Valid as of: 1. August 2017
Personal data is all information relating to a specific or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using additional information available to us.
Provider of the KALYPSO Services and the responsible body within the meaning of data protection law is Kalypso Media Group GmbH, Wilhelm-Leuschner-Strasse 11-13, 67547 Worms, Germany, Tel.: +49 6241 5061900, @: firstname.lastname@example.org (hereinafter: "we" /"us").
You can access this information at any time on our websites.
A Information on data processing
- Basic user data
- Usage data
- Anti-cheat and fraud prevention technology
- Disclosure of data to third parties
- Where is the data stored?
- How do we protect your personal data?
- Social plugins
- Public information, including user-generated content, online forums, blogs and profiles
- Use of KALYPSO Services by minors
- User rights
B Text of the declarations of consent
A Information on data processing by KALYPSO
1. Basic user data
a) What basic user data is collected and stored?
The use of some of the KALYPSO Services requires you to register a user account (hereinafter: "KALYPSO Account"). During the registration process, you will be asked to give us several pieces of information, in particular:
- Email address
- Username (pseudonym)
- Confirmation that you are older than 16
When registering a KALYPSO Account you should choose a username which does not allow conclusions to be drawn about your person as other users can use your username to see the information contained in your player profile as well as your game statistics.
Should you also wish to take advantage of the option to purchase virtual goods and services in our webstore, further information will generally have to be provided in the course of the payment process to the chosen payment service provider, in particular
- First name and surname
- Home address
- Date of birth
At no given time will we store sensible personal data like credit card information or any other sensible payment information on the website or in your user account. The payment is always made immediately and directly through the respective payment provider (“PayPal”, “Amazon Payment” or “Micropayment”).
Further voluntary information
In the course of using the KALYPSO Services, the user may voluntarily add further information at a later time to their KALYPSO Account, for example when setting up a profile for internal user forums or player profile. This information could include the name, birthday, contact details, gender, pictures, personal preferences, personal relationships and other details relating to the person of the user. These can be edited by the user at any time. The data stored in relation to the forum or gamer profile is, where applicable, also visible to other registered users of the KALYPSO Services. They form the own outward presentation of the user within the forum or the profile pages and can, in addition, be used by us for statistical purposes in order to improve user-friendliness and to personalise our services as well as to display advertising based on your interests.
We provide users with the possibility of sending us support requests. In connection with such support requests, we may ask for certain information, including, but not limited to, information which helps us to allocate the requests, processing the requests and/or resolve underlying technical problems. That information may then be stored for the above purposes and allocated to the corresponding KALYPSO Account (if stated) until such time as permission to use that information is revoked:
- First name, Surname
- User ID/Username
- More detailed information on the relevant KALYPSO Service and on the problem which has arisen
- Email address
- Security question and answer (for identity verification)
- Payment details for any refunds which may be due
b) For what purposes do we collect, process and use basic user data?
We use the data you provide during registration in order to open an individual KALYPSO Account for you to enable you to use the KALYPSO Services, to satisfy your requests, to fulfil your orders and to send you confirmation of purchases and other account and use related information. In addition to that, we use the data for statistical purposes in order to improve user friendliness and to promote the service. Where necessary, we also use the information related to your KALYPSO Account to tailor the advertisements displayed within our services to your specific interests by assigning you to certain interest groups on the basis of this information. We use the information related to your KALYPSO Account for the following purposes in particular:
- to offer customer service and to process user requests;
- to keep you informed about games and/or particular game-specific events (e.g. competitions);
- to subscribe you to newsletters, including newsletter advertising, insofar as you have given us your prior express consent;
- to analyse the performance of our services, in order to ensure the proper operation of our services and to identify and remedy software errors and security risks as well as to improve our services according to our users' requirements;
- to offer adverts and advertising communications which are tailored to your interests;
- to offer software updates and dynamic content;
- to contact you in connection with the provision of our services;
- to prevent fraud;
- to enable you to create a personal profile;
- to enable your (personalised) use of our website and services including enquiries and requests regarding product and customer service, advertising and log-in;
c) How long is basic user data stored?
