PRIVACY POLICY

Privacy Policy

The responsible party, regarding the General Data Protection Regulation (GDPR) and other national data protection laws as well as other data protection provisions is:

EuroVideo Medien GmbH

Sonnenstr. 21

80331 München

Tel. +49 (89) 96 24 44 - 0

Fax +49 (89) 96 24 44 – 35

E-Mail: info@eurovideo.de

The Data Protection Officer of EuroVideo GmbH is:

Ingo Wolff

tacticx GmbH

Walbecker Straße 53

47608 Geldern

Datenschutz-ev@EuroVideo.de

1. Mobile Apps

1.1. General Information on the Processing of Personal Data

We process personal data in compliance with the relevant data protection regulations of the GDPR. We will only process data where we are legally permitted to do so. When you use these apps, we will process personal data only with your consent (Art. 6 paragraph 1 sentence 1 lit. a GDPR), for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract (Art. 6 paragraph 1 sentence 1 lit. b GDPR), for compliance with a legal obligation (Art. 6 paragraph 1 sentence 1 lit. a GDPR) or if the processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data (Art. 6 paragraph 1 sentence 1 lit. f GDPR).

1.2 Duration of Storage

Unless otherwise stated in the following sections, we will store the data only as long as necessary to achieve the purpose of processing or to fulfill our contractual or statutory obligations.

2. Data processing while downloading or using the App

When downloading the app, no information is actively transferred by us to the app store involved (Apple App Store, Google Play, Amazon App Store, Samsung App Store, etc.). If you want to know what data is collected and processed by a given app store during the downloading process, please consult their privacy policy. We have no control over any data collection by app stores. They are solely responsible for the processing of any of your personal data within the meaning of Article 4(7) GDPR.

When using the App, the operating system of the device you are using will be processed by us. There will be no connection between this information and other personal data of the user. We are not able to identify you as a person.

The legal basis for this processing is Art. 6 paragraph 1 sentence 1 lit. b GDPR. The data provided will only be processed for the purposes stated in the terms of use and they will only be stored for the duration of use. You may terminate your use at any time by deactivating your user account.

3. Access Rights of this App

This app requires various access permissions from your device. These are required to maintain certain functionality of our apps. For example, if you only want to download updates using a wireless connection, the app needs access to your wireless connection. If you would like to purchase additional content via the app, we may need access to the interface required for your app store. Another example is what is referred to as “push notifications”, in which we can use an interface to display a message directly on your device. The access permissions on your mobile device are dependent on the operating system (e.g. Android, iOS, etc.) and the store where the app was purchased (e.g. Google Play Store, Apple App Store, Amazon, etc.). As a rule, you will receive information prior to the installation as to which access permissions are required by our app.

The legal basis for the processing of technically necessary access permissions is Art. 6 paragraph 1 sentence 1 lit. b GDPR. All further access permissions are based on Art. 6 paragraph 1 sentence 1 lit. f GDPR. Under “Settings” in Apple iOS, you can get an overview at any time of the content that our apps can access. You can restrict these access permissions at a later point in time. In Android, various access permissions are also needed on your mobile device. Under “Settings/Apps” you can subsequently check the access rights of our apps.

Android iOS Purpose

Internet connection Internet connection Download of the App and Updates

File system File system Create folders

Push-Notification Push-Notification Notifications

Contacts - Google Play needs this Access Right

4. Registration, Login and Payments

In order to use the app, no registration is required. The first time you start the App, you are asked to enter a username.

In the context of this use, only the username is processed. The legal basis for this processing is Art. 6 paragraph 1 sentence 1 lit. b GDPR. It is absolutely essential to provide the information marked as mandatory in order to establish the user relationship. The data provided will only be processed for the purposes stated in the terms of use and they will only be stored for the duration of use. You may terminate your use at any time by deactivating your user account.

In principle, you can enjoy our games without having to provide personal contact data. If you pay for chargeable activities in our games, your personal data will be collected by the corresponding payment service providers listed.

All payment-relevant data, such as your contact and payment data, are initially collected and processed by the corresponding payment provider. The legal basis for this data processing is Article 6(1)(b) GDPR.

For payments, we collect the geolocation of your IP address, which allows us to determine in which country you are located. The legal basis for this data collection is Art. 6 paragraph 1 sentence 1 lit. c GDPR, as the processing is necessary for compliance with a legal obligation. The legal obligation arises from Directive 2006/112/EC (MOSS Directive).

