This website is operated by KONECT Games (UK) Ltd. (Company number 09885934), hereinafter referred to as “we”, “us” and “KONECT Games”, with registered office at 303 Goring Road, Worthing BN12 4NX, United Kingdom. As Data Controller, in accordance with Art. 4 (7) EU GDPR, we describe in this Data Protection Declaration the data we collect from you when you visit our website and for which purposes we process such data (Part A). In addition, we inform you on how we process data of our customers, suppliers and interested parties for marketing purposes (Part B), and explain in general which rights and safeguards we provide in the course of data processing (Part C). All relevant contact details are set forth under No. C.4 of this Data Protection Declaration.
As the protection of your personal data is very important to us, we strictly adhere to the statutory provisions as set forth in the Data Protection Act and the EU GDPR when collecting and processing your personal data.
In the following, we inform you in detail on the scope and purpose of our data processing as well as your rights as data subject. Therefore, please read our Data Protection Declaration thoroughly before you continue using our website and provide your consent to data processing if applicable.
A. PROCESSING OF PERSONAL DATA WITHIN OUR WEBSITE
1. PERSONAL DATA
In general, you can use our website without disclosing any personal data. However, the use of individual services can be subject to deviating provisions which we point out to you separately.
Thus, regardless of the cookies described in detail hereinafter, we generally only collect and store such data which you provide to us yourself by entering them into our input screen or through any other active interaction with our website.
Personal data is any information relating to an identified or identifiable natural person. For example, this includes your name, address, telephone number or your date of birth, but also your IP address or geolocation data which can allow for conclusions about your identity.
a. To the extent you use our website for informative purposes only, i.e. if you do not register for a service or otherwise provide us with information – e.g. in a contact form – we will only collect the personal data that your browser transmits to our server. So, if you wish to visit our website, we will collect the following data which is technically necessary for us to display our website to you and to ensure its stability and security in accordance with Art. 6 (1) sentence 1 point (f) EU GDPR:
· IP address
· date and time of the request
· time zone difference to the Greenwich Mean Time (GMT)
· content of the request
· access status / http status code
· data volume transferred in each instance
· website from which the request originates
· browser used
· operating system and its interface
· language and version of the browser software
In general, you can differentiate between first-party cookies, third-party cookies and third-party requests.
· First-party cookies
First-party cookies are stored by us or our website itself in your browser to provide you with the best possible user experience.
· Third-party cookies
Third-party cookies are stored in your browser by a third-party provider. These are mostly tracking or marketing tools which, on the one hand, evaluate your user behaviour, and on the other hand, enable the third-party provider to recognise you on other websites you visit. In general, for example retargeted marketing is based upon the function of such cookies.
· Third-party requests
Third-party requests are all enquiries which you as website user make to third parties via our website – for example, if you interact with plugins of social networks or use the offer of a payment provider. In such case, no cookies are stored in your browser, but it cannot be excluded that personal data are sent to such third-party provider through such interaction. For this reason, we also provide you with detailed information in our Data Protection Declaration about the tools & applications used by us.
c. Our website uses the following types of cookies the scope and functionality of which are explained in the following:
· Transient cookies
Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. Such cookies store what is referred to as the “session ID”, with which various requests from your browser can be assigned to the shared session. This will allow your computer to be recognised if you return to our website. These session cookies are erased as soon as you log out or close your browser.
· Persistent cookies
Persistent cookies are automatically deleted after a set period of time, which may differ depending on the cookie. However, you can delete the cookies yourself at any time via our browser settings.
d. You have the option to change your browser settings in a way in which you, for example, reject acceptance of third-party cookies or of all cookies. However, we have to notify you that in such case, you may not be able to use all functions of our website.
3. COLLECTION AND PROCESSING OF PERSONAL DATA
Personal data exceeding the information stored by cookies will only be processed by us if you disclose them to us voluntarily, e.g. if you register with us, enter into a contractual relationship with us or otherwise contact us. This only affects contact data as well as information on the matters for which you approach us.
