Privacy policy for online services

Altigi GmbH/Goodgame Studios, Theodorstr. 42-90, Haus 9, 22761 Hamburg, and other companies of the Goodgame Studios Group (“Goodgame Studios”), take the protection of your personal information very seriously. The following privacy policy will provide you with information about the personal information that is collected and how it is processed and used.

Table of contents:

  1. Subject matter of this privacy policy
  2. Responsible contact
  3. Collection of information
  4. Cookies
  5. Cookies of third party providers and tracking
  6. Use of your personal information
  7. Transmission of personal information
  8. More information about the privacy policy
  9. Changing or deletion of data
  10. Security of your personal information
  11. Contact
1 Subject matter of this privacy policy
This Privacy Policy applies to all services offered on Goodgame Studios’ websites, in particular the Goodgame Studios portal at “www.goodgamestudios.com” and the individual online game websites.

Unless stated otherwise, this Privacy Policy is exclusively in place to regulate how Goodgame Studios treats your personal information. If you make use of services provided by third parties, only the Privacy Policy conditions of these third parties shall apply.

2 Responsible Contact
The responsible contact according to the Federal Data Protection Act is Altigi GmbH/Goodgame Studios, Theodorstr. 42-90, Haus 9, 22761 Hamburg.

If you have any questions concerning privacy policy matters, please contact privacy@goodgamestudios.com. By contacting this email address, you can inquire into privacy issues and review, change, or delete your personal information stored by Goodgame Studios. Alternatively, you can also contact us using the above postal address. If possible, please include the online or mobile game that you have played, the server, and your player name.

3 Collection of information
In principle, you can access our internet offers without disclosing any personal information to us. It is always your choice whether or not to provide us with your personal information. We collect your information in order to fulfill the user contract we have agreed upon with you. In addition to monitoring compliance with the terms of use and game rules, this includes in particular the proper handling of your payment arrangements.

We require personal information if you would like to register on our websites, participate in sweepstakes, or subscribe to our newsletter. This information includes, for example, your name, address, email address, and other personal information that Goodgame Studios may inquire into in individual cases. In many cases, it is possible to use Goodgame Studios’ services with pseudonyms. Users are encouraged to make use of this feature.

In addition, certain pieces of information such as IP address, browser version, and access times are automatically sent to us by your computer or mobile device and stored on our server. Information regarding the type of mobile device and operating system being used is also collected at this time. We only use this information to conduct statistical and performance analyses or to prosecute unauthorized use of our website. The information remains anonymous whenever possible. We reserve the right to carry out personalized campaigns using the personal information that you have permitted social networks to share with third parties. In this regard, we shall refer to the privacy policies of the social networks in question.

We gather, process, and use personal information only with your consent, unless already permitted by legal statutes. If consent is given electronically within the context of our online offerings, we shall fulfill our legal obligation to give you proper notification of this.

We do not knowingly collect any information from anyone under 13 years of age.

4 Cookies
We use cookies on our website. These are small text files stored on your computer. We use both permanent cookies and session cookies so that we can offer you the best service possible. The data saved in the cookies make the use of our services as comfortable as possible for you, not only for your current use of the respective service but also beyond it.

If you don’t want to allow permanent cookies, you can select the option to deactivate permanent cookies in your browser.

The data stored in session cookies are only valid for the current visit to our online offers and serve to provide you with an unrestricted use of our services and to make the use of our offers and services as comfortable as possible for your current visit. If you deactivate session cookies, we cannot guarantee that you will be able to use all of our services without limitations.

5 Cookies of third party providers and tracking
We use the services of other companies to optimize our websites and our services. You will receive an overview of the services we use in the following section.
a. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, text files stored on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. We use Google Analytics with the add-on “_anonymizeIP()” so that the IP addresses later transmitted to Google are shortened and modified in advance on the European servers to prevent any direct references to particular persons. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage to the website operator. Your IP address, which has been transmitted by Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use all functions of this website. Furthermore, you can prohibit Google from collecting and analyzing the cookie generated data about your use of the website (including your IP address) by clicking here or downloading and installing the browser plugin available here http://tools.google.com/dlpage/gaoptout?hl=en.