The data will generally be stored to the KALYPSO Account until the account is deleted. Where the use is subject to declarations of consent, it will continue until receipt of a notification of revocation. Please note that we may be obligated, on the basis of statutory obligations, in particular provisions relating to tax law and commercial regulations, to archive the relevant personal data even beyond the effective date of your revocation. The data will be deleted after the relevant statutory time period.
2. Usage data
In addition to the information you actively provide us with, we automatically collect a range of data as users use our websites and other KALYPSO Services, in particular on the manner and extent of the use of our services, which requires no action on the part of the user.
a) What data is automatically collected?
Automatically collected data includes data, which is not directly related to your person, such as the IP address allocated to you at the time of access (in anonymised form), the duration of the access, the pages displayed and other data automatically conveyed by your PC, e.g. in the form of log files with information, in particular, on the hardware you are using, your operating system, browser information, language settings, your screen resolution and your internet service provider.
In the course of the use of our KALYPSO Services we also collect a range of service related data, e.g. on the functions of a service used by you, game statistics, number of points and achievements attained, user rankings and the time which you spend on our games as well as the pages and links which you visit in the course of using our services. This information will be stored and allocated to your KALYPSO Account and used for the statistical evaluation of your use (see below).
b) For what purposes do we collect, process and use usage data?
We use your data to facilitate your use of our services, to correct technical problems, to ensure the continuous functioning of our products and services and to improve and further develop these according to the needs of our users. We use the automatically collected usage data, which is stored without being linked to your KALYPSO Account, for the following purposes:
- to assess the success of marketing measures, in particular conversion rates for advertisements and newsletters;
- to enable you to link our services to your public profiles on social networks or other third party services;
- to fulfil your orders and to send you an order confirmation;
- to authenticate your software and verify your rights of use;
- to ascertain your approximate location in order to offer country and language specific services and functions as well as statistical evaluations on the use of our services.
- to tailor the advertisements displayed within our services to your specific interests by assigning you to certain interest groups on the basis of this information.
In addition, your game statistics aid the evaluation of your skill level and the creation of a ranking in relation to other users. Insofar as you participate in tournaments or other online game events, the statistical data generated by your participation (such as, for example, your results, placings and successes) will be visible, under your username, to other users of our services. We use this information for the creation and publication of rankings and comparison lists to highlight the competitive nature, which is an essential factor of our Services.
c) In what way is data automatically collected?
For the automated collection of usage data, we use technologies such as cookies, in order to collect passive usage data from our website without your active input. These include, in particular:
In addition to the cookies we set during the use of our service, additional cookies may be set, where applicable, by third party providers when you visit our website. This occurs because we have commissioned third parties to collect information for us, for example for statistical usage analysis (e.g. as part of the use of Google Analytics); it also occurs because our sites contain content or advertisements of third parties. Where required, your browser connects for the purpose of accessing such third party content, directly with the servers of the third party providers, thus enabling those providers to place their own cookies on your end device.
Most browsers are automatically set to accept cookies when visiting a website. You can deactivate cookies or set your browser to display a warning as soon as cookies are sent. However, when cookies are deactivated some sections of our websites will not function properly. You can set your web browser to warn you when there is an attempt to place cookies on your computer or to limit the range of cookies permitted by you.
Under certain circumstances, we also use flash cookies on our sites, also known as "local shared objects", which use Adobe technology. Flash cookies are small files which are similar to the browser cookies described above and are used to store website settings to enable the personalised appearance of the site. Like normal cookies, flash cookies appear on your PC as small files. You can adapt your settings under the point "Global Storage Settings" on the Adobe website. For further information on the Flash Player security and data protection, visit the Adobe website at www.adobe.com and the Macromedia website at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
Please note that if you deactivate cookies you might not be able to use some of the features and functions for the use of our services which require cookies. The cookies set by us have a maximum life span of 6 months.
(b) Internet log files
Where necessary we also store internet log files which your PC automatically transmits to our webserver. These log files typically contain information about your computer or your end device, in particular browser type/version, operating system used, URL of the linking websites and date and time of the access.
(c) Analytical metric tool and other technologies
KALYPSO uses an own analytical metric tool and third party analytics technologies (see more detailed information below), to collect data when you play our games. These tools and technologies collect information about your computer, browser, your operating system, your use of features and pages, any application software used and information about the manner and extent of use of our games, including game metrics and statistics and your purchasing behaviour.
