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Privacy Policy

The protection of the personal data of users and customers has the highest importance for KRASSGAMES. The data protection policy of KRASSGAMES is in accordance with the applicable legal provisions of the Federal Data Protection Act (BDSG), the Telemedia Act and the provisions of the EU Data Protection Ordinance (DSGVO). This privacy policy explains how we (KRASSGAMES) use and process the data on this website and in our mobile apps.

Name and contact details of the person responsible and, if applicable, his or her representative:

krassGames GmbH & Co. KG
Mittelweg 24d,
20148 Hamburg

Commercial Register: HRB 112480 (Hamburg)
Tax number: 42/639/01946
Managing Director: Jens Fährmann

Contact details of the data protection officer: support@krassgames.com

Purposes for which the personal data are to be processed:

We collect, store and process personal data when you voluntarily provide it to us in connection with your order or when you contact us. This applies to:

– the provision of the respective app,
– and own marketing purposes,
– for our statistics

Legal basis for processing

Your data will be processed on the following legal basis:

– your consent, Art. 6 Par. 1 lit. a) GDPR
– for the execution of a contract with you, Art. 6 para. 1 lit. b) GDPR
– legitimate interest, Art. 6 para. 1 lit. f) GDPR (see below)

Legitimate Interest

We have the following legitimate interests in the processing of your data:
– improvement of our offer
– protection against abuse
– statistics

Recipients or categories of recipients of personal data

When processing your data, we work with the following service providers who have access to your data:

– providers of web analysis tools

Duration for which the personal data is stored:

We store your data,

– if you have consented to the processing at most until you revoke your consent,
– if we need the data for the execution of a contract for at most as long as the contractual relationship with you exists or legal retention periods are running,
– if we use the data on the basis of a legitimate interest only as long as your interest in deletion or anonymisation does not predominate.

Data sources

We receive the data from you (including the devices you use).

Data transfer to third countries

There is a data transfer to third countries outside the European Union. This is done on the basis of statutory contractual regulations which are intended to ensure an adequate protection of your data and which you can view on request.

Right of access, rectification, cancellation or restriction of processing or right of opposition to processing and data transferability:

You have – partly under certain conditions – the right
– to request information on the processing of your data
– to correct your data,
– delete or block your data,
– to restrict processing,
– to veto the processing of your data,
– to receive your data in a transferable format and to transmit it to a third party,
– to revoke your consent to the processing of your data in the future and
– to complain to the competent supervisory authority about inadmissible data processing.

The responsible supervisory authority is the Hamburg Commissioner for Data Protection and Freedom of Information (HmbBfDI). Should you revoke your acceptance of our Privacy Policy you are no longer allowed to use our app.

Requirement or obligation to provide data

Unless expressly stated otherwise the provision of data is never required or obligatory.

Further information on data protection

Automatic storage of access data

Every time a user accesses the KRASSGAMES website, the access data of the process is automatically stored in a log file. This is general information, such as the page from which the file was requested, the name of the file retrieved, the date and time of the call, the amount of data transferred, the protocol used and the description sent by the Internet browser and, if applicable, that of the operating system.

This general information is anonymized, i.e. it is not stored together with any of your personal data held by KRASSGAMES and is not otherwise merged with it. They are only evaluated for statistical purposes and used to improve the content and functionality of the website. These data are not passed on to third parties for other non-commercial or commercial purposes. The access data is stored in the log file for a maximum of 4 weeks.

Contact form

The contact form on our website is an easy way to contact us quickly. To enable us to contact you, some fields are marked as mandatory. If you fill in the fields and choose “Send”, you agree that your data will be sent to us with the message by e-mail. The data is not stored on the web server.

E-Mail-Newsletter

If you register for our newsletter, we use the data required for this or separately communicated by you, in order to send you regularly our e-mail newsletter. You can unsubscribe from the newsletter at any time and either by sending a message to the contact option described above or via the unsubscribe link provided in the newsletter.

