Draft data privacy statement of astragon Entertainment GmbH

I. General information

Welcome! Thank you for your interest in our website. We are astragon Entertainment GmbH, Am Wehrhahn 33, D-40211 Düsseldorf. You can contact us at: info@astragon.de. Below we explain which personal data we collect and process when you use our services or make use of our offers.

Our standard

The protection of your privacy is of the utmost importance to us. For this reason, compliance with the statutory provisions on data protection is a given for us. However, it is also important to us that you know at all times which personal data we collect and why, and how we process it. We will also be happy to explain to you what rights you have and how you can exercise them.

What is personal data?

In short, anything that can be used to identify you as an individual person, whether through the information itself or in connection with other information. Examples of this are your name, your e-mail address or even a customer number, but also the time at which you visit our website, if this is stored together with your IP address. We always endeavour to collect as little personal data as possible. At the same time, we inform you in detail in this document about your personal data, if we collect any.

Why is this document so long?

The legislator requires that we describe all personal data to you individually,

 

1. Responsible body & company data protection officer

We are responsible within the meaning of the European General Data Protection Regulation (GDPR):

astragon Entertainment GmbH
Am Wehrhahn 33, 40211 Düsseldorf
info@astragon.de

For all enquiries regarding data protection, please contact our company data protection officer. You can reach the data protection officer at: datenschutz@astragon.de

2. Legal basis

We collect and process personal data based on the following legal bases:

We store and access information on your device based on the following legal bases:

3. Rights of data subjects

When it comes to your personal data, you are the data subject. You are entitled to the following rights with regard to data processing by us to the extent specified in the respective articles of the General Data Protection Regulation:

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, work or the place of the alleged infringement if you believe that the processing of personal data relating to you infringes the GDPR.

4.Deletion of data and duration of storage

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

II. Specific data processing

1. Data collection when visiting the website

a) Scope of the data processing

When you visit our website, the following data will be gathered and saved by our web server:

The IP address or host name is only available to us in anonymised form in the log files. This data is stored in the log files of our system. This data is not stored together with other personal data of the user. Our websites are hosted by our hosting service provider Strato AG, which also processes this data for us.

b) Legal basis

The legal basis for the processing of the aforementioned data is Art. 6 para. 1 lit. f GDPR. The legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR lies in the functionality of our website and its availability, which fulfils the requirements of the users and takes their usage preferences into account.

 

c) Purpose of the data processing

Temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session. The data is stored to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

d) Duration of the storage

The log files are deleted from the system after 6 weeks at the latest. If there is a need to retain the data for the aforementioned purpose due to specific events, the data may be stored for longer. In any case, as already mentioned, the IP addresses of users are anonymised so that it is no longer possible to assign them to a specific user.

e) Right to objection and removal

The collection of data for the provision of the website and the storage of the data is absolutely necessary for the operation of the website. Consequently, the user has no option to object.

2. Contact form

a) Scope of the data processing

There is a contact form on our website that can be used to contact us electronically. If you enter data in the input mask, it will be transmitted to us and stored. These data are your name, your e-mail address, your telephone number if applicable, the nature of your enquiry and your individual message to us. The date and time of your message is also automatically recorded.

Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

b) Legal basis

The legal basis for the processing of the data transmitted in the course of contacting us is Article 6 para. 1 lit. f and, if applicable, also lit. a GDPR. If the contact is aimed at the conclusion of a contract or relates to a contractual relationship, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

The legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR lies in answering a customer enquiry or answering a contact enquiry on other topics. The data is stored on our servers on the basis of Art. 28 para. 3 GDPR.

c) Purpose of the data processing

The purpose of data storage is to make contact at the request of the communication partner.

d) Duration of the storage

The data will be stored for as long as is necessary to deal with the enquiry. Insofar as these are commercial letters subject to retention under commercial and tax law, they will also be stored for the statutory retention period.

e) Right to objection and removal

The user has the option at any time to revoke their consent to the processing of personal data with effect for the future or to object to further use in accordance with the above-mentioned processing purposes. The objection can be sent by e-mail to datenschutz@astragon.de. Deletion can only take place if we no longer need to store the message or if it is no longer required for warranty purposes; in this case, however, the data will be blocked for any other use. In such a case, the conversation cannot be continued.

