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Legal Notice

Published by:

Ravensburger AG
Robert-Bosch-Str. 1
88214 Ravensburg

E-Mail: [email protected]

Authorized representatives:
Clemens Maier (chief executive officer)
Filip Francke
Susanne Knoche
Hanspeter Mürle

Chairman of the supervisory board:
Dr. Thomas Vollmoeller

Registry court / Register number:
Amtsgericht Ulm / HRB 551302

VAT identification number:
DE154720975

Data protection declaration

As of: May 2018

§ 1 Information on the collection of personal data

(1) In the following, you will find information on the collection of personal data during use of our mobile app. Personal data is all data that can be linked to you personally, e.g. name, address, email address, user behavior.

(2) Responsible pursuant to Art. 4 Section 7 of the EU General Data Protection Regulation (GDPR) is the Ravensburger AG (please see the legal notice for our contact address). Should you have questions, comments, or criticism about data protection, or if you wish