If you visit our website using a mobile device (e.g. a smartphone or tablet), you can refuse the future use of Google Analytics via this link. By activating the link, we will put a cookie in your browser, which signals to us that we should prevent Google Analytics from using your device. Please keep in mind that you will have to repeat the refusal process if you remove the cookies from your browser.

b. Google Remarketing
Our websites use Google’s remarketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on the websites of the Google partner network. Likewise users that are similar to the visitors of our websites can be addressed. The advertising will be displayed using cookies. These are small text files saved on the user’s computer. The information generated by the cookie about the website use will be transmitted to and stored on servers in the United States by Google. In the event that the IP address is transferred, it will be reduced by the last 3 digits. Using cookies, the user behavior on a website can be analyzed and subsequently utilized to provide targeted product recommendations and advertising based on the user’s interests.

If you would prefer to not receive any targeted advertising, you can deactivate the use of cookies for these purposes through Google by visiting the website: https://www.google.com/settings/ads/. Alternatively, users can deactivate the use of cookies by third party providers by visiting the Network Advertising Initiative’s deactivation website (http://www.networkadvertising.org/choices/).

Please note that Google has its own data protection policy which is independent of our own. We assume no responsibility or liability for their policies and procedures. Please read Google’s privacy policy before using our websites (https://www.google.com/intl/en/policies/privacy/).

c. Facebook Conversion Tracking Pixel
With your permission, our website utilizes the Conversion Tracking Pixel service of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes.

Only users over 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians.

Please click here if you would like to revoke your permission:
https://www.facebook.com/ads/website_custom_audiences/.

d. Facebook login
We also offer you an easier way to register for our games and services. You can use your existing Facebook account for this purpose. By clicking the Login with Facebook link, you can use this registration method via our online portal. To do this, you need to already have a Facebook account or have access to Facebook.

If you would like to register for one of our services via your Facebook account, the first step of the registration process will immediately redirect you to Facebook. Facebook will then ask you to log in or register. At no time will we have access to your personal login information (username and password).

In a second step, you will connect your Facebook profile with the service that you would like to register for. At this point, you will learn what data from your Facebook profile will be transmitted to us. This information is usually your “public information” on Facebook and information that you have made available to the public or authorized for the application in question. Information of this type generally includes your name, profile picture and cover photo, your networks, your username (Facebook URL), and your user ID number (Facebook ID). We will also use the email address you have saved with Facebook in order to contact you outside of Facebook. You can see an overview of the public information in your profile via the General Account Settings menu of your Facebook profile (https://www.facebook.com/settings?tab=applications).

If you would like to remove our service’s connection to Facebook via Facebook Connect, please log in to Facebook and make the required changes to your profile. We will then no longer have the right to use information from your Facebook profile for you.

e. Twitter Conversion Tracking
We use the Conversion Tracking service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). This tracking records if a user of our website clicks on a link posted by Twitter. In this way, both we and Twitter can see if a registration has taken place. The identity of the user remains anonymous. In addition, we use Twitter’s Tailored Audiences service. This enables us to appeal to our website’s users with targeted advertisements. To do this, Twitter uses a code snippet (tag) which we have integrated into our website. No personal data are collected during this process. Tailored Audiences is also used to create lookalike targeting lists.

You can find more information about Twitter’s privacy policy in their data privacy statement (https://twitter.com/privacy?lang=en). You can adjust your privacy settings for tailored advertisements at this link: https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-ads Twitter also supports “Do Not Track” (DNT). If you have activated this option in your browser, Twitter will not receive any browser-related information (browser cookie ID) from web partners in order to tailor their advertisements to you.

6 Use of your personal information
We use your personal data in order to constantly improve our range of services and to satisfy users’ needs.

We use your personal information for the establishment, processing, and settlement of your user relationship with Goodgame Studios and the processing of payments.

Furthermore, we use your information in order to communicate with you. This communication includes emails informing you on new features in our services where appropriate. We use your personal information in order to inform you about products, services, or certain events which could be of interest to you on a regular basis. Each message contains the text: “In order to stop receiving emails for this game account in the future, please click here”. After clicking on “here”, you will no longer receive messages regarding this game account. Your refusal will not incur any costs other than the transmission costs in accordance with basic tariffs.