3. Application data

a) Scope of the data processing

We publish vacancies on our website and on LinkedIn and ask you to apply for the individual positions. You can apply by e-mail or LinkedIn and we will make the information you provide in your application available to our relevant employees. For the processing of this data we use services of Personio SE & Co KG, for applications via e-mail services of Microsoft Corp and for applications via LinkedIn services of LinkedIn Ireland Unlimited Company. Personio is based in Germany. Microsoft Corp. is based in the United States of America. LinkedIn Ireland Unlimited Company is based in Ireland.

b) Legal basis

The legal basis for the processing of your application data is Section 26 BDSG. The storage of data at Mircosoft Corp. takes place on the basis of Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c GDPR using the standard clauses of the EU Commission. The storage of data at Personio SE & Co. KG and LinkedIn Ireland Unlimited Company is based on Art. 28 para. 3 GDPR.

c) Purpose of the data processing

The address data will be used to contact you. The other data will only be used to check whether we wish to offer you the position in question or another position and to be able to respond to any subsequent allegations of discrimination.

d) Duration of the storage

The data will be stored for as long as we consider you to be a potential candidate for the job offer and thereafter for at least the duration of your employment relationship or, if we do not agree on an employment contract, for at least six months after the position has been awarded to a third party in order to be able to respond to discrimination claims. In this case, you can request the deletion of your application data at any time after the aforementioned period of 6 months by sending an e-mail to datenschutz@astragon.de.

e) Right to objection and removal

You can object to the use of your data at any time by sending an e-mail to datenschutz@astragon.de and we will then delete your personal data. Until then, we will not use the data for any other purpose than to respond to allegations of discrimination.

4. YouTube embedded

a) Scope of the data processing

We embed videos from Youtube.com on our websites. In this case, this content is not initially loaded. Only when you click on a correspondingly labelled link with information about the respective provider of the integrated content, this content will be loaded. This establishes a direct connection to the web server of the respective provider and the respective provider can process your personal data. Please refer to the provider's privacy policy to find out what data is involved:
Google / YouTube provides data protection information here: https://policies.google.com/privacy

b) Legal basis

The legal basis for enabling data collection by the respective content provider is your express consent pursuant to Art. 6 para. 1 lit. a GDPR by clicking on the corresponding link despite a corresponding notice.

c) Purpose of the data processing

The purpose of enabling data collection by the content providers is to enable access to further content of interest to the visitor on our website.

d) Duration of the storage

We do not store any data.

e) Right to objection and removal

You can decide for each embedded content whether you want to give the corresponding consent. Claims for objection or deletion must then be addressed to the data controller.

5. Newsletter dispatch

a) Scope of the data processing

If you purchase goods or services on our website and enter your e-mail address, we may subsequently use it to send you a newsletter. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter.

It is possible to subscribe to a free newsletter on our website or in our app, which contains direct advertising for our products or the products of our cooperation partners. When registering for the newsletter, the data from the input mask is transmitted to us or the e-mail address already stored is used. In this case, the date and time of registration for the newsletter and the IP address used will also be stored. As part of the confirmation of the newsletter registration, the date and time at which you click on the confirmation link for the newsletter registration and the IP address used are also stored. If you have consented to this, we use a web beacon to record the opening and clicking behaviour with regard to the respective newsletter in anonymised form when the newsletter is opened.

When the newsletter is sent, your e-mail address is passed on to the external service provider "CleverReach GmbH & Co. KG", which sends the newsletter on our behalf. No further use is made by the service provider. The service provider is based within the European Union.

b) Legal basis

The legal basis for the processing of data when sending newsletters due to the prior purchase of goods or services is Art. 6 para. 1 lit. f GDPR in conjunction with Section 7 para. 3 UWG.

The legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR therefore lies in direct advertising and increasing sales to existing customers.

The legal basis for the processing of data during direct registration and for the recording of opening and click behaviour for the newsletter for user optimisation is Art. 6 para. 1 lit a GDPR and Section 25 para. 1 TDDDG.

The legal basis for the transfer of data to the shipping service provider is Art. 28 para. 3 GDPR.

c) Purpose of the data processing

The purpose of storing the e-mail address is to enable electronic contact for advertising purposes. The date and IP address of the registration and the confirmation of the registration are recorded in order to document the consent to the newsletter dispatch in a verifiable manner and to exclude misuse.

The opening and click behaviour for the newsletter is recorded in order to improve our newsletter dispatch.

The data is passed on to the service provider for the purpose of sending the newsletter in bulk. The service provider does not have the right to use the data for its own purposes beyond this.

d) Duration of the storage

If we have received your e-mail address in connection with the purchase of goods or services, it will be deleted or blocked for the sending of advertising 18 months after the last purchase of goods or services or in the event of an objection.

If you have expressly consented to receiving the newsletter, we will only delete or block the e-mail address for sending advertising if you revoke your consent. The data used to confirm the newsletter subscription will be stored for the same period of time.

e) Right to objection and removal

You can object to the use of your e-mail address for advertising purposes or withdraw your consent at any time without incurring any costs over and above the charges for your communication tariff. You can object to the use of your e-mail address for advertising purposes with effect for the future by clicking on a link provided in each advertising mailing. You can also send an e-mail to: datenschutz(at)astragon.de to object to the use of advertising with effect for the future or to revoke your consent. In the event of an objection by e-mail, the cancellation or blocking may take up to 5 working days; advertising may still be sent during this period.

6. Use of our Discord server

a) Scope of the data processing

We operate a server with the Discord service of Discord Netherlands BV. This allows users to communicate with each other in writing or via voice chat and exchange content. Data processing by Discord takes place on the basis of the necessary contract with Discord itself. The scope and legal basis for processing by Discord can be found in their data protection information: https://discord.com/privacy

We ourselves do not have access to the Discord database and can only moderate the respective channels editorially and exclude users from using them.

b) Legal basis

The legal basis for the processing is the consent of the user in accordance with Art. 6 para. 1 lit. a GDPR. There is joint responsibility with Discord in accordance with Art. 26 GDPR.

c) Purpose of the data processing

The purpose is to exchange information about our game with the user and other players.

d) Duration of the storage

The storage period of posts is determined by Discord in its privacy policy.

e) Right to objection and removal

Users can delete their messages or their customer account on Discord themselves at any time or contact the contact point specified in Discord's privacy policy. If the deletion of posts is desired, you can contact us at datenschutz@astragon.de.

7. Content acquisition via Xsolla

a) Scope of the data processing

If you purchase content from us, payment will be processed through Xsolla (USA), Inc. (Xsolla), Arch. Makariou III, 155, Proteas House, 5th floor, 3026, Limassol, Cyprus. We receive from Xsolla the respective user ID, ID, currency and payment amount of the payment (purchaser data). The scope and legal basis for processing by Xsolla can be found in their data protection information: https://xsolla.com/privacypolicy?lang=en

b) Legal basis

The legal basis for processing is Art. 6 para. 1 lit. b GDPR, as we process the purchaser data in order to make the content purchased via Xsolla available to you. Xsolla is independently responsible for the processing.

c) Purpose of the data processing

The purpose is to reliably manage your claims to our purchased content.

d) Duration of the storage

The data is stored for as long as is necessary to provide our content. Insofar as these are commercial letters subject to retention under commercial and tax law, they are also stored for the statutory retention period.

e) Right to objection and removal

There is no possibility of objection or cancellation.