Cookies

This website also uses so-called cookies. A cookie is a text file with an identification number that is transmitted to the user’s computer and stored there together with the other data actually requested when using the website. The file is kept there for later access and serves to authenticate the user.
Since cookies are only simple files and not executable programs, they pose no danger to your computer. Cookies do not contain any personal data, so that the protection of privacy is guaranteed. Depending on the selected setting of the Internet browser by the user, the user automatically accepts cookies. However, this setting can be changed and the storage of cookies deactivated or set in such a way that the user is notified as soon as a cookie is set. However, if the use of cookies is deactivated, some functions of the website may not be available or only to a limited extent.
The KRASSGAMES website uses temporary (so-called “session”) cookies, i.e. cookies that are only valid for the period of a so-called “session” and are automatically deleted when the browser ends. KRASSGAMES may link to other websites where cookies may also be used.
For more information on what cookies are and how you can delete them, please visit: http://www.allaboutcookies.org/.

 

Use of the “Google Analytics” analysis tool

We use the Google Analytics service of Google Inc. this service enables an analysis of the use of our Internet pages and uses cookies for this purpose. For this purpose, the information generated by the cookie, such as your anonymized IP address, is transmitted on our behalf to a server of Google Inc. in the USA, stored there and evaluated. The IP address is only incompletely transmitted because the code “gat._anonymizeIp();” has been added to this website’s code. The adding of the code ensures that IP addresses are collected anonymously. Your IP address is usually made anonymous by Google Inc. reducing your IP address within the European Union or in other contracting states of the European Economic Area (EEA). In exceptional cases, your IP address will be transmitted to a Google Inc. server in the USA and anonymized there. Your IP address transmitted here will not be merged with other data from Google Inc. You can object to the collection of your data by Google Analytics at any time. You have the following options:
Most browsers automatically accept cookies. However, you can prevent the use of cookies by setting your browser; in this case, however, not all functions of the website may be available. You must make the settings separately for each browser that you use.

You can also prevent Google Inc. from collecting and processing this data by downloading and installing the browser ad on available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Alternatively or within browsers on mobile devices, please click on the following link: Disable Google Analytics. An opt-out cookie is stored on your device for our Internet pages with effect for your current browser. If you delete your cookies in this browser, you must click on that link again.
For more information on Terms of Use and Privacy please visit http://www.google.com/analytics/terms/us.html or https://policies.google.com/?hl=en

MOBILE APPS

The following data can be processed by the provider when using the apps distributed by KRASSGAMES:

Depending on the device, a device ID is assigned to identify the user. As a rule, this ID cannot be linked to personal or personal data. If you enter your email address, it can be associated with your ID. When using chargeable services, it may be necessary to pass on the device ID to the respective payment service provider (e.g. Apple Inc.) in order to be able to process payment transactions. KRASSGAMES uses the protocol data only for statistical evaluations for the purpose of operation, security and optimisation of the offer. However, KRASSGAMES reserves the right to check the log data subsequently if there is a justified suspicion of illegal use based on concrete indications.

- Some apps contain and may also use third-party SDKs to use external services (e.g. Facebook, Flurry etc.). The use of these services is always optional as far as technically possible and is on a voluntary basis. KRASSGAMES has only limited influence on whether and which data may be read and processed by these third parties.
- Some apps offer so-called “connected” or “social” features that can be used to play (or generally interact) with others or against other users. As a component of these features, the apps usually offer the possibility of creating a user profile. By creating such a user profile, the user accepts that (public parts) of his profile can be viewed by other users and/or generally on the Internet (e.g. screen name and avatar on public highscore lists). This is especially true if the user decides to link the user profile to a Facebook account. Such “connected”/”social” features can always be used anonymously or with a standard display name that cannot easily be resolved.

All apps use device identifiers to personalize content and ads, provide social media features, and analyze access to our app. We also share these identifiers and other information about your device with our social media partners, advertisers and analysts.

