Data Protection Statement of European Games Group AG
EUROPEAN GAMES GROUP AG („EGG“),
Schellingstraße 21, 80799 Munich
Phone: +49 89 4444 9318,
Last Updated: 2020-07-21
Effective Date: 2020-07-21
Your privacy is important to us, and we take our responsibility of caring for it seriously. This policy describes what information EGG collects when you use the mobile, online and downloadable products and services (“products”) offered by EGG or by the respective Developer EGG maintains a publishing relationship. By using our products, you consent to this policy.
TABLE OF CONTENTS
- Information We Collect
- How We Collect Information
- How We Use Your Information
- Information We Share with Third Parties
- Where We Hold Your Information
- How We Protect Your Personal Information
- Duration of Storage, storage periods
- Your Choices and Controls
- Third Party Services
- Job Applications
- Changes to Our Policy
- Contact Us
1. Information We Collect
The information we collect depends on what products you use and how you use them. The controller of the personal information collected is European Games Group AG, Schellingstraße 21, 80799 Munich, phone: +49 89 4444 9318, E-Mail: email@example.com, Germany or the respective Developer. In case the Developer is the Controller, EGG is processor of the personal information.
A. Information You Give Us Directly
We collect information you provide us, including for example:
- Your email address, username, country, date of birth, telephone number and password;
- Security questions and answers;
- Demographic details, for instance in response to surveys about our products;
- Information you provide when seeking help from us such as your name and records of the issues you experience;
- Billing information, such as your name, address, telephone number, payment card number, and payment account details;
- Your Account information; and
- Information you provide to enter a contest or sweepstakes. If you win, we may need to collect your social security number, postal address and/or national identification for eligibility, prizes delivery and tax purposes.
When you participate in social features (such as chat), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected or used by other users without your consent. Please make sure your privacy settings reflect your preferences.
When you participate in online multiplayer games your in-game profile information, gameplay, and statistics are visible to all. We may record your gameplay, including your controller button inputs, and replay these together with your profile information and game statistics to other players in-game without further notice to you, for example as part of a spectator mode, or for out-of-game promotional purposes.
B. Other Information We Collect When You Use Our Products
We collect other information automatically when you use our products, including:
- IP address;
- Mobile and other hardware or device identifiers;
- Browser information, including your browser type and the language you prefer;
- Referring and exit pages, including landing pages and pages viewed;
- Platform type;
- Information about your media, device, hardware and software, such as your
hardware settings and components, software and updates you have installed or use, and presence of required plug ins; and
- Device event information, including crash reports, request and referral URL’s and system activity details (e.g. whether you encountered an error playing our games or lost Internet access)
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.
C. Information Provided to Us by Third Parties
PlayStation®3 & PlayStation®4 Computer Entertainment Systems. By signing up to play our products on a PlayStation®3 or PlayStation®4 computer entertainment system, information shared with the Developer by Sony might be shared with EGG.
Xbox Live. By signing up to play our products on Microsoft’s Xbox Live Service, information shared with the Developer by Microsoft might be shared with EGG.
Wii / Wii U. By signing up to play our products on a Nintendo Wii or Wii U console, information shared with the Developer by Nintendo might be shared with EGG.
Nintendo Switch™. By signing up to play our products on a Nintendo Switch™ console, information shared with the Developer by Nintendo might be shared with EGG.
Steam™. By signing up to play our products on via Steam™, information shared with the Developer by Valve might be shared with EGG.
Mobile Platforms. If you play or purchase our product on your mobile device and/or tablet, we receive information about you from the app stores, the Developer and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.
D. Other Third Parties
We may receive information from third parties, like Facebook or Game Center, when you use these services in connection with our products. We may also receive information about you when other players choose to share their contact lists with us.
We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found on https://gamesgroup.eu/privacyappendix. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.
2. How We Collect Information
We collect some information from you when you provide it to us directly, such as via an online form or when you talk with our customer support team. We and third parties also use certain technologies described below to collect information to deliver excellent experiences.
A. Cookies and Similar Technologies
We use also other technologies for similar purposes as a cookie. We use pixels or clear GIFs to collect information about your use of our products and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement. Other examples include HTML 5 cookies, Silverlight Application Storage, device fingerprints and “flash cookies.” If you want to remove flash cookies or prevent them from being placed, adjust your preferences in the Macromedia Website Privacy Settings Panel at www.macromedia.com/support/documentation/en/flashplayer/help/. We currently do not respond to Do Not Track (DNT) signals. We may adopt a DNT standard if one is established. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.
