Oddsparks: An Automation Adventure

Privacy Policy

The protection of the personal data of the players of “Oddsparks: An Automation Adventure” (hereinafter referred to as “Oddsparks”), published by www.handy-games.com GmbH, i_Park Klingholz 13,97232 Giebelstadt (hereinafter referred to as “HandyGames”) is an important concern for HandyGames. For us, protecting your privacy is an essential basis for trusting information sharing and mutually open communication and collaboration. We therefore take the protection of your personal data very seriously.

Please find below information about the processing of your personal data when you participate as a player in the game “Oddsparks” (published by HandyGames and developed by Massive Miniteam GmbH).

1. Controller

(1) Due to Art. 4 Clause 7 General Data Protection Regulation (hereinafter referred to as “GDPR”), the controller is

www.handy-games.com GmbH

i_Park Klingholz 13

97232 Giebelstadt

Phone: +49 (0) 9334 9757 – 0

Fax: +49 (0) 9334 9757 – 19

E-Mail: info@handy-games.com

represented by the managing directors Markus Kassulke and Christopher Kassulke, who can be reached there

- hereinafter referred to as “HandyGames” -

as well as

Massive Miniteam GmbH

Atelier 55 im WALZWERK

Rommerskirchener Straße 21

50259 Pulheim

Phone: +49 176 47394019

E-Mail: contact@massiveminiteam.com

represented by the managing director Tim Schroeder

- hereinafter referred to as “Massive Miniteam” -

The aforementioned companies act as joint controllers within the meaning of Article 26 paragraph 1 sentence GDPR. The following Privacy Policy refers to joint data processing.

(2) You have the option of contacting our Data Protection Officer at any time regarding the topics of data protection and data security through HandyGames:

Thorsten Krietsch

Data Protection Officer (TÜV Germany)

Carstennstraße 47

12205 Berlin

E-Mail: mail@thorsten-krietsch.de

Phone.: + (0)30 47 03 32 15

Mobile: + (0)151 22 08 88 55

Fax: +49 (0)30 50 17 56 50

Website: https://www.tedeka-consulting.com

2. Data processing, processing purposes and legal bases

Below we will introduce you to all data processing processes when using “Oddsparks”, explain the exclusive processing purposes and the legal basis for the respective processing.

2.1 Participation in the game “Oddsparks”

(1) When you participate in the game, data about you is processed by those jointly responsible in separate areas.

(2) Concerning the joint controllership a contract (due to Art. 26 Clause 1 GDPR) can be proven upon first request.

A contract on shared responsibility within the meaning of Article 26 Paragraph 1 Sentence 1 GDPR can be proven at any time upon first request.

(3) However, we would like to point out that when you use the “Oddsparks” game, additional data may be collected about you; namely:

2.1.1 tools used and data processing through them

(1) Azure PlayFab

Azure PlayFab (hereinafter referred to as „PlayFab“) is a service provided by Microsoft Corporation, 1 Microsoft Way, Redmond, Washington 98052-8300

The purpose of the service is to provide and analyze live games so that the developer can permanently optimize the game and performance. For this purpose, the following data is processed by the game developer:

Steam User IDs and names

IP-Address (anonymized)

(2) Sentry.io

Sentry.io (hereinafter referred to as „Sentry“) is a service by Functional Software Inc., 45 Fremont Street, 8th Floor, San Francisco, California 94105.

The purpose of the service is to find out the underlying reasons in the event of a game crash (“crash”) and to optimize the game. For this purpose, the following data is processed by the service provider in the event of a crash:

Account IDs
IP-Addresses
Hardware-Configuration (Architecture, RAM, CPU, OS Name and Version, Device Name)
Steam User IDs & names

This data is only processed in the event of a crash and with the express consent of the user. For this purpose, the user is asked in each individual case to allow the crash report to be sent and processed.

(3) Epic Online Services

Epic Online Services is a service der Epic Games, Inc., 620 Crossroads Blvd., Cary, NC USA.

The purpose of the service is to enable multiplayer games across different platforms (“cross platform gaming”). This gives the user more options.