We use the personal data provided by you only to the extent this is required in the course of fulfilling the respective purpose of the processing (e.g. registration, distribution of newsletters, processing of orders, distribution of information material and advertising, processing of competitions, responses to questions, enabling access to certain information) and permissible by applicable law (in particular in accordance with Art. 6 EU GDPR) (for example distribution of advertising and information material to existing customers).
The purpose of the processing of your data is the operation of our website and targeted provision of company-specific information, including the presentation of the goods and services we offer (marketing). Any further use of your data only takes place to the extent you provided us with your prior and express consent. You can withdraw your consent at any time with effect for the future, as set forth in more detail below.
4. STORAGE DURATION
In general, we store data which you provided us only for customer support or for marketing and information purposes until expiry of two years after our last communication. However, we will erase your data before expiry of such period if you request this to the extent this is not prevented by applicable statutory provisions.
In the event of a contract initiation or conclusion, we will process your personal data after full contract processing until the expiry of the guarantee, warranty, limitation and statutory retention periods to which we are subject, and until conclusion of any legal disputes for which we need the data as legal evidence.
5. OUR ONLINE SERVICES
a. Contact Form
You can contact us using our contact form provided on our website. For this purpose, we store your form of name, surname, e-mail and telephone number. We do not sell such data and do not disclose such data to third parties.
To the extent you consent thereto, we transfer your data within our group for the purpose of analysis as well as for the transfer of information for marketing purposes. Within our group of companies, the data that you provided to us for this purpose will be compared with data which we may collect from other sources in the course thereof.
6. TOOLS AND APPLICATION USED
a. Google Tools
Acting on our behalf, Google uses this information to assess your use of our website, to compile reports about the website activities and to perform other services connected to the use of the website and of the internet for the website operator. The IP address transferred by your browser in the context of Google Analytics will not be combined with any other data from Google.
If you wish further information on the type, scope and purpose of the data collected by Google, we recommend that you read their data protection provisions:
Google may process your data in the USA, and has agreed to comply with the EU-US Privacy Shield.
b. In addition, we also use the Google Adsense tool, an online advertising service by means of which advertising customised to your interests can be presented to you. With this tool, we pursue the interest to display to you advertising which might be of interest to you in order to make our website more interesting to you. For this purpose, statistical information about you is collected which is processed by our advertising partners which can be recognised by the note “Google Ads”.
If you visit our website, Google is informed that you accessed our website and sets a web beacon thereafter in order to store a cookie on your computer. The data mentioned under No. 4 of this Declaration will be transferred; we do not have any influence on the scope and duration of storage in the course of the processing of your data by Google. In the course thereof, your data will also be transferred to the USA and evaluated there. If you are logged on to your Google account, your data can be directly attributed to such account. If you do not wish your data to be attributed to your Google profile, you have to log out.
There are different ways for you to prevent installation of cookies of Google AdSense; in particular, you can reject the service when visiting our website or change your browser software settings accordingly.
c. We also use the services of Google Adwords in order to attract attention for our exciting offers and products by means of adverts on external websites. With this tool, we can also exactly determine inhowfar the individual marketing measures are proportionate to concrete campaigns. Thus, we pursue the interest to display to you customised advertising adapted to your interests and to achieve a fair calculation of marketing costs in this context.
The adverts shown to you are displayed by Google via so-called “Ad Servers”.
For this purpose, we use Ad Server cookies that can be measured by certain parameters such as fading-in of the adverts or clicks by the users in order to determine the success of marketing campaigns. This works as follows: In cases in which you access our website via a Google ad, Google Adwords stores a cookie in your browser which usually ceases to be valid after 30 days. The purpose of this cookie is not to identify you personally but to store the unique cookie ID, the number of Ad Impressions per placement, the last impression (relevant for post view conversions) as well as opt-out information for analysis purposes.
