We are very
delighted that you have shown interest in
our enterprise. Data protection is of a particularly high priority for the management
of the FreeGame. The use of the Internet pages of the FreeGame is possible without any indication of personal data; however, if a data subject wants to use special enterprise services
via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The
processing of personal data, such as the name,
address, e-mail address, or telephone number of a data subject shall always be
in line with the General Data Protection Regulation (GDPR), and in accordance
with the country-specific data protection regulations applicable to the
FreeGame. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore,
data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the
controller, the FreeGame has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions
may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
The data
protection declaration of the FreeGame is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible
and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this
data protection declaration, we use, inter
alia, the following terms:
Personal
data means any information relating to an
identified or identifiable natural person . An identifiable
natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification
number, location data, an online identifier or to one or more factors specific
to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.
Data
subject is any identified or identifiable natural
person, whose personal data is processed by the controller responsible for the
processing.
Processing
is any operation or set of operations which
is performed on personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.
Restriction
of processing is the marking of stored
personal data with the aim of limiting their processing in the future.
Profiling
means any form of automated processing of
personal data consisting of the use of personal data to evaluate certain
personal aspects relating to a natural person, in particular to analyses or
predict aspects concerning that natural person's performance at work, economic
situation, health, personal preferences, interests, reliability, behavior,
location or movements.
Pseudonymisation is the processing of personal data in
such a manner that the personal data can no longer be attributed to a specific
data subject without the use of additional information, provided that such
additional information is kept separately and is subject to technical and
organizational measures to ensure that the personal data are not attributed to
an identified or identifiable natural person.
Controller
or controller responsible for the
processing is the natural or legal person, public authority, agency or other
body which, alone or jointly with others, determines the purposes and means of
the processing of personal data; where the purposes and means of such
processing are determined by Union or Member State law, the controller or the specific
criteria for its nomination may be provided for by Union or Member State law.
Processor
is a natural or legal person, public
authority, agency or other body which processes personal data on behalf of the
controller.
Recipient
is a natural or legal person, public
authority, agency or another body, to which the personal data are disclosed,
whether a third party or not. However, public authorities which may receive
personal data in the framework of a particular inquiry in accordance with Union
or Member State law shall not be regarded as recipients; the processing of
those data by those public authorities shall be in compliance with the
applicable data protection rules according to the purposes of the processing.
Third party
is a natural or legal person, public
authority, agency or body other than the data subject, controller, processor
and persons who, under the direct authority of the controller or processor, are
authorized to process personal data.
Consent of
the data subject is any freely given,
specific, informed and unambiguous indication of the data subject's wishes by
which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her.
Controller
for the purposes of the General Data
Protection Regulation (GDPR), other data protection laws applicable in Member
states of the European Union and other provisions related to data protection
is:
FreeGame
The Data
Protection Officer of the controller is:
Jason
tomas
FreeGame
Any data
subject may, at any time, contact our Data
Protection Officer directly with all questions and suggestions concerning data
protection.
The
Internet pages of the FreeGame use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many
Internet sites and servers use cookies. Many
cookies contain a so-called cookie ID. A cookie ID is a unique identifier of
the cookie. It consists of a character string through which Internet pages and
servers can be assigned to the specific Internet browser in which the cookie
was stored. This allows visited Internet sites and servers to differentiate the
individual browser of the dats subject from other Internet browsers that
contain other cookies. A specific Internet browser can be recognized and
identified using the unique cookie ID.
Through the
use of cookies, the FreeGame can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of
a cookie, the information and offers on
our website can be optimized with the user in mind. Cookies allow us, as
previously mentioned, to recognize our website users. The purpose of this
recognition is to make it easier for users to utilize our website. The website
user that uses cookies, e.g. does not have to enter access data each time the
website is accessed, because this is taken over by the website, and the cookie
is thus stored on the user's computer system. Another example is the cookie of
a shopping cart in an online shop. The online store remembers the articles that
a customer has placed in the virtual shopping cart via a cookie.
The data
subject may, at any time, prevent the setting
of cookies through our website by means of a corresponding setting of the
Internet browser used, and may thus permanently deny the setting of cookies.
Furthermore, already set cookies may be deleted at any time via an Internet
browser or other software programs. This is possible in all popular Internet
browsers. If the data subject deactivates the setting of cookies in the
Internet browser used, not all functions of our website may be entirely usable.
The website
of the FreeGame collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected
may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of
access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information
technology systems.
When using
these general data and information, the
FreeGame does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement,
(3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the
FreeGame analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the
personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The data
subject has the possibility to register on
the website of the controller with the indication of personal data. Which
personal data are transmitted to the controller is determined by the respective
input mask used for the registration. The personal data entered by the data
subject are collected and stored exclusively for internal use by the
controller, and for his own purposes. The controller may request transfer to
one or more processors (e.g. a parcel service) that also uses personal data for
an internal purpose which is attributable to the controller.
