1 CONTROLLER AND CONTACT
The controller pursuant to data protection laws is:
Kolibri Games GmbH
Hallesches Ufer 60
If you have any questions or suggestions about data protection, you can send us an e-mail at firstname.lastname@example.org.
Our data protection officer can be reached at the following address: Dominik Fünkner, Leopoldstr. 21, 80802 München, www.datenschutzexperte.de.
2 SCOPE OF DATA PROTECTION
The scopeof data protection is personal data. In accordance with Article 4 section 1 GDPR, personal data encompasses all information relating to an identified or identifiable natural person, which includes, for example, names or identification numbers.
3 COLLECTION AND USE OF YOUR DATA
3.1 AUTOMATED DATA COLLECTION
When accessing our website, your device automatically transmits data for technical purposes. The following information is stored separately from any other information you may transmit to us:
- URL accessed
- Date and time of access
- IP address (minus one byte)
This data is stored for technical reasons only and is never associated with any specific person.
When you submit an application to us through our website, we collect and store the data that you transmit so we can examine your application.
Your data is collected and stored in order to process your application (Article 6 section 1 (b) GDPR).
We store so-called cookies in order to offer you a comprehensive range of features and to make our websites more convenient to use. Cookies are small files that your web browser stores on your computer. If you do not want any cookies used, you can prevent cookies being stored on your computer by adjusting the settings of your web browser. Please note that by doing so, you might reduce the functionality of our site.
Specifically, we use the following cookies:
- Own cookies
- remembers that you accepted the cookie agreement.
- Third party functions
- Google Maps
- Breezy HR
- Social Website Cookies
5 Google Analytics
We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called cookies, text files that are stored on your device and allow us to analyze how you use our website. The information that the cookie generates about your use of this website (including your abbreviated IP address) is transmitted to a Google server in the United States and stored there. Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to the use of our website and internet usage. Google might also transfer this information to third parties if required by law or insofar as third parties pro-cess this data on Google’s behalf.
If you do not want web page analytics to be used, you can opt out of Google Analytics by using a browser add-on. You can download the add–on here: http://tools.google.com/dlpage/gaoptout.
We are entitled to use Google Analytics because we have a legitimate interest in custom-ized design and in performing a statistical analysis of our website, and due to the fact that your legitimate interests do not prevail under Article 6 section 1 (f) GDPR.
6 CHANGE OF PURPOSE
Your personal data might be used for purposes other than those described, but only if the law allows it, or if you have consented to a change in the purpose of processing your data. If your data is subsequently processed for purposes other than those for which it was originally collected, we will tell you what these other purposes are before further processing occurs, and provide you with all other relevant information.
7 AUTOMATED INDIVIDUAL DECISIONS OR PROFILING MEASURES
We do not use automated processing to make decisions, and we do not profile.
8 DISCLOSURE OF DATA
As a matter of principle, your personal data will not be disclosed to others without your express prior consent, except in the following circumstances:
- To provide our services, we outsource work to outside companies under contract and to service providers (“processors”). In such cases, personal data will be transferred to such processors for processing. These processors are carefully selected and regularly reviewed by us to ensure your privacy. Processors may only use data for the purposes specified by us. Moreover processors are contractually bound to process your data only in accordance with this data protection policy and with German data protection laws.
We outsource work to the following processors:
- Microsoft Ireland Operations Limited
- Breezy HR, Inc.
Transfer of data to processors is based on Article 28 section 1 GDPR. In subsidiary manner transfer can be warranted on grounds of our legitimate interest in the economic and technical benefits of using specialized processors, and due to the fact that your rights and interests in protecting your personal data do not prevail under Article 6 section 1 (f) GDPR.
- We also process data in countries outside the European Economic Area (“EEA”).For the US, the European Commission resolved by decision of July 12, 2016 that under the rules for the EU-U.S. Privacy Shield an adequate degree of data protection exists (adequacy decision, Article 45 GDPR). Additional information – including information about certification of our service providers – is available at https://www.privacyshield.gov. We use the following service providers, which are certified under the EU-U.S. Privacy Shield:
- Microsoft Corp. (for maintenance services from the USA)
- Breezy HR, Inc.
9 DELETION OF YOUR DATA
We will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs, unless the data must be kept longer for legal reasons, for criminal prosecution or to secure, assert or enforce legal claims.
If data must be kept for legal reasons, they are blocked. In that case they are no longer available for further use.
10 YOUR RIGHTS AS A DATA SUBJECT
10.1 RIGHT TO INFORMATION
You are entitled at any time upon request, to obtain information from us about your personal data within the scope of Article 15 GDPR. To request such information, you may submit an application by mail or by e-mail to the address given above.
10.2 RIGHT TO CORRECT INACCURATE DATA
You are entitled to demand that we correct forthwith any inaccurate personal data concerning you. For this purpose, please get in touch with the contact addresses listed above.
10.3 RIGHT TO DELETION
10.4 RIGHT TO RESTRICTION OF PROCESSING
You are entitled to demand that we restrict processing in accordance with Article 18 GDPR. This right applies especially if we are not in agreement with the user concerning the accuracy of any personal data. The right persists for the time required to verify its accuracy. In addition such right applies in the following cases: if the user is entitled to demand deletion but instead demands restricted processing; if the data is no longer required for the purposes we are pursuing, but the user needs them in order to assert, exercise or defend legal claims; and if an objection has been raised but its successful exercise is still disputed between us and the user. To assert aforesaid right, please get in touch with the contact addresses listed above.
10.5 RIGHT TO DATA TRANSFERABILITY
You are entitled to demand from us whatever personal information you may have given us. Pursuant to Article 20 GDPR, at your request we must provide you with such information in a structured, commonly used and machine-readable format. To assert aforesaid right, please get in touch with the contact addresses listed above.
10.6 RIGHT TO OBJECT
Pursuant to Article 21 GDPR you are entitled at any time to object to the processing of your personal data on grounds related to your particular situation, including grounds under Article 6 section 1 (e) or (f) GDPR. We will cease processing your personal information unless we can demonstrate compelling and legitimate grounds for processing that outweigh your interests, rights and freedoms, or unless the processing is done for the purpose of enforcing, pursuing or defending legal claims.
You are entitled to make a complaint to the pertinent oversight body. The oversight body in charge is:
Berlin Commissioner for Data Protection and Freedom of Information
11 CHANGES TO THIS DATA PROTECTION POLICY
Updated to: 1. June 2018