Finally, we use your information in order to protect our webpages and to trace unauthorized accesses.

7 Transmission of personal information
As a matter of course, your data will not be sold to third parties. Goodgame Studios transmits your personal data to third parties only to the following extent:

We are collaborating with payment providers (e.g. credit card companies, banks, PayPal, mobile services, debt collection agencies, etc.), providers that create and compile statistical data, and IT service providers (e.g., data centers, hosts, backup services, database services). These service providers only have access to your data to the extent necessary for the completion of their tasks. These service providers are required to handle your data in accordance with this privacy policy and the relevant data protection statutes.

In the case that Goodgame Studios, companies controlled by Goodgame Studios, certain affiliated companies, or shares of the company are sold, your customer information will ordinarily be passed on with the part of the company that is changing hands. As a matter of course, your data shall remain subject to this privacy policy and the relevant data protection statutes in a case such as this.

8 More information about the privacy policy
Please keep in mind that all information you choose to make public, e.g. in chats, via email, or in forums or comments, can be collected and used by others.

For our own liability, we maintain the right to review this content. In addition, we shall strive to clarify and prevent any fradulent measures (e.g. illegal game rigging at the expense of Goodgame) via independent reviews.

9 Changing or deletion of data
As a registered user you can review, update, correct or delete your personal data in your profile settings or by contacting us at: https://support.goodgamestudios.com/.

Goodgame Studios will delete personal data upon request, unless mandatory obligations contradict such a deletion.

10 Security of your personal information
The data collected from you is processed according to the German Data Protection Act. All employees are obliged and have been advised to maintain data confidentiality and privacy obligations.

When submitting payments, the transfer of your information is protected by SSL encryption technology. Our SSL transfer is GoDaddy certified.

11 Contact
Altigi GmbH/Goodgame Studios
Theodorstr. 42-90, Haus 9
22761 Hamburg
Germany
privacy@goodgamestudios.com

The operating data protection officer of Goodgame Studios is the attorney David Oberbeck (www.datenschutzkanzlei.de). If you have any questions regarding the privacy policy, please send them via post to:

Data Protection Officer
c/o Altigi GmbH/Goodgame Studios

Theodorstraße 42-90, Haus 9
22761 Hamburg
Germany

Privacy Policy for mobile applications (apps)

Altigi GmbH/Goodgame Studios, Theodorstr. 42-90, Haus 9, 22761 Hamburg, takes the protection of your personal data very seriously. The following policy statement informs you about which personal data we collect and how we process and use them.

In order to explain how we handle personal data, and to fulfill the relevant legal provisions concerning data protection, we present the following Privacy Policy. This policy applies to our mobile applications (apps) for smartphones and tablet PCs.

Contents:

  1. Scope of this Privacy Policy
  2. Responsible party
  3. Data collection upon downloading
  4. Data collection by us
  5. Access permissions for our Apps
  6. Data analysis by Goodgame Studios
  7. Tune mobile app tracking
  8. Facebook
  9. Use of your data
  10. Disclosure of data
  11. Further notes on data protection
  12. Changing or deletion of data
  13. Data security
  14. Contact
1 Scope of this Privacy Policy
This Privacy Policy applies to all mobile applications (apps) offered under the responsibility of Goodgame Studios.

Unless stated otherwise, solely this Privacy Policy regulates how Goodgame Studios treats your personal data. In the event that you are using services of third parties, the policy of these third parties shall apply exclusively.

2 Responsible party
The “responsible party”, within the meaning of the Federal Data Protection Act (Bundesdatenschutzgesetz) is: Altigi GmbH / Goodgame Studios, Theodorstr. 42-90, Haus 9, 22761 Hamburg.

If you have any questions about privacy, please contact privacy@goodgamestudios.com. You can use this address at any time to ask questions about data protection, to query which data are saved by Goodgame Studios, or to have such edited or deleted. Alternatively, you can contact us by post at the above mailing address. Please submit, where possible, the name of the online or mobile game you play, the server and your player name.