By
registering on the website of the controller, the
IP address��assigned by the Internet service provider (ISP) and used by the data
subject��date, and time of the registration are also stored. The storage of this
data takes place against the background that this is the only way to prevent
the misuse of our services, and, if necessary, to make it possible to investigate
committed offenses. Insofar, the storage of this data is necessary to secure
the controller. This data is not passed on to third parties unless there is a
statutory obligation to pass on the data, or if the transfer serves the aim of
criminal prosecution.
The
registration of the data subject, with the
voluntary indication of personal data, is intended to enable the controller to
offer the data subject contents or services that may only be offered to
registered users due to the nature of the matter in question. Registered
persons are free to change the personal data specified during the registration
at any time, or to have them completely deleted from the data stock of the
controller.
The data
controller shall, at any time, provide
information upon request to each data subject as to what personal data are
stored about the data subject. In addition, the data controller shall correct
or erase personal data at the request or indication of the data subject,
insofar as there are no statutory storage obligations. A Data Protection
Officer particularly designated in this data protection declaration, as well as
the entirety of the controller��s employees are available to the data subject in
this respect as contact persons.
The website
of the FreeGame contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail
(e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject
to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
The data
controller shall process and store the
personal data of the data subject only for the period necessary to achieve the
purpose of storage, or as far as this is granted by the European legislator or
other legislators in laws or regulations to which the controller is subject to.
If the
storage purpose is not applicable, or if a
storage period prescribed by the European legislator or another competent
legislator expires, the personal data are routinely blocked or erased in
accordance with legal requirements.
Each data
subject shall have the right granted by the
European legislator to obtain from the controller the confirmation as to
whether or not personal data concerning him or her are being processed. If a
data subject wishes to avail himself of this right of confirmation, he or she
may, at any time, contact our Data Protection Officer or another employee of
the controller.
Each data
subject shall have the right granted by the
European legislator to obtain from the controller free information about his or
her personal data stored at any time and a copy of this information.
Furthermore, the European directives and regulations grant the data subject
access to the following information:
Furthermore, the data subject shall have a right to
obtain information as to whether personal data are transferred to a third
country or to an international organization. Where this is the case, the data
subject shall have the right to be informed of the appropriate safeguards
relating to the transfer.
If a data
subject wishes to avail himself of this
right of access, he or she may at any time contact our Data Protection Officer
or another employee of the controller.
Each data
subject shall have the right granted by the
European legislator to obtain from the controller without undue delay the
rectification of inaccurate personal data concerning him or her. Taking into
account the purposes of the processing, the data subject shall have the right
to have incomplete personal data completed, including by means of providing a
supplementary statement.
If a data
subject wishes to exercise this right to
rectification, he or she may, at any time, contact our Data Protection Officer
or another employee of the controller.
Each data
subject shall have the right granted by the
European legislator to obtain from the controller the erasure of personal data
concerning him or her without undue delay, and the controller shall have the
obligation to erase personal data without undue delay where one of the
following grounds applies, as long as the processing is not necessary:
If one of
the aforementioned reasons applies, and a
data subject wishes to request the erasure of personal data stored by the
FreeGame, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the
FreeGame or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the
controller has made personal data public and
is obliged pursuant to Article 17(1) to erase the personal data, the
controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to
inform other controllers processing the personal data that the data subject has
requested erasure by such controllers of any links to, or copy or replication
of, those personal data, as far as processing is not required. The Data
Protection Officer of the FreeGame or another employee will arrange the necessary measures in individual cases.
Each data
subject shall have the right granted by the
European legislator to obtain from the controller restriction of processing
where one of the following applies:
If one of
the aforementioned conditions is met, and a
data subject wishes to request the restriction of the processing of personal
data stored by the FreeGame, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the FreeGame or another
employee will arrange the restriction of the processing.
Each data
subject shall have the right granted by the
European legislator, to receive the personal data concerning him or her, which
was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit those data
to another controller without hindrance from the controller to which the
personal data have been provided, as long as the processing is based on consent
pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2)
of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the
GDPR, and the processing is carried out by automated means, as long as the
processing is not necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the
controller.
Furthermore, in exercising his or her right to data
portability pursuant to Article 20(1) of the GDPR, the data subject shall have
the right to have personal data transmitted directly from one controller to
another, where technically feasible and when doing so does not adversely affect
the rights and freedoms of others.
In order to
assert the right to data portability, the
data subject may at any time contact the Data Protection Officer designated by
the FreeGame or another employee.