We sometimes use Google Analytics on our websites, a web analytics tool from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies" which are stored on your PC and which enable an analysis of your use of the website. The information obtained by the cookies about your use of this website will generally be transmitted to a server in the USA and stored there. We use Google Analytics on our websites, however, with an IP anonymisation tool, with which your IP address, when collected by Google Analytics, will, in member states of the European Union or in other states which are party to the Agreement on the European Economic Area, be masked beforehand and thus will be exclusively transmitted by Google in anonymised form. Google uses the collected information to statistically evaluate your use of our website for us, to create reports on website activities and to provide further services related to the website and the internet usage for us. The IP address transmitted by your browser in the scope of Google Analytics will not be combined with other data from Google.
You can deactivate the Google Analytics function with a browser add-on, which you can download at https://tools.google.com/dlpage/gaoptout. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.
(d) Clear GIFs and tracking pixels
Clear GIFs (also known as web bugs, beacons, tracking pixels or tags) are small graphic images which are placed on a website, a web based document or in an email message. Clear GIFs are invisible to users as they are normally very small (only 1 x 1 pixel) and have the same colour as the background of the website, document or email message. We use Clear GIFs to collect statistical usage data about our websites, functions or other elements of a website. Clear GIFs also enable us to determine, for example, whether users come to our website via an advertisement placed by us and whether they register there or use a specific service. We also might use Clear GIFs in our advertising emails or in newsletters to determine whether you open these and whether you open the links therein. We use the data collected in this way for statistical purposes in order to analyse and improve our advertising campaigns and other customer communications. Where necessary, we also use this information to tailor the advertisements displayed within our Services to your specific interests by assigning you to certain interest groups on the basis of this information.
d) How long is basic user data stored?
Unless we have additional consent or we are statutorily or contractually obligated to retain data, we will only store your data as long as your account is active or as long as is necessary to provide you with our services and to achieve the corresponding purpose.
3. Anti-cheat and fraud prevention technology
When you play online we monitor the gameplay through so called "anti-cheating software" to establish whether the user is using cheating software or is interfering with the gameplay intended by the game in any other unauthorised way ("cheating"). This anti-cheating software is installed together with the game on your end device.
Whenever you connect to our game online, the anti-cheating software checks the course of your game, the game files, and the working memory (RAM) of your hardware (when operating) to identify unauthorised third party programs running simultaneously with your game and modifications to game files which facilitate or support cheating. "Non-authorised third party programs" in this context means, for example, "add-ons", "mods", "hacks", "trainers", or other "cheats" which enable you to interfere with or modify the gameplay intended by the game.
In the event that the anti-cheating software discovers the use of an unauthorised third party program, or any other prohibited interference in the gameplay of the game, the game will automatically end and we will receive the information that a respective violation has occurred on your KALYPSO Account. This notification will include information on the date, time and classification of the violation. The anti-cheating software will be deactivated when you end the connection to the game server.
4. Disclosure of data to third parties
Generally, we do not pass on any personal user data to third parties without your express prior consent. In certain circumstances, you have the option of sharing information with others yourself as part of the KALYPSO Services, e.g. if you give out personal information in a publically accessible player or forum profile.
In order to provide some of the KALYPSO Services we work with service providers (e.g. payment service providers, hosting providers) who may, in the course of providing the respective service, process personal data on our instruction and on the basis of a commissioned data processing agreement.
Otherwise, your data will only be passed on in special exceptional cases, where we are obligated or entitled to do so by statute or upon binding order from a public authority.
5. Where is the data stored?
We store and process data collected in relation to the use of KALYPSO Services, exclusively on servers located inside the European Union.
6. How do we protect your personal data?
We undertake appropriate efforts to protect your personal data and to ensure the security of our systems using the relevant latest technology. To this end, we use, among other things, state of the art encryption methods. At the same time, it should be noted that no type of transmission via the internet or method of electronic data storage is 100% secure. We can therefore offer no guarantee against unauthorised access to our servers and systems.
