.com/privacy-policy

– http://www.apple.com/legal/privacy/en-ww

– https://www.amazon.com/gp/help/customer/display.html?nodeId=468496

– https://www.heyzap.com/legal/privacy

– http://www.mopub.com/legal/

– http://unity3d.com/legal/cookie-policy#cookies

– https://www.applovin.com/privacy

In addition, you may see our games advertised in other services.  After clicking on one of these advertisements and installing our game, you will become a user of our Service.  In order to verify the installs, a device identifier may be shared with the advertiser.

 

9.                        Security of your Personal Information

We take reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.

Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems.  Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.  We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security.

 

10.                      International Transfer

Game data is stored on servers located in the United States via Amazon Web Services or profitbricks.com in Germany and may store information on servers and equipment in other countries.

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in the Policy.

The legal basis for transmitting data to recipients outside the EU is point (b) of Article 49 (1) GDPR.

Last updated: May 2018