Each data
subject shall have the right granted by the
European legislator to object, on grounds relating to his or her particular
situation, at any time, to processing of personal data concerning him or her,
which is based on point (e) or (f) of Article 6(1) of the GDPR. This also
applies to profiling based on these provisions.
The FreeGame shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of
the data subject, or for the establishment, exercise or defense of legal claims.
If the
FreeGame processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies
to profiling to the extent that it is related to such direct marketing. If the data subject objects to the FreeGame to the processing for direct marketing purposes, the
FreeGame will no longer process the personal data for these purposes.
In
addition, the data subject has the right, on
grounds relating to his or her particular situation, to object to processing of
personal data concerning him or her by the FreeGame for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
In order to
exercise the right to object, the data
subject may directly contact the Data Protection Officer of the FreeGame or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding
Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Each data
subject shall have the right granted by the
European legislator not to be subject to a decision based solely on automated
processing, including profiling, which produces legal effects concerning him or
her, or similarly significantly affects him or her, as long as the decision (1)
is not is necessary for entering into, or the performance of, a contract
between the data subject and a data controller, or (2) is not authorized by
Union or Member State law to which the controller is subject and which also
lays down suitable measures to safeguard the data subject's rights and freedoms
and legitimate interests, or (3) is not based on the data subject's explicit
consent.
If the
decision (1) is necessary for entering into, or
the performance of, a contract between the data subject and a data controller,
or (2) it is based on the data subject's explicit consent, the FreeGame shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain
human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data
subject wishes to exercise the rights
concerning automated individual decision-making, he or she may at any time
directly contact our Data Protection Officer of the FreeGame or another employee of the controller.
Each data
subject shall have the right granted by the
European legislator to withdraw his or her consent to processing of his or her
personal data at any time.
f the data
subject wishes to exercise the right to withdraw
the consent, he or she may at any time directly contact our Data Protection
Officer of the FreeGame or another employee of the controller.
The data
controller shall collect and process the
personal data of applicants for the purpose of the processing of the
application procedure. The processing may also be carried out electronically.
This is the case, in particular, if an applicant submits corresponding
application documents by e-mail or by means of a web form on the website to the
controller. If the data controller concludes an employment contract with an
applicant, the submitted data will be stored for the purpose of processing the
employment relationship in compliance with legal requirements. If no employment
contract is concluded with the applicant by the controller, the application
documents shall be automatically erased two months after notification of the
refusal decision, provided that no other legitimate interests of the controller
are opposed to the erasure. Other legitimate interest in this relation is, e.g.
a burden of proof in a procedure under the General Equal Treatment Act (AGG).
On this
website, the controller has integrated Google
AdSense. Google AdSense is an online service which allows the placement of
advertising on third-party sites. Google AdSense is based on an algorithm that
selects advertisements displayed on third-party sites to match with the content
of the respective third-party site. Google AdSense allows an interest-based
targeting of the Internet user, which is implemented by means of generating
individual user profiles.
The
operating company of Google's AdSense component is
Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United
States.
The purpose
of Google's AdSense component is the
integration of advertisements on our website. Google AdSense places a cookie on
the information technology system of the data subject. The definition of
cookies is explained above. With the setting of the cookie, Alphabet Inc. is
enabled to analyze the use of our website. With each call-up to one of the
individual pages of this Internet site, which is operated by the controller and
into which a Google AdSense component is integrated, the Internet browser on
the information technology system of the data subject will automatically submit
data through the Google AdSense component for the purpose of online advertising
and the settlement of commissions to Alphabet Inc. During the course of this
technical procedure, the enterprise Alphabet Inc. gains knowledge of personal
data, such as the IP address of the data subject, which serves Alphabet Inc.,
inter alia, to understand the origin of visitors and clicks and subsequently
create commission settlements.
The data
subject may, as stated above, prevent the
setting of cookies through our website at any time by means of a corresponding
adjustment of the web browser used and thus permanently deny the setting of
cookies. Such an adjustment to the Internet browser used would also prevent
Alphabet Inc. from setting a cookie on the information technology system of the
data subject. Additionally, cookies already in use by Alphabet Inc. may be
deleted at any time via a web browser or other software programs.
Furthermore,
Google AdSense also uses so-called tracking pixels(
).
Through
Google AdSense, personal data and
information which also includes the IP address, and is necessary for the
collection and accounting of the displayed advertisements is transmitted to
Alphabet Inc. in the United States of America. These personal data will be
stored and processed in the United States of America. The Alphabet Inc. may
disclose the collected personal data through this technical procedure to third
parties.
Google
AdSense is further explained under the
following link https://www.google.com/intl/en/adsense/start/
Google
Analytics is further explained under the
following
Link: https://policies.google.com/privacy
On this
website, the controller has integrated
components of DoubleClick by Google. DoubleClick is a trademark of Google,
under which predominantly special online marketing solutions are marketed to
advertising agencies and publishers.