We also use Analytics, Advertising, Anti-Cheat and Anti-Fraud technologies in our products that utilize the same cookies and similar mechanisms. These technologies are described below.
B. Analytics Technologies
We use our own servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.
For instance, EGG may collect and store data from your computer or device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in section 3, below. If you play a game offline, this data will be stored on your device and transmitted to EGG when your device connects to the Internet. If you participate in online services, EGG also may collect, use, store, transmit and publicly display statistical data regarding game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.
Third party analytics services integrated into our products may combine the information they collect in connection with EGG’s services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A representative list of third party analytics companies that operate in our products can be found at https://gamesgroup.eu/privacyappendix.
C. Advertising Serving Technologies
These technologies collect and use information so we can serve appropriate advertising to you and help track results and measure effectiveness. In addition to identifiers, this information includes:
- Advertisements served and the location of the ad;
- Length of time an advertisement was visible;
- Domain type, IP address, size of the advertisement; and
- Advertisement response.
Third party advertising companies may combine the information collected in the context of delivering an ad to you via our Products and Services with other information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies. A representative list of advertising serving companies that operate their own networks on our sites and online and/or mobile products and/or services as well as how to opt out to the extent applicable can be found at https://gamesgroup.eu/privacyappendix.
To learn more about some of these ad networks’ practices, or to opt out of third party targeted advertising, you can visit https://www.networkadvertising.org, https://www.aboutads.info/choices/, http://youradchoices.ca/, or https://www.youronlinechoices.eu. Note that opting out does not mean you won’t see ads; it just means that the advertising you see may be less relevant to your interests.
D. Anti-Cheat and Fraud Prevention Technologies
3. How We Use Your Information
If processing of personal data is based on Article 6 f GDPR, our legitimate interest is the conduct of our business.
We use your personal and non-personal information, both individually and combined together, in the following ways:
To operate our business and to enhance and personalize your game experience including to:
- Operate, improve, and develop our games and services;
- Populate online leaderboards and enable online matchmaking;
- Provide replays to you and other players via spectator modes;
- Help you find your friends or tell your friends about an EGG product or service;
- Facilitate sharing on social networks;
- Serve and measure the effectiveness of advertising;
- Measure the health of our services;
- Set up and maintain accounts you register for;
- Provide game experiences that you may like;
- Set up loyalty programs;
- Facilitate your gameplay on multiple devices when available;
Identify, fix, and troubleshoot bugs and service errors;
- Provide software updates;
- Activate or authenticate your games and save game progress and stats;
- Adhere to your preferences and to deliver dynamic content; and
- Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.
To provide you support, including to:
- Help identify and troubleshoot problems with your account or games;
- To survey your opinions through surveys or questionnaires;
- Communicate with you and respond to your specific requests or questions; and
- Manage and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties.
To personalize our communications with you, including to:
- Present offers and/or information relating to games you might like to the extent permitted by law or consent based;
- Make recommendations to you; and
- Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
4. Information We Share with Third Parties
We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.
We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys, facilitating credit card processing, payment debt collection agency, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.
We do not knowingly disclose personal information about children under 18 years of age to independent third parties even with consent.
However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our games. An example is the Facebook “Like” button.
5. Where We Hold Your Information
6. How We Protect Your Personal Information
Security of our players’ information is a priority at EGG, and we take a range of measures to help protect it. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control. We process the information collected from you according to the European data protection law. All employees are obliged and have been advised to maintain data confidentiality and privacy obligations, and that received.
7. Duration of Storage, storage periods
We store your data only as long as this is necessary for the provision of our online offer and the associated services or we have a legitimate interest in the further storage. In all other cases, we will delete your personal information except for such information as we may need to maintain in order to fulfill contractual or statutory (e.g. tax or commercial) retention periods (e.g. invoices). Contractual retention periods may also arise from contracts with third parties (e.g. owners of copyrights and ancillary copyrights). Data that is subject to a retention period are saved until the expiration of the deadline.
8. Your Choices and Controls
We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your account information and preferences, choose to opt in or out of EGG marketing emails and choose whether to share your information with select EGG partners. If you would like to opt out at any time after granting approval, use the provided controls within the product or contact us directly.