3 Data collection upon download
When you download the app, no information is actively transmitted by us to the respective app store (Apple App Store, Google Play, Amazon, Windows, etc.). If you want to know which data are collected and processed by the respective app store as part of a download, please inform yourself with their privacy policy. We have no influence on possible data collection by the stores.
4 Data collection by us
We only use information about you to the extent that this is necessary for downloading the app to your device. If necessary, we collect information from whichever source (banners, store, etc.) you used to download the app.

In order to use our app, we create a username and a password for you, and present this information on your mobile device. This individualized access is necessary to connect to our game servers. The data will be created automatically by our system and can be customized by you later with an e-mail address and password of your choosing. Alternatively, you can use an existing user account for the app.

In principle, you can access our app offers without disclosing any personal information to us. It is always your choice whether or not to provide us with your personal information.
We collect information from you in order to fulfill the user contract concluded with you. To this end, in addition to monitoring compliance with the conditions of use and game rules, we monitor in particular the proper handling of any payment order you have initiated.

If you register within our apps, participate in sweepstakes or subscribe to our newsletter, we require personal data. This information includes, for example, your name, address, email address, and other personal information that Goodgame Studios may inquire into in individual cases. In many cases, use of Goodgame Studios’ services is possible using a pseudonym. Users are encouraged to make use of this possibility.

For statistical purposes, your mobile device and its associated operating system are recorded by us. Beyond the purposes of pursuing unauthorized use of our services, we analyze this data only for statistical and service development. To the fullest extent possible, the information is anonymized.

5 Access permissions for our apps
Our apps require different access permissions on your device. These are required to guarantee certain functionality of our apps. If you want, for example, to create a profile picture from within the app, we need access to your camera or photo album. If you want to buy additional content through the app, we may need access to the necessary interface to your app store account. Another example is so-called “push notifications”, in which we can use an interface to display a message directly on your end device.

The access permissions on your mobile device are dependent on the operating system (e.g. Android, iOS, etc.) and the store where the app was purchased (e.g. Google Play Store, Apple App Store, Amazon, etc.). You generally receive information on which access permissions are required by our apps prior to installation.

In Apple iOS, see “Settings” at any time for an overview of what content our apps can access. You can restrict these access permissions at a later time.

In Android, various access permissions are also needed on your mobile device. Under “Settings / Apps”, you can review the access permissions of our apps.

6 Data analysis by Goodgame Studios
We also perform analyses on the behavior of users of our services, in order to derive approaches for service optimization. These evaluations are conducted with a pseudonym, in accordance with § 15 para. 3 German Telemedia Act (TMG), i.e. the user name and other identifying characteristics are replaced by a random character for the purpose, making the determination of a specific natural person impossible or significantly more difficult.

Within our apps, we do not use any proprietary marketing or advertising cookies. Instead, we use cookies on your device that can store your user name and the current games settings in a text file. These cookies are necessary for the provision of our apps.

7 Tune Mobile App Tracking
Our app is analyzed with technologies of Tune Inc. (2220 Western Ave., Seattle, WA, USA). To this end, various session and interaction data from you are collected and stored. We need this information to improve the content and usability of our games and to optimize the user experience for you. The session and interaction data are at no time processed in personalized form, rather under a pseudonym. For more information on data processing by TUNE Inc., please refer to the respective privacy policy of that provider: http://www.mobileapptracking.com/privacy-policy/.

You may at any time opt out of tracking by TUNE Inc. with future effect: http://www.optoutmobile.com/optout/index.html.

8 Facebook
Facebook SDK: Within our app, we use the Software Development Kit (SDK) from Facebook. The Facebook SDK is issued and administered by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. By means of this integration, we can link various Facebook services with our app. For example, users can use the Facebook SDK to share contents of our apps on their own Facebook timeline, or to send messages to other Facebook users. Further information about Facebook SDK within iOS can be found here: https://developers.facebook.com/docs/ios. For Android, please refer to: https://developers.facebook.com/docs/android.