We also receive information from payment providers related to payment fraud prevention. The legal basis for this data collection is Art. 6 paragraph 1 sentence 1 lit. c GDPR, as the processing is necessary for compliance with a legal obligation.

5. Unity3D

In order to provide analytics for your games, Unity Analytics generates an anonymized user ID for each user in your game. We do not use any of these IDs generated from Apps to track users across apps built by other developers or to map users between different services, devices, or browsers on the same computer. In addition to these IDs, Unity Analytics also collects the following personal information from App users: IP address, identifiers for advertisers (IDFA is only collected if Unity Ads is also enabled) and device identifiers (IDFV, Android device ID or IMEI if Android device ID is unavailable).

Unity’s use of the personal information identified above is limited to providing app-level analytics for the application’s developer and analyzing and reporting anonymized and aggregate-level information about devices, apps and the game industry (for example, the percentage of devices using a certain operating system or the percentage of certain devices by regions). This aggregate-level data contains no personal information. Also, if you’ve enabled Unity Ads in an App, Unity may use information about a user collected by Unity Analytics from that App to serve contextual advertising within that App. https://docs.unity3d.com/Manual/UnityAnalyticsCOPPA.html

Please notice that Unity operates in several countries, so it is possible that the data mentioned above is located in non-EU area. We ensure the protection of your privacy and personal data in a recognized and appropriate way via contractual agreements (EU-standard contract, accessible here: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF

The processing of this data is necessary for the purposes of our legitimate interests of refinancing the App and is based on Art. 6 paragraph 1 sentence 1 lit. f GDPR. You can opt-out by clicking the info-button or data-privacy-button, next to any ad.

6. Facebook Analytics

We are using "Facebook Analytics for Apps", an analysis service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). Facebook Analytics for Apps makes it possible to analyse usage of the App for purposes of statistics and market research. Facebook Analytics for Apps collects data from persons who use the App. We receive these data in aggregated and anonymised form and provide the username to Facebook, which is generally stored by Facebook. The data collected with Facebook Analytics for Apps can be put into context with the username. Facebook is not able to identify individual persons with the provided data. The information generated by the use of Facebook Analytics for Apps regarding the usage of the app will be saved and processed by Facebook and we will inform the User about this accordingly, based on the knowledge available to us. Facebook can use these data with the user's Facebook account and also for its own advertising purposes in accordance with the data usage guidelines of Facebook. (https://www.facebook.com/about/privacy).

7. Adjust Tracking

We use the services of Adjust GmbH (Saarbrücker Str. 37a, 10405 Berlin, Germany, “Adjust”) to improve the service. This allows us to us to track and analyze which marketing channels or sources are producing the best results for directing users to download the Products and to help us understand how our users are using our app. For this purpose, Adjust processes mobile identifiers such as the IDFA, GAID or similar mobile identifiers. For more information on Adjust, see here: https://www.adjust.com/privacy-policy/ and here: https://www.adjust.com/gdpr/. To opt out of tracking by Adjust please use the following link, choose your platform and the Device ID: https://www.adjust.com/opt-out/. For further questions, regarding the opt-out, please contact: privacy@adjust.com or legal@adjust.com. The processing of this data is necessary for the purposes of our legitimate interests of refinancing the App and is based on Art. 6 paragraph 1 sentence 1 lit. f GDPR.

8. Safety

EuroVideo Medien GmbH uses technical and organizational security measures to protect users' personal data against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. Our security measures are continuously improved in line with technological developments.

9. Automated individual person-related decisions or profiling

We do not process data for the purpose of making automated individual person-related decisions or profiling.

10. Rights of data subjects

If EuroVideo processes your personal data, you are the data subject according to Art. 4 No. 1 GDPR with the following rights towards EuroVideo:

10.1. Right of access

According to Art. 15 GDPR, you have the right to request information as to whether or not, and to what extent, we process personal data about you. You have the right to have us correct your data in accordance with Article 16 GDPR, if they are not correct. You have the right to have us delete or restrict your personal data, as well as the right to object the processing of your data in accordance with Article 17, 18 and 21 GDPR.

10.2. Complaints to Government Authorities

Notwithstanding any other right, if you believe that the processing of your personal data constitutes an infringement of the provisions of the GDPR, you have the right to lodge a complaint with a supervisory authority in accordance with Article 77 GDPR.

10. State of the data protection declaration

The current data protection declaration can be accessed at any time during the following link: https://ghost-tappers.com/ghosttappers_privacy.html

As of: October 2018