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
• Name and address of the Data Protection Officer
• What data do we collect?
• How do we collect the data?
• What do we use your data for?
• How do we protect your data?
• Will your data be shared with third parties?
• Transfers to third countries
• What are your rights?
• When will your data be deleted?
• Communication
• In-app chat
• Facebook Connect
• Sign in with Apple
• App optimization / in-app messages
• Online advertisement
• User surveys / User feedback
• Protection of minors
• Changes and updates to the Privacy Policy
• Contact

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

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

General information about data processing

• Contact data (e.g. e-mail address)
• Device ID (user specific identifiers created by Google respectively Apple)
• Mobile advertising ID (user specific identifiers created by Google respectively Apple)
• Where applicable Facebook ID and/or Apple ID
• Metadata such as IP address
• Interactions - Each time you interact with our service, we collect and store the details of your interaction
• Mobile User ID (numbers that are automatically created by us and assigned to your account for internal tracking and advertising purposes)

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

Categories of data subjects:

• Customers / interested persons
• Visitors and users of the online offer
• In the following, we refer to the data subjects as "users"

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

• Providing the online offer, its contents, and functions
• To administer your contract and your player account
• To create user profiles for advertising, improvements of our services, and customer surveys - unless you object to this
• For fraud and misuse detection
• Security measures

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.

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 paragraph 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.

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 or observance of officially recognized special contractual obligations (so-called "standard contractual clauses").

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.

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.

When contacting us, e.g. via e-mail or through the contact form, your details are used to process your enquiry in accordance with GDPR Article 6 paragraph 1 lit. b), or with your consent in accordance with GDPR Article 6 paragraph 1 lit. a). This 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).

Our app feature “Clubs” contains a chat functionality through which you may communicate with other users. Please note, that such feature is not supposed to be used for private communication. Therefore, we advise you not to post anything that you consider to be confidential. Other users being present can see your postings. In case we become aware of an infringement of the chat rules (e.g. insults, advertising posts, etc.) our Customer Support Team will review the respective communications and take appropriate steps if necessary.

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.

For our iOS users we offer an additional alternative option which enables users to register using their Apple ID through Sign in with Apple. When you use Sign in with Apple, an identifier created by Apple, your name (which can be changed) and optionally your email address is transferred from Apple to our app. The data transmitted by Apple may be stored and processed by us for the purpose of providing our services. If you want to disconnect our app from Sign in with Apple, follow the instructions here.

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 Braze. 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 the services of adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany, we process user specific data about installs, uninstalls, downloads and the app’s usage, which enables us to optimize our offer and advertising campaigns (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.

We analyze the usage of our app by using the services of Braze, Inc., 330 W 34th Street, 18th Floor, New York, NY 10001, USA. Braze uses the collected data to create reports about user behavior, which help us to provide a better product. Furthermore we use Braze to send you in-app messages about news or offers on our app. Braze is using the Firebase Cloud Messaging component of Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland for this purpose. The data servers used by Braze are located in the European Union. You can find Braze’s Privacy Policy here. To disable the collection of your data by Braze please send an email to dataprotection@grandginrummy.com.

Advertisements within our app

Within our app we use the services of AppLovin Corporation, 1100 Page Mill Road, Palo Alto, CA 94304, USA, through which AppLovin and/or advertising networks can place their customers’ advertisements in our app. Personal data is solely processed by AppLovin and the advertising networks. The Privacy Policy of AppLovin can be found here.

The advertising networks may store cookies or pixel on your device and will collect and process certain personal data about you and your device (such as your advertising identifier and your IP address).

Currently we’re cooperating with the following advertising networks:

• AppLovin (AppLovin Corporation)
• Adcolony (Adcolony inc.)
• Meta Audience Network (Meta Platforms Ireland Limited)

You can generally restrict the use of your mobile advertising ID for personalized advertising on your device. Apps will then be unable to use your mobile advertising ID to display personalized 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.

You may still see advertising thereafter, but this advertising will not be personalized.

Advertising our app

We advertise our app by placing our advertisements in third-party apps or on third party websites. If you installed our app by clicking on such an advertisement, GameDuell will store your mobile advertising ID and may confirm to the advertising network distributing our advertisement the install and potentially other events relating to the install relating to your mobile advertising ID. The details of the data processing are to be found in the app or on the website of the third party advertising our app.

To generally restrict our use of your device's mobile advertising ID, please change your settings as follows. Apps will then be unable to use your mobile advertising ID.

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

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.

Alchemer

For customer surveys we use the services of Alchemer LLC., 168 Centennial Parkway, Unit #250, Louisville, Colorado, 80027 USA. To improve our game, we process your User ID and other user data (e.g. number of games played + won or virtual goods purchased) via Alchemer to combine your interests with your gaming behavior.

Alchemer's Privacy Policy can be found here.

Condens

For customer interviews we use the services of Condens Insights GmbH, Brienner Str. 41, 80333 Munich, Germany.

Condens's Privacy Policy can be found here.

Doodle

For the appointment management of usability and game tests or interviews, we use the service of Doodle AG, Werdstrasse 21, 8021 Zurich, Switzerland.

Doodle's privacy policy can be found here.

Google Meet

For customer interviews we use the video conferencing services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Meet's Privacy Policy can be found here.

Lookback

For customer surveys we use the services of Lookback Group Inc., 470 Ramona St., Palo Alto, CA 94301, USA.

Lookback's Privacy Policy can be found here.

Zoom

For customer interviews we use the video conferencing services of Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA.

Zoom’s Privacy Policy can be found here.
 

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.

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.

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