We do not ourselves collect or process personal data in the course of the use of Google Adwords; we only receive from Google statistical evaluations based upon which we can determine which of the marketing campaigns used by us are particularly successful.
In addition to the measures already described, you can prevent participation in such tracking process by deactivating cookies for conversion tracking; for this, you have to configure your browser such that cookies from the domain “www.googleadservices.com” are blocked or by permanent deactivation in your Firefox, Internet Explorer or Google Chrome browsers at the link www.google.com/settings/ads/plugin.
d. We use the “Custom Audiences” remarketing function provided by Facebook Inc. (“Facebook”). Thus, interest-based ads (“Facebook Ads”) can be displayed to the users of the website in the course of a visit to the Facebook social network or other websites also using the procedure. With this, we pursue the interest to display to you advertising which is of interest to you in order to make our website more interesting to you.
Through this marketing tool, your browser automatically establishes a direct connection to the Facebook server. We have no influence on the scope of such information disclosed in the course thereof and further use of the data by Facebook. If you are registered with Facebook, Facebook can attribute the visit to your profile – but even if you are not registered with and/or are not logged on to Facebook, there is the possibility that the provider finds out and stores your e-mail address. Further information on the data processing by Facebook is available at www.facebook.com/about/privacy.
The “Facebook Custom Audiences” function can be rejected upon visiting our website as well as for users who are logged in at https://www.facebook.com/settings/?tab=ads#_.
e. Our website also includes links to other websites; these are provided for information purposes only. These websites are not under our control and are therefore not covered by the provisions of this Data Protection Declaration. However, if you activate a link, the operator of such website may collect data on you and process it in accordance with their data protection declaration which may deviate from our Declaration. Please always read the current data protection provisions applicable to the websites linked to from our website.
f. In addition, our website provides you with the option to interact with different social networks using links and plugins. These may include:
· Facebook, operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
· Twitter, operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA
· Google+, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
· Linked In, operated by LinkedIn Inc., 2029 Stierlin Court, Mountain View, CA 94043, USA
· YouTube, operated by YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066 USA
. Vimeo, operated by Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA
If you click on a link or a plugin of one of these social networks, such plugin or link will be activated and, as described, a connection to the respective server of such network will be established. We have no influence on the scope and content of the data that is transferred to the respective operator of such social network by clicking on the plugin.
If you wish to obtain information on the nature, scope and purpose of the data collected by the operators of such social networks, we recommend that you read the data protection provisions of the relevant social network.
B. PROCESSING OF DATA OF OUR CUSTOMERS, SUPPLIERS AND INTERESTED PARTIES FOR MARKETING PURPOSES
We use personal data of our customers and suppliers, e.g. contact persons, their contact details and marketing-specific information, not only for the purpose of contract processing and subject to statutory retention obligations (e.g.: accounting), but also for marketing and customer support purposes.
In addition, we collect personal data of interested parties (such as contact persons, their contact details and marketing-specific information) in the course of our acquisition and sales activities. On the internet, at trade fairs and other events, we are always looking for potential contractual partners and for this purpose maintain a marketing database in order to allow for targeted advertising regarding our products and services. We perform all of the activities set forth herein in our legitimate interest for marketing purposes in accordance with Art. 6 (1) sentence 1 point (f) EU-GDPR in connection with Recital 47 for the duration of three years after the end of a contractual relationship (customers & suppliers) or our first (fruitless) communication (interested parties), unless there is an explicit consent of the data subject for storage and use beyond such period.
For example, you can participate in our demo events and test our apps in the course of our testing event free of charge. For this, you have to register with us in our software in the course of our testing event and create a user account therein.
For this purpose, we store your form of address, last name, first name, street, postcode, country, e-mail, telephone number, fax, website and combine them, subject to your consent, with your personal information already existing in the system in order to improve our products as well as our services. For this, we also obtain your consent so that, for example, our sales team inform you by e-mail after the event in order to receive your feedback on the event and your product experience. By participating in the texting event, you do not automatically subscribe to our newsletter, unless you expressly consent thereto in the course of the testing event.