The data processed for this is:

Account IDs
IP-Addresses

Further data is only processed if the user actively uses corresponding services, such as voice chat, for which he gives his express consent by using the respective service.

2.1.2 Processing purposes

Data processing takes place exclusively for the purposes stated under 2.1.1. No data processing beyond this takes place.

2.1.3 Legal basis

The legal basis for data processing is Article 6 clause 1 sentence 1 lit a) (the consent of the data subject), Article 6 clause 1 sentence 1 lit b) (performance of the contract) and Article 6 clause 1 sentence 1 lit f) (the legitimate interest of the developer as well of the publisher). The legitimate interest lies exclusively in the optimization and marketing of the game.

2.1.4 Duration of processing

With both tools mentioned above, the data is processed for as long as necessary for the purposes of the processing. This is a maximum of 3 years.

2.1.5 Third Party transfer

(1) Your data will be transfered on by HandyGames primarily to the contractual partner Massive Miniteam and to third parties necessary for the fulfillment of the contract.

(2) A transfer to unsafe third countries will only be permitted if they are covered by the standard contractual clauses in accordance with Art. 46 Para. 2 lit. c) GDPR or other sufficient guarantees.

2.1.6 automated decision making, including profiling

Automated decision-making, including profiling, does not take place.

3. Transfer of personal data to an international organization

A transfer to third countries or international organizations is not announced and is not actively pursued by those responsible.

4. Rights of data subject

4.1 Right of access by the data subject

You have the right to receive confirmation from us, free of charge, as to whether we are processing personal data relating to you. If this is the case, you have the right to information about this personal data and further information, which you can find in Art. 15 GDPR. We will provide you with a copy of the personal data processed about you, as long as this does not affect the rights and freedoms of third parties.

4.2 Right to rectification

You have the right to request that we immediately correct any incorrect personal data concerning you. You also have the right - taking into account the above-mentioned purposes of processing - to request the completion of incomplete personal data, including by means of a supplementary statement.

4.3. Right to erasure ('right to be forgotten')

You have the right to request the erasure of your data if the conditions set out in Article 17 Para. 1 GDPR are met. This right exists in particular if the data is no longer required for the purpose of processing (loss of purpose), you revoke the consent on which the data processing is based in accordance with Article 7 Paragraph 3 GDPR, or you object to data processing in accordance with Article 21 Paragraph 1 GDPR have lodged an objection or our data processing is not lawful.

4.4 Right to object

In the event that we process your personal data based on Article 6 Paragraph 1 Sentence 1 Letter f of the GDPR (because of our legitimate interest), you shall have the right 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 points (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

4.5 Right to withdraw ones consent

You can revoke your consent to the processing of your personal data at any time with future effect without giving reasons. The lawfulness of processing based on past consent remains unaffected.

4.6 Right to restriction of processing

You have the right to request that we restrict processing if one of the requirements of Article 18 GDPR is met.

4.7 Right to data portability

You have the right to receive the personal data relating to you in a structured, commonly used and machine-readable format. You must be able to transmit this data to another person responsible without hindrance from us if the requirements of Art. 20 Para. 1 GDPR are met.

4.8 How to exercise your rights

To exercise your rights, you can contact us by post, fax or email using, among other things, the contact details listed in section 1 of this Privacy Policy. If there are serious doubts about your identity, we reserve the right to request proof of identity from you.

5. Right to lodge a complaint with a supervisory authority

(1) Without prejudice to any other rights, you have the right to lodge a complaint with a data protection supervisory authority at any time, in particular in the member state of your place of residence, your place of work or the place of the alleged violation, if you are of the opinion that the processing of your personal data by us is contrary to violates data protection law.

(2) The supervisory authority responsible for us is:

Das Bayerisches Landesamt für Datenschutzaufsicht

House address:

Promenade 18

91522 Ansbach

Deutschland

Postal address:

Postfach 1349

91504 Ansbach

6. Necessity of providing your personal data

(1) The provision of your personal data, as described in sections 2.1.1 (1), 2.1.1 (2) and 2.1.1 (3) of this Privacy Policy, is neither contractually nor legally binding.

This does not apply if it is necessary for one of the parties to fulfill the contract.

Version: 2023/11/29