You may deactivate your Account or delete the personal information associated with your account by using the provided controls within the product or by contacting us directly. If you do so, you will no longer have access to the our games or services associated with your account. Note that EGG may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you services, create and improve our products, comply with the law, and to run our business.
You can access the personal information we hold about you. To request access, contact us directly. Before we process any request, we may ask you for certain personal information in order to verify your identity and we may request payment where allowed by law. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your requests in a reasonable timeframe.
You have additionally, under certain conditions, the right to rectify, erase or restrict the processing of your personal data or have the right to object the processing. You also have the right for data portability. You can also object at any time to the processing of your personal data for advertising purposes (“advertising conflict”). Please take into account that for organizational reasons there may be an overlap between your revocation and the use of your data as part of an ongoing campaign. If you have given us consent to the processing of your data, you can withdraw them at any time with effect for the future. The lawfulness of the processing of your data until the revocation remains unaffected.
You can file a complaint with a data protection authority. You can contact the data protection authority, which is responsible for your place of residence or your state, or the data protection authority which is responsible for us. This is: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 27, D-91522 Ansbach, firstname.lastname@example.org.
You also may adjust your browser settings to block certain online tracking, such as cookies.
9. Third Party Services
10. Job application
Personal data which you submit on registration when applying for a particular position at EGG, such as your name, e-mail address, date of birth, telephone number, IP address, device ID, curriculum vitae, photograph, references and certificates or other information from which your identity is discernible.
Information we collect from third party public sources, such as LinkedIn or Xing or other career networking services.
By applying, you explicitly confirm that you are interested in an employment at EGG. You therefore voluntarily provide your personal data to be used for recruiting purposes, in particular for filing and matching your profile with any and all open positions at EGG, including beyond those for which you specifically applied.
If there is a job opportunity at EGG which matches your profile, EGG may forward your data to the responsible EGG managers in order to contact you for interviews. The personal data will be processed in the form of databases and will be collected in secured personal files.
You have the option of withdrawing your application at any time.
EGG will use your personal data:
– to manage your relationship with us and process your job application(s),
– to contact you (including by e-mail) about suitable job opportunities as they arise.
– to assess your eligibility for the particular position you have applied for or for available positions at EGG.
– to invite you to EGG recruitment events (including by e-mail).
We use reasonable safeguards to limit access to your personal data to those employees at EGG seeking/considering a candidate for a position.
As part of the application process and for successful candidates during your employment, we may share your data as follows:
– With third parties that work with EGG to organize and manage data on our behalf (“Service Providers”). In these circumstances your personal data will not be used by Service Providers for any other purpose and Service Providers will use reasonable security precautions.- In circumstances where we are legally required to do so.
– In the event of a reorganization, divestiture, merger or sale, we may transfer all personal data we collect to the relevant third party and will obtain your consent to do so if required by law.
Your data will be deleted in accordance with the applicable laws once the application process ends or if you withdraw your application.
On deletion of your personal data we may retain limited personal information to ensure that we do not contact you again in the future and where there is a legal requirement to do so.
You may choose to submit digital materials demonstrating your skills and abilities for review by EGG (“Material(s)”). Please note that Materials are not generally required. If submitted, we will use your Material only for evaluation purposes and will not distribute any copies of the Material to any third parties. We will return or destroy all copies of your Material upon completion of our review or upon your earlier request.
EGG engages in a continuous program to develop new products and ideas internally and we also regularly receive other submissions for consideration. The games, ideas or concepts that EGG develops internally or that others submit may be similar to your Material. As a result, we cannot agree to treat as confidential any Material you submit, even if it is marked as confidential or proprietary. Our acceptance or review of your Material does not imply that we will use, develop or market your Material. Our review of your Material does not prevent us from using, developing, or marketing technologies, ideas or games that may be similar in concept or idea to your Material.
11. Changes to Our Policy
We may update this policy from time to time, so please review it frequently. We’ll notify you of material changes via a notice within our products. Your continued use of our products means you accept the changes. Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms. If you are asked to affirmatively accept material changes to this policy and you decline to do so, you may not be able to continue to use the product provided.
12. Contact Us
If you have a complaint or question about this policy, you may contact us at email@example.com (Data Protection Officer: Maximilian Hartung (eDSB of Datenschutz Agentur).