Facebook Login via the SDK: In order to use Facebook services within our apps, you will need to first use Facebook Login to connect with Facebook. This requires that you have an existing Facebook account or that you create a Facebook account. If you want to use your Facebook account to log in to our services, you will be guided directly in a first step to Facebook, where Facebook will ask you to sign in or register. In no event will we learn your personal login information (username and password). In a second step, you can link your Facebook profile with each service you want to register to use. You will then receive a separate notice detailing which data is transferred to us from your Facebook profile. This generally includes your “public information” on Facebook and anything you make public or make accessible to the respective application. This generally includes your name, your profile and cover picture, your gender, your networks, your username (Facebook URL) and your user identifier (Facebook ID). In order to communicate with you without going through Facebook, we also use the e-mail address you have registered with Facebook.

You can check and modify the status of your connection to Facebook and the respective access privileges of our apps at any time under your Facebook profile settings (https://www.facebook.com/settings?tab=applications). Here, you will also find an overview of which information in your profile is public. If you want to cancel the connection between Facebook and our apps, please log in to Facebook and make the necessary changes in your profile settings. We will then no longer be able to access information from your Facebook profile in order to serve you.

Facebook App Events: We use the Facebook SDK service called “Facebook App Events” to evaluate the reach of our advertising campaigns and use of Facebook SDK. Facebook merely provides us with an aggregated analysis of user behavior with our app. We also have no influence on the information that will be processed by Facebook App Events.

In our app settings, you can opt out of using App Events for the given purposes.

9 Use of your data
We use your personal information as needed in order to design and continually improve our services.

We also use your personal information for establishing, implementing and managing your user relationship with Goodgame Studios and processing payments.

In addition, we use your information to communicate with you. This includes that we will, where appropriate, inform about news in our services via e-mail. We may use your data to keep you regularly informed about products, services and certain events from our range of services that might be of interest to you. In any such communication, you will find a link labeled ‘To unsubscribe from future e-mails for this game account, please click here’. By clicking on ‘here’, you will receive no further information relating to the respective game account.

Finally, we use your data in order to protect our web pages and to trace unauthorized access.

10 Disclosure of data
Of course, your personal data will not be sold to third parties. Goodgame Studios submits personal data received from you to third parties exclusively to the following extent:

We work together with payment providers (e.g. credit card companies, banks, PayPal, mobile services, debt collection agencies, etc.), service providers that prepare and compile statistical data, IT service providers (e.g. data centers, hosts, backup services, database services) together. These service providers only have access to your personal data to the extent necessary to fulfill their tasks. These service providers are obliged to treat your personal information in accordance with this Privacy Policy and the relevant data protection laws.

In the event that Goodgame Studios, any companies owned by Goodgame Studios, individual subsidiary/affiliated companies or parts of companies are sold, your customer information will generally be passed on with the transmitted part of the company. Your data is of course also subject – in such case – to this Privacy Policy and the relevant data protection laws.

11 Further notes on data protection
Please note that all information voluntarily published by you (e.g. in chat areas, in forums, in comments or by e-mail) can be collected and used by others.

For reasons of own liability, we reserve the right to check these contents. Furthermore, we strive to test for and prevent fraud (e.g. illegal game-fixing at the expense of Goodgame) by means of independent testing and prevention measures.

12 Changing or deletion of data
As a registered user you can review, update, correct or delete your personal data in your profile settings or by contacting us at: https://support.goodgamestudios.com/.

Goodgame Studios will delete personal data upon request, unless mandatory obligations contradict such a deletion.

13 Data security
We process information collected from you according to German data protection law. All employees are obliged to maintain data confidentiality and privacy practices, and are trained in this regard.

For payment transactions, your information is encrypted using the SSL process. Our SSL transfer is GoDaddy certified.

14 Contact
Altigi GmbH/ Goodgame Studios
Theodorstr. 42-90, Haus 9
22761 Hamburg
privacy@goodgamestudios.com

The Operational Data Protection Officer of Goodgame Studios is the attorney David Oberbeck (www.datenschutzkanzlei.de). If you have questions regarding data protection, please address these by post:

Data Protection Officer
c/o Altigi GmbH/Goodgame Studios
Theodorstraße 42-90, Haus 9
22761 Hamburg

Status: August 2016