The
operating company of DoubleClick by Google is
Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED
STATES.
DoubleClick
by Google transmits data to the
DoubleClick server with each impression, clicks, or other activity. Each of these
data transfers triggers a cookie request to the data subject's browser. If the
browser accepts this request, DoubleClick uses a cookie on the information
technology system of the data subject. The definition of cookies is explained
above. The purpose of the cookie is the optimization and display of
advertising. The cookie is used, inter alia, to display and place user-relevant
advertising as well as to create or improve reports on advertising campaigns.
Furthermore, the cookie serves to avoid multiple display of the same
advertisement.
DoubleClick
uses a cookie ID that is required to
execute the technical process. For example, the cookie ID is required to
display an advertisement in a browser. DoubleClick may also use the Cookie ID
to record which advertisements have already been displayed in a browser in
order to avoid duplications. It is also possible for DoubleClick to track
conversions through the cookie ID. For instance, conversions are captured, when
a user has previously been shown a DoubleClick advertising ad, and he or she
subsequently makes a purchase on the advertiser's website using the same
Internet browser.
A cookie
from DoubleClick does not contain any
personal data. However, a DoubleClick cookie may contain additional campaign
IDs. A campaign ID is used to identify campaigns that the user has already been
in contact with.
With each
call-up to one of the individual pages of
this website, which is operated by the controller and on which a DoubleClick
component was integrated, the Internet browser on the information technology
system of the data subject is automatically prompted by the respective
DoubleClick component to send data for the purpose of online advertising and
billing of commissions to Google. During the course of this technical procedure,
Google gains knowledge of any data that Google may use to create commission
calculations. Google may, inter alia, understand that the data subject has
clicked on certain links on our website.
The data
subject may, as stated above, prevent the
setting of cookies through our website at any time by means of a corresponding
adjustment of the web browser used and thus permanently deny the setting of
cookies. Such an adjustment to the Internet browser used would also prevent
Google from setting a cookie on the information technology system of the data
subject. In addition, cookies already in use by Google may be deleted at any
time via a web browser or other software programs.
Further
information and the applicable data protection
provisions of DoubleClick may be retrieved under DoubleClick by Google https://www.google.com/intl/en/policies/
.
Art. 6(1)
lit. a GDPR serves as the legal basis for
processing operations for which we obtain consent for a specific processing
purpose. If the processing of personal data is necessary for the performance of
a contract to which the data subject is party, as is the case, for example,
when processing operations are necessary for the supply of goods or to provide
any other service, the processing is based on Article 6(1) lit. b GDPR. The
same applies to such processing operations which are necessary for carrying out
pre-contractual measures, for example in the case of inquiries concerning our
products or services. Is our company subject to a legal obligation by which
processing of personal data is required, such as for the fulfillment of tax
obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases,
the processing of personal data may be necessary to protect the vital interests
of the data subject or of another natural person. This would be the case, for
example, if a visitor were injured in our company and his name, age, health
insurance data or other vital information would have to be passed on to a
doctor, hospital or other third party. Then the processing would be based on
Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article
6(1) lit. f GDPR. This legal basis is used for processing operations which are
not covered by any of the above-mentioned legal grounds, if processing is
necessary for the purposes of the legitimate interests pursued by our company
or by a third party, except where such interests are overridden by the
interests or fundamental rights and freedoms of the data subject which require
protection of personal data. Such processing operations are particularly
permissible because they have been specifically mentioned by the European
legislator. He considered that a legitimate interest could be assumed if the
data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Where the
processing of personal data is based on Article
6(1) lit. f GDPR our legitimate interest is to carry out our business in favor
of the well-being of all our employees and the shareholders.
The
criteria used to determine the period of storage of
personal data is the respective statutory retention period. After expiration of
that period, the corresponding data is routinely deleted, as long as it is no
longer necessary for the fulfillment of the contract or the initiation of a
contract.
We clarify
that the provision of personal data is
partly required by law (e.g. tax regulations) or can also result from
contractual provisions (e.g. information on the contractual partner). Sometimes
it may be necessary to conclude a contract that the data subject provides us
with personal data, which must subsequently be processed by us. The data
subject is, for example, obliged to provide us with personal data when our
company signs a contract with him or her. The non-provision of the personal
data would have the consequence that the contract with the data subject could
not be concluded. Before personal data is provided by the data subject, the
data subject must contact our Data Protection Officer. Our Data Protection
Officer clarifies to the data subject whether the provision of the personal
data is required by law or contract or is necessary for the conclusion of the
contract, whether there is an obligation to provide the personal data and the
consequences of non-provision of the personal data.
Last updated: February 7th, 2019