7. Social plugins
We use a variety of plugins for social media platforms on our website for the below companies:
- Twitter: Twitter Inc., 1355 Market Street, Suite 900,
San Francisco, CA 94103, USA
data protection information: https://twitter.com/privacy?lang=de
- Facebook: Facebook, Inc., 1601 Willow Road, Menlo Park,
California 94025, USA
data protection information: https://de-de.facebook.com/policy.php
- Steam: Valve Corp., Inc., NE 4th Street, Bellevue, Washington 98004, USA
- data protection information:http://store.steampowered.com/privacy_agreement/
- Twitch: Twitch Interactive, Inc. 225 Bush Street, 9th Floor, San Francisco, California
- data protection information:https://www.twitch.tv/p/privacy-policy
Embedded on our website are various Facebook links. This web presence is operated exclusively by Facebook Inc., 1601 S California Ave, Palo Alto, CA 94304, USA (Facebook).
Within the scope of our web presence, these links are identified by the Facebook logo or by the phrase ‘Like’. You may find an overview on different Facebook plugins and their appearance on https://developers.facebook.com/docs/plugins
Should a user click one of these links, then the Facebook plugins are activated and establish a direct connection via the user’s browser to a Facebook server.
Provided that the user clicks one of the aforementioned links while visiting our website, and is logged into their personal Facebook account, the information will be forwarded to Facebook that the user has visited our website. Facebook can associate your visit to the website to your account.
This data is transferred to and saved by Facebook. To prevent this, the user must log out of their account before clicking the link. The functions embedded in the links by Facebook, especially the transfer of data and user information, are not activated by visiting our website, but rather by clicking the corresponding links.
The purpose and scope of data collection via Facebook, the processing and use of such data, as well as your rights thereof and personal settings regarding privacy protection can be found in the Facebook privacy settings section (https://www.facebook.com/privacy/explanation).
For further questions pertaining to the collection, processing or use of individual user data and, regarding the disclosure, correction, blocking or deleting of data, please contact our data protection supervisors or go to https://www.facebook.com/policy.php
8. Content posted by the user in public forums, blogs, chats and profiles
When using the KALYPSO Services, from time to time you will be given the option to publish information relating to your person in our online chats, blogs, walls or in user profiles visible to the public or in similar forums on our websites and/or as part of our services. Any Information you disclose in one of these forums is non-encrypted, public information which can be seen by other users of the relevant service and, if published on a website, also by any third parties. In this respect, you cannot expect the protection or confidential treatment of this information. You should note that all information, shared by you in the scope of these public activities, which enables the identification of your person, can be read, recorded, used and processed by other users in order to send you messages. We accept no responsibility for the information made public by you in these forums which can be used by other users to identify your person. Please also note that in the scope of normal internet activities, in certain circumstances, specific technical information is sent to third parties from your browser, such as advertising networks or analytics companies.
We have no control over the information sent to such networks or third parties by your browser and recommend that you ensure that your browser settings prevent the disclosure of information which you do not wish to share. If you wish to make a video, image or photo publicly available in one of our websites you should note that these could potentially be processed, collected, copied and/or used by other users without your consent.
We assume no responsibility for the videos, images or photos made public by you of your own volition within any KALYPSO Services.
9. Use of KALYPSO Services by minors
Many KALYPSO Services are intended for a wide range of ages in their user base. We do not intentionally collect personal data of minors. To the extent we request information on age for the use of our services and a user identifies themselves as under the age of 16, we will either collect no data from this user or ensure that we have the consent of their parents for the collection, use, processing and disclosure of the personal data of the child.
Please note as a parent or legal guardian that in consenting for your child to use KALYPSO Services this can also include access to internal communication services and forums, in which posts by your child may be available to a wide public and through which your child may potentially communicate with users of all ages and give out personal details to these users.
Parents can change or revoke the consent granted and, with an email to the address above, view, edit or apply for the removal/deletion of the personal data of their child.
In the event of a change to this Privacy and Cookies Policy with the effect that the collection, use, processing or disclosure of the personal data of the child, for which consent was granted, is expanded we shall notify the relevant parent.
