1. AN OVERVIEW ON DATA PROTECTION
1.1 General Information
1.2 Data Recording on this Website
Who is the responsible party for the recording of data on this website (i.e. the „controller “)?
As the operator of this website, we are responsible for data processing on this website. You will find our contact details under “General and Mandatory Information” and on the imprint of our website.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance, be information you enter into our contact form.
Our IT systems automatically record other data when you visit our website. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. Please do not hesitate to contact us at any time under the address disclosed on the imprint of this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when you visit this website.
Such analyses are performed primarily with cookies and with what we refer to as analysis programs. As a rule, the analyses of your browsing patterns are conducted anonymously; i.e. the browsing patterns cannot be traced back to you.
You have the option to object to such analyses or you can prevent their performance by not using certain tools.
2. GENERAL AND MANDATORY INFORMATION
2.1. Data Protection
We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.
2.2. Information about the responsible party
The responsible party (referred to as the „controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).
The controller according to data protection laws is:
Kolibri Games GmbH
Hallesches Ufer 60
If you have any questions or suggestions about data protection, you can send us an email to email@example.com
Our data protection officer can be reached at the following address:
Dominik Fünkner, Leopoldstr. 21, 80802 München, www.datenschutzexperte.de
This website is hosted by an external service provider: https://www.a2hosting.com/. Personal data collected on this website are stored on the servers of A2 Hosting. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.
A2 Hosting is used for the purpose of fulfilling the contract with our potential and existing customers (Article 6 para. 1 lit. b DSGVO) and in the interest of secure, fast and efficient provision of our online services by a professional provider (Article 6 para. 1 lit. f DSGVO).
Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
4. COLLECTION AND USE OF YOUR DATA
4.1 Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
We store so-called cookies in order to offer you a comprehensive range of features and to make our websites more convenient to use. Cookies are small files that your web browser stores on your computer. If you do not want any cookies used, you can prevent cookies being stored on your computer by adjusting the settings of your web browser. Please note that by doing so, you might reduce the functionality of our site.
Specifically, we use the following cookies:
- Borlabs Cookie (own cookie)
- ARRAffinity (Azure)
- Google Tag Manager
- Google Analytics
- Facebook Feed
4.3. Request by e-mail or telephone
If you contact us by e-mail or telephone, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out precontractual measures. In all other cases, the processing is based on your consent (Article 6 (1) a GDPR) and/or on our legitimate interests (Article 6 (1) (f) GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions in particular statutory retention periods remain unaffected.
5. ANALYSIS TOOLS AND ADVERTISING
5.1. Google Analytics
We use Google Analytics, a web analytics service provided by Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses so-called cookies, text files that are stored on your device and allow us to analyze how you use our website. The information that the cookie generates about your use of this website (including your abbreviated IP address) is transmitted to a Google server in the United States and stored there.
Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to the use of our website and internet usage. Google might also transfer this information to third parties if required by law or insofar as third parties process this data on Google’s behalf.
We are entitled to use Google Analytics because we have a legitimate interest in customized design and in performing a statistical analysis of our website, and due to the fact that your legitimate interests do not prevail under Article 6 section 1 (f) GDPR. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.
You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option to prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: HTTP://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT.
Objection to the recording of data
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation. (https://tools.google.com/dlpage/gaoptout)
For more information about how Google uses your information, see Google’s Privacy Declaration: https://support.google.com/analytics/answer/6004245?hl=en.
Demographic parameters provided by Google Analytics
This website uses the function „demographic parameters” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender and interests of website visitors. The sources of this information are interest related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section „Objection to the recording of data.”
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en
This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe (Website: https://www.hotjar.com).
Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.
We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so called conversion funnels).
Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.
You can set up your browser in such a manner that you will be notified anytime cookies are placed and you can permit cookies only in certain cases or exclude the acceptance of cookies in certain instances or in general and you can also activate the automatic deletion of cookies upon closing of the browser. If you deactivate cookies, the functions of this website may be limited.
The use of Hotjar and the storage of the Hotjar cookies are based on Article 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Article 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
Deactivation of Hotjar
If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/opt-out.
Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.
For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy.
6. PLUG-INS AND TOOLS
This website embeds videos of the website YouTube. The website operator is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
If you visit a page on this website into which a YouTube has been embedded, a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified about which of our pages you have visited.
Furthermore, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud. These cookies will stay on your device until you delete them.
If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Article 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Article 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
6.2. Google Web Fonts
To ensure that fonts used on this website are uniform, this website uses so called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts.