8. Social media presence

a) Scope of the data processing

We maintain publicly accessible profiles on various social networks. Your visit to these profiles triggers a variety of data processing operations. These data processing operations may be necessary for individual functionalities of our profiles in social networks. These functionalities are not available to the user or are only available to a limited extent if the user does not provide us with their personal data. When users visit our profiles, their personal data is not only collected, used and stored by us, but also by the operators of the respective social network. This happens even if the user does not have a profile in the respective social network. The individual data processing operations and their scope differ depending on the operator of the respective social network and are not necessarily traceable by us. The user can find details about the collection and storage of the user's personal data and about the type, scope and purpose of its use by the operator of the respective social network in the data protection declarations of the respective operator:

As the operator of a Facebook fan page, we can only view the information stored in your public Facebook profile, and only if you have such a profile and are logged into it when you visit our fan page. In addition, Facebook provides us with anonymous usage statistics that we use to improve the user experience when visiting our fan page. We do not have access to the usage data that Meta Platforms collects to compile these statistics. Meta Platforms has committed to us to assume primary responsibility under the GDPR for the processing of this data, to fulfil all obligations under the GDPR with regard to this data and to make the essentials of this obligation available to the data subjects.
We do not have access to the databases of the social media providers.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. a and f GDPR. This data processing serves our (and your) legitimate interest in enabling dialogue with you and other players about our game and improving the user experience when visiting the respective social media presence in line with the target group.
There is joint responsibility with the social media providers in accordance with Art. 26 GDPR.

c) Purpose of the data processing

The purpose is to exchange information with you and other players about our game and to improve the user experience when visiting our social media presences for specific target groups.

d) Duration of the storage

The storage duration of data processing operations on our social media presences is determined by the respective privacy policies of the social media providers.

e) Right to objection and removal

You can delete your messages or your customer account on the social media sites yourself at any time or contact the contact points specified in the privacy policies of the social media providers.

9. Google Analytics

a) Scope of the data processing

Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited
Gordon House, Barrow Street
Dublin 4, Ireland
Tel: +353 1 543 1000
Fax: +353 1 436 1001
- hereinafter referred to as "Google".
This software collects information about how you use the website and uses it to compile various statistics. The usage data collected includes, in particular, the specific selection of links, the time spent on individual pages and the order in which the website is used, and the frequency with which pages are accessed. This data is collected together with your IP address. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.
Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. We have activated so-called IP anonymisation on our website, i.e. the IP address is shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there. Google itself describes its data processing activities here http://tools.google.com/dlpage/gaoptout?hl=de

b) Legal basis

The legal basis for the processing of data when using the website is Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG. You give your consent when you enter the website or open the app in the form of confirmation in our tracking/cookie bar. The legal basis for the transfer of data to Google is Art. 26 para. 3, 6, Art. 46 para. 2 lit. c GDPR in conjunction with the use of the standard clauses of the EU Commission.

c) Purpose of the data processing

The processing serves the purpose of analysing this website and the usage behaviour of its visitors in order to improve our services.

d) Duration of the storage

The data is anonymised immediately after collection. Personal data is therefore only collected during transmission and is not stored permanently.

e) Right to objection and removal

You can prevent the storage of cookies, including the generation and transmission of data to Google, by restricting or prohibiting the setting of cookies in your browser software. This can be done via the browser itself or via our tracking/cookie bar. As a result, cookies not associated with Google may also be deactivated and not all functions of this website can be used to their full extent.

You can prevent the collection of the data generated by the cookie and related to your use (including your IP address) and its transmission to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link

https://tools.google.com/dlpage/gaoptout?hl=en

As an alternative to the browser plugin, you can click the following link: to prevent Google Analytics from collecting data on this website in the future. An opt-out cookie will be stored on your end device. If you delete your cookies, you must click the link again.

Your cookie consent


Date 27.09.2024