If we do not collect the personal data for marketing purposes from the data subject, we inform the data subject about the source of their data during our first contact.
Where, in the course of an ongoing business relationship or due to an explicit request from an interested party, we are to provide products and services offered by other companies affiliated with us, we will provide such affiliated companies offering the products and services the particular data subject is interested in with personal data of the interested party due to our legitimate interest for marketing purposes.
We and each of the companies affiliated to us store data for marketing purposes and customer support analogously to the period as described in A.4.
C. GENERAL INFORMATION ON DATA PROTECTION
1. TRANSFER OF DATA
We generally do not transfer your data to third parties, unless we are legally obliged to do so or such disclosure is required to perform a contractual relationship concluded between us or you have expressly consented to the disclosure of your data in advance. External processors or other cooperation partners will only receive your data to the extent this is required for contract performance or if we have a legitimate interest therein; we will always point this out to you where applicable. To the extent one of our processors can access your personal data, we will ensure that such processors comply with the provisions under data protection legislation to the same extent as we do.
We do not sell to third parties your personal data. To the extent our contractual partners or processors are based in a third country, i.e. a state outside the European Economic Area (EEA), we inform you on the consequences thereof in the description of the offer.
We employ numerous technical and organisational security measures in order to protect your personal data against manipulation, loss, destruction and against access by unauthorised third parties. Our security measures are subject to ongoing improvements in accordance with technological developments on the internet. If you wish further information on the type and scope of the technical and organisational measures we take, we are gladly at your disposal for corresponding written requests at any time.
3. YOUR RIGHTS
In accordance with the General Data Protection Regulation and the Data Protection Act, you as data subject have the following rights and remedies:
· Right to Information (Art. 15 EU GDPR)
As data subject affected by the above described and other data processing activities, you are entitled to request information whether and, if so, which personal data relating to you is processed. For your own protection – to prevent unauthorised parties from obtaining information on your data – we will verify your identity in an appropriate manner before we provide such information.
· Right to Rectification (Art. 16) and Erasure (Art. 17 EU GDPR)
You are entitled to request immediate rectification of inaccurate personal data relating to you or – taking into account the purposes of data processing – completion of incomplete personal data as well as erasure of your data to the extent the criteria under Art. 17 EU GDPR have been fulfilled.
· Right to Restriction of Processing (Art 18 EU GDPR)
Under the applicable statutory conditions, you are entitled to restriction of processing of all personal data collected. As of the request for restriction, such data will only be processed subject to your individual consent or for the establishment and exercise of legal claims.
· Right to Data Portability (Art. 20 EU GDPR)
You can request unhindered and unrestricted transfer of personal data provided by you to you or a third party.
· Right to Object (Art. 21 EU GDPR)
You have the right to object, on grounds relating to your particular situation, at any time to any processing of the personal data relating to you which is necessary to safeguard our or a third party’s legitimate interests. After such objection, your data will no longer be processed, unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing is made for the establishment, exercise or defence of legal claims. You can object to data processing for the purpose of direct marketing with effect for the future at any time.
· Withdrawal of Consent
Should you have provided us with a separate consent to the processing of your personal data, you may withdraw that consent at any time. Such withdrawal applies to the lawfulness of the processing your personal data after you declared it towards us.
If you take a measure to assert your rights under the GDPR set forth above, KONECT Games (UK) Ltd. shall provide a statement on the measure requested or comply therewith without undue delay, no later than within one month after receipt thereof.
We will react to all reasonable requests free of charge and as fast as possible, subject to the statutory provisions.
For requests regarding a breach of the right to access, breach of the right to secrecy, rectification or erasure, the data protection authority is competent: https://ico.org.uk
4. CONTACT INFORMATION / CONTACT PERSON
a. Contact information of the Controller
KONECT Games (UK) Ltd.,
303 Goring Road
Worthing BN12 4NX
b. Contact information of the contact person for data protection matters
Version: August 2018