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GameDuell Data Privacy Policy

GameDuell takes data protection seriously and respects your privacy. In this data protection declaration we inform you about what data we collect within the scope of our online offer and how we process this data. With regard to the terminology used, e.g. "personal data" or their "processing", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Overview

Name and address of the Controller

The Controller within the meaning of the GDPR and other national data protection laws of the member states as well as other data protection regulations is:

GameDuell GmbH, Taubenstr. 24-25, 10117 Berlin, Germany

phone: +49 (0) 30 288 768 661, mail: dataprotection@grandginrummy.com

 

Name and address of the Data Protection Officer

The Data Protection Officer of the Controller is:
Berit Schubert, DataSolution Thurmann GbR, Isarstr. 13, D-14974 Ludwigsfelde, Germany, phone: +49 (0) 3378 205729, mail:
mail@datasolution-thurmann.de

 

General information about data processing

What information do we collect?

No special categories of data are processed (GDPR Article 9 (1)).

Categories of data subjects:

How do we collect the data?

The data is collected either automatically when you use our services, or through your own entries in our app, or by use of pixels.

What do we use your data for?

How do we protect your data?

We take appropriate technical measures in accordance with GDPR Article 32, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk; Measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability, and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion, and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software, and procedures, according to the principle of data protection through privacy by design and privacy by default settings (GDPR Article 25). Your data is protected against abusive access and loss through versatile measures electronically, technically, contractually, and administratively. We use security techniques (such as SSL encryption, cryptographic techniques) to protect your data against unauthorized access.

Will your data be shared with third parties?

If, in the course of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit data to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission, e.g. if a transmission of the data to third parties, such as to payment service providers, acc. to GDPR Article 6 para. 1 lit. b is required to fulfill the contract. You have consented to a legal obligation or on the basis of our legitimate interests.

In order to be able to offer you our service optimally, we use, among others, service providers who work on our behalf. If this is the case, corresponding order agreements have been concluded with the service providers acc. to GDPR Article 28.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), this will only be done if it is necessary to fulfill our (pre) contractual obligations, on the basis of your consent, due to a legal obligation, or based on our legitimate interests. We only process the data in a third country if the special conditions according to GDPR Article 44 ff. are fulfilled. That means the processing will be done e.g. on the basis of special guarantees, such as the officially recognized statement of an EU level of data protection (e.g. the Privacy Shield for the USA) or observance of officially recognized special contractual obligations (so-called "standard contractual clauses").

What are your rights?

We would like to inform you that you have a right to free information about your stored data as well as a right to correction, deletion, or blocking of data and objection and data transferability at any time. Please also contact us for further information or for the assertion of revocation rights: dataprotection@grandginrummy.com. You also have the right of appeal to a supervisory authority.

When will your data be deleted?

We store your data only as long as it is necessary to fulfill the aforementioned purposes or until you object to the data processing. Thereafter, the data is deleted or blocked if the deletion is not contrary to legal regulations or legislated interests. There is a well-founded interest, for example, in asserting, exercising, or defending legal claims or in avoiding fraud cases, i.e. for your protection.

The data is used in anonymous form for evaluations and statistics.

Contacting

When contacting us (for example by e-mail), we use the information provided by the user to process the request and its processing acc. to GDPR Article 6 para. 1 lit. b).

The information of the users can be stored in our systems.

We delete the data if it is no longer required. We review the necessity of the data every two years. In the case of legal archiving obligations, deletion takes place after expiration of the respective legally prescribed periods (in the case of commercial law after 6 years, and in the case of tax law after 10 years).

Facebook Connect

We offer an additional alternative registration option via Facebook Connect. When you use Facebook Connect, data (such as your user ID and public profile data) is transferred from your Facebook profile to our app. Conversely, data from our app can be transferred to your Facebook profile. The data transmitted by Facebook may be stored and processed by us for the purpose of providing our services. If you want to disconnect our app from Facebook Connect, follow the instructions here.

App optimization

In order to provide our services to your full satisfaction, we use tracking services to create anonymous or pseudonymous user profiles. We’re using the services of Amplitude, Adjust, and Leanplum. The legal basis for the processing is GDPR Article 6 Abs. 1 lit. f.

Amplitude

We use the analysis service of Amplitude, Inc., 631 Howard St., Floor 5, San Francisco, CA 94105, USA to better understand and optimize the behavior of our users when using our app.

You can find Amplitude’s Privacy Policy here. To disable the collection of your data by Amplitude please send an email to dataprotection@grandginrummy.com.

Adjust

Through services of adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany, we process user specific data about downloads and the app’s usage, which enables us to optimize our offer (e.g. in game purchases, downloads). You can find Adjust’s Privacy Policy here. To disable the collection of your data by adjust please send an email to dataprotection@grandginrummy.com.

Leanplum

We analyze the usage of our app by using the services of Leanplum, Inc, 1550 Bryant Street, Suite 545, San Francisco, CA 94103, USA. Leanplum uses the collected data to create reports about user behavior, which help us to provide a better product. You can find Leanplum’s Privacy Policy here. To disable the collection of your data by Leanplum please send an email to dataprotection@grandginrummy.com.

 

Online advertisement

Advertisements within our app

Within our app we use the services of Fyber GmbH, Johannisstraße 20, 10117 Berlin, Germany, through which advertising networks can place their customers’ advertisements in our app. Personal data is solely processed by Fyber and the advertising networks. The Privacy Policy of Fyber can be found here.

If you don’t want your personal data to be processed by Fyber or the advertising networks, please don’t click on any of the advertisements displayed to you.

Furthermore, you can restrict the use of your mobile advertising ID for targeted advertising on your device. Apps will then be unable to use your mobile advertising ID to display targeted advertisements.

iOS: Settings > Privacy > Advertising > Limit Ad Tracking.

Android: Google-Settings > Ads > Opt out of Ads Personalization.

You can also reset the mobile advertising ID on your mobile device.

iOS: Settings > Privacy > Advertising > Reset Advertising Identifier.

Android: Google-Settings > Ads > Reset Advertising ID.

 

User surveys / User feedback

Occasionally we may ask you for voluntary feedback about our app. This only happens with your consent, which is obtained separately in the context of the surveys. On the basis of the survey and test results, you may receive further invitations that correspond to your interests. We will inform you in advance about the details, in particular any collection of personal data. In this regard you can make use of your rights mentioned above. The legal basis for the processing is GDPR Article 6 Abs. 1 lit. a. You have the possibility to object to the processing of your data for these purposes at any time. If you participate, we use the following service providers.

 

Survey Monkey

For customer surveys we use the services of Survey Monkey, Europe UC 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland.

Survey Monkey's Privacy Policy can be found here.
 

User Testing

For usability and game tests we use the services of User Testing, Inc., 690 5th Street, San Francisco, CA 94107, USA.

User Testing’s Privacy Policy can be found here.
 

Doodle

For the registration process for usability and game tests we use the services of Doodle AG, Werdstrasse 21, Postfach 8021 Zürich, Schweiz.

Doodle’s Privacy Policy can be found here.

 

Protection of minors

This service is intended for adult users. We have no content aimed at children nor young people. As a result, we do not knowingly collect personal information from children under the age of 16. However, we advise all users under the age of 16 not to disclose or make available any personal data to our service.

Changes and updates to the Privacy Policy

We reserve the right to change, update, or amend this data protection declaration at any time. Any revised privacy policy applies only to personal information collected or amended after the effective date of the revised privacy policy.

Contact

If you have any further questions, please do not hesitate to contact us. Please send an e-mail to dataprotection@grandginrummy.com or contact our data protection officer directly.