To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. The use of Google Web Fonts is based on our interest in presenting our online content in a uniform and appealing way. According to Article 6 Sect. 1 lit. f GDPR, this is a legitimate interest.
If your browser should not support Web Fonts, a standard font installed on your computer will be used. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
6.3 Google reCAPTCHA
We use „Google reCAPTCHA” (hereinafter referred to as „reCAPTCHA“) on this website. The provider is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data entered on this website (e.g. information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g. IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.
The data is processed on the basis of Art. 6 Sect. 1 lit. f GDPR. It is in the website operator’s legitimate interest, to protect the operator’s web content against misuse by automated industrial espionage systems and against SPAM.
7. CHANGE OF PURPOSE
Your personal data might be used for purposes other than those described, but only if the law allows it, or if you have consented to a change in the purpose of processing your data. If your data is subsequently processed for purposes other than those for which it was originally collected, we will tell you what these other purposes are before further processing occurs and provide you with all other relevant information.
8. AUTOMATED INDIVIDUAL DECISIONS OR PROFILING MEASURES
We do not use automated processing to make decisions, and we do not profile.
9. DISCLOSURE OF DATA
As a matter of principle, your personal data will not be disclosed to others without your express prior consent, except in the following circumstances:
- To provide our services, we outsource work to outside companies under contract and to service providers (“processors”). In such cases, personal data will be transferred to such processors for processing. These processors are carefully selected and regularly reviewed by us to ensure your privacy. Processors may only use data for the purposes specified by us. Moreover, processors are contractually bound to process your data only in accordance with this data protection policy and with German data protection laws.Transfer of data to processors is based on Article 28 section 1 GDPR. In subsidiary manner transfer can be warranted on grounds of our legitimate interest in the economic and technical benefits of using specialized processors, and due to the fact that your rights and interests in protecting your personal data do not prevail under Article 6 section 1 (f) GDPR.
- We also process data in countries outside the European Economic Area (“EEA”).For the US, the European Commission resolved by decision of July 12, 2016 that under the rules for the EU-U.S. Privacy Shield an adequate degree of data protection exists (adequacy decision, Article 45 GDPR). Additional information – including information about certification of our service providers – is available at HTTPS://WWW.PRIVACYSHIELD.GOV.
10. DELETION OF YOUR DATA
We will delete or anonymize your personal information as soon as it is no longer needed for the purposes for which we collected or used it in accordance with the preceding paragraphs, unless the data must be kept longer for legal reasons, for criminal prosecution or to secure, assert or enforce legal claims.
If data must be kept for legal reasons, they are blocked. In that case they are no longer available for further use.
11. YOUR RIGHTS AS A DATA SUBJECT
11.1 Right to Information
You are entitled at any time upon request, to obtain information from us about your personal data within the scope of Article 15 GDPR. To request such information, you may submit an application by mail or by e-mail to the address given above.
11.2 Right to correct inaccurate data
You are entitled to demand that we correct forthwith any inaccurate personal data concerning you. For this purpose, please get in touch with the contact addresses listed above.
11.3 Right to deletion
11.4 Right to restriction of processing
You are entitled to demand that we restrict processing in accordance with Article 18 GDPR. This right applies especially if we are not in agreement with the user concerning the accuracy of any personal data. The right persists for the time required to verify its accuracy. In addition such right applies in the following cases: if the user is entitled to demand deletion but instead demands restricted processing; if the data is no longer required for the purposes we are pursuing, but the user needs them in order to assert, exercise or defend legal claims; and if an objection has been raised but its successful exercise is still disputed between us and the user. To assert aforesaid right, please get in touch with the contact addresses listed above.
11.5 Right to data transferability
You are entitled to demand from us whatever personal information you may have given us. Pursuant to Article 20 GDPR, at your request we must provide you with such information in a structured, commonly used and machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible. To assert aforesaid right, please get in touch with the contact addresses listed above.
11.6 SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from „http://“ to „https://“ and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
11.7 Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
Pursuant to Article 21 GDPR you are entitled at any time to object to the processing of your personal data on grounds related to your particular situation, including grounds under Article 6 section 1 (e) or (f) GDPR. We will cease processing your personal information unless we can demonstrate compelling and legitimate grounds for processing that outweigh your interests, rights and freedoms, or unless the processing is done for the purpose of enforcing, pursuing or defending legal claims.If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Article 21 section 2 GDPR).
You are entitled to make a complaint to the pertinent oversight body. The oversight body in charge is:
Berlin Commissioner for Data Protection and Freedom of Information
12. CHANGES TO THIS DATA PROTECTION POLICY
Updated to: November 04th, 2019