We would encourage you to talk with your child about communication with strangers and giving out personal information online. We will in no way make the participation of a child in an activity - such as a tournament - dependent on giving us more personal data than would reasonably be seen as necessary for participation.
10. User rights
At your request we will provide you at any time with information on the data on your person stored by us. You can, at any time, correct, update, block or delete the data given to us or request that we correct, update, block or delete your data. Please note that accounts or data, once deleted, cannot be restored. When you delete your KALYPSO Account we delete all the stored data on your person which we do not have to retain for statutory or contractual reasons. Retained data will only be stored for the relevant purpose and will be deleted after the reason for its retention ceases to exist.
Insofar as we are not able to meet your request to delete data, as the data may or must be retained for a statutorily permitted purpose, you have the right to demand your data be blocked for other purposes.
Insofar as you have granted us express consent to use your data, you can at any time revoke this, effective from that point forward, for example by cancelling your KALYPSO Account and ceasing to use the KALYPSO Services.
To assert your rights or for questions on the topic of data protection you can contact us at any time by post at Kalypso Media Group GmbH, Wilhelm-Leuschner-Strasse 11-13, 67547 Worms, Germany or by email at email@example.com. We will be happy to help you.
B Text of the declarations of consent
During the registration process for our KALYPSO Services or during their use you have, where applicable, granted us your express consent to use your data. You can download the content of this consent for yourself at any time.
You can revoke consent you have granted at any time, effective from that point forward, by deleting your account or sending a notification of revocation to us by post or by email. We hereby note that we may be obligated, on the basis of statutory obligations, in particular provisions relating to tax law and commercial regulations, to archive the relevant personal data even beyond the time the revocation takes effect. The data will be deleted after the relevant statutory time period.
Please note that if you do not consent to the use of your data or revoke your consent, you may not be able to use the KALYPSO Services or may only be able to use them to a limited extent.
1. Registering a KALYPSO Account
During your KALYPSO Account registration, you have also agreed, by activating the relevant check box, to the processing of your personal data to the extent set out below:
We may store the information provided by you in the course of the registration process (email address, username, password) until the revocation of your KALYPSO Account and use this for the identification of your person during log-in and for communication when providing our services. In addition to that, we use the data for statistical purposes in order to improve user friendliness and to promote the service. We may also use your email address to inform you about current events in relation to our services such as discount promotions, new developments, other services, events and competitions offered by us.
We can store further information and content (e.g. real name, home address, birthday, telephone number, gender, hobbies) which you voluntarily disclose when creating a player profile or a forum profile in the scope of the KALYPSO Service, to your KALYPSO Account and use that further information to the same extent as your original registration details. Where necessary, we also use the information saved in relation to your KALYPSO Account to tailor the advertisements displayed within our KALYPSO Services to your specific interests by assigning you to certain interest groups on the basis of this information. All data which you disclose in your public player profile or a public forum profile can also be seen by other registered users.
When you use our game we automatically collect a range of usage data, without your active input, on the game results and number of points, usage times and, where applicable, particular achievements attained via your account. This data is used for the creation of statistics and rankings as well as the outward presentation of your KALYPSO Account. We store these game statistics to your KALYPSO Account. Your game statistics together with your username are also visible online through your public player profile to other registered users and, in the form of rankings, where applicable, also to non-registered third parties.
Finally, we also use technologies and tools which automatically collect data on your use of our KALYPSO Services and on the use of advertisements we place on third party sites and newsletters (so-called conversion tracking). This also includes data automatically transmitted by your browser, such as your IP address, the length of time of access, the pages displayed and information on the hardware used by you, your operating system, browser information, your screen resolution and your internet service provider. This data will be collected by us and statistically evaluated in pseudonymised form, in order to analyse the use of our KALYPSO Services and thus improve the Service, adapt it to your requirements and detect security risks. Where necessary, we also use this information to tailor the advertisements displayed within our services to your specific interests by assigning you to certain interest groups on the basis of this information.
2. Newsletter subscription
When signing up to our newsletter, you have agreed, by activating the relevant check box, to the processing of your personal data to the extent set out below:
You agree that we, as part of our email newsletter, may regularly send you information on our products and services offers in the area of games and special promotions and events in connection with our services. You can, at any time, revoke your consent.