- The “Ad ID” (also known as IDFA “Identifier For Advertisers” (Apple) or GAID (Google Advertiser ID) (Google)) is a temporary identification number that we use to improve the gaming experience in online games. We also pass this ID on to integrated partners so that they can display advertising that is better tailored to your interests, for example. We finance the development and operation of our games by displaying the most appealing advertising possible. An assignment to your person or an individualization of your device beyond the device ID assigned by us is neither in our interest nor is this technically possible for us.
You can object to the use of the advertising ID generated by the device on your device (“Opt Out”). This will probably not cause you to see less advertising, but it will be less based on your usage behavior and probably less interesting/relevant to you.
To deactivate the device side forwarding of the advertising ID, go to iOS devices (Apple) under Settings/Privacy, select “Advertising” below and activate “No ad tracking”. For Android devices, please visit Settings/Account/Google/Display and activate “Deactivate Interest Related Ads”.

In accordance with the DSGVO, we only automatically collect data that is indispensable for the exercise of our immediate business purpose.

The companies behind all third-party SDKs included in our apps were tested for compliance with the DSGVO. Under “Personally Identifiable Data” you can see which SDKs from which companies are contained in which of our apps and, if necessary, read out personal data such as the “advertising ID” or other device data.

- To use the app, the same log data (see above) is still processed as when using the website.

By downloading and installing any of our apps you agree that you have read, understand, and unconditionally accept our general Terms & Conditions and our Privacy Policy. You especially agree that we collect and/or transfer data (including device ids, advertising-ids and IP addresses) to optimize our in-app advertising and to enhance its performance and targeting.

If you do not agree to our Terms & Conditions and our Privacy Policy, you should not use any of our apps or services in any way. You are generally prohibited from using our apps if you live in the European Union AND are under 16 years of age.

Personal information

Profile data of the app „Mobile FC“

Our app „Mobile FC“ automatically generates an "anonymous" user profile. The system needs some of the data in this profile to be able to recognize the individual user. We will use the information in the following ways and in accordance with the following legal bases:

Personal Information

Use

Legal Basis for Processing (EU)


Generated AccountID

We generate this and use this to store your Game data (including level and progress) with your profile.

Necessary to perform our contract with you to provide the Game. 

Managername

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game. 

Clubname

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game. 

Region Location and Language (manually selected by you)

We use this information to: • set up your gameplay on a regional server; • provide you with your geographic ranking; and • improve gameplay.

Necessary to perform our contract with you to provide the Game. 

Email Address

We only receive this information if you voluntarily provide it.

We collect this information with your consent.

Game progress (manager, club, team, successes)

We use this information to provide you with feedback and information about your gameplay and progress.

Necessary to perform our contract with you to provide the Game. 

IP Address

We use this information: • to improve our services, including the functionality of the Game; • for security and verification purposes; • identify and address bugs and assess game function for optimisation; and • to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Device ID, Device Information (application version, OS version, platform, country code)

We use this information: • to improve our services, including the functionality of the Game; • for security and verification purposes; • identify and address bugs and assess game function for optimisation; and • to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Advertising ID

If you click on a link that advertises the Game, we store the Advertising ID for that advertisement with your profile.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

Messaging Data

If you use message services then we will process such data in order to deliver your messages to other users.

Necessary to perform our contract with you to provide a message service in-Game.

Transaction Records: payments on Google Play or iOS App Store (Open ID, cost, product purchased, IP Address, device details)

We use this information to maintain a record of your transaction history.

Necessary to perform our contract with you to provide you with details of your transactions.

Customer Support Ticket ID & User Communications with Support (Managername, Clubname, AccountID, DeviceID)

We use this information to:

  • improve our services; 
  • provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Game. 

 

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information

Retention Policy


AccountID

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Managername

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 60 days.

Clubname

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 60 days.

Region Location (manually selected by you)

Game Play Statistics (Level, Heroes, Score/s)

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Email Address

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 60 days.

Messaging Communications

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 7 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

IP Address

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Device ID, Device Information

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Advertising ID

Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. 

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Transaction Records

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.

Customer Support Tickets and User Communications with Support

Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).

Of course we treat this personal data with all due respect and 100% DSGVO-compliant. We do not link this data to external data sources or pass it on to external partners. All profile data is stored on servers within the European Union.

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

We update this Data Protection Statement regularly and reserve the right to make changes to it. Therefore please regularly check whether a new version is available. The date of the last change of this document is shown at the bottom of this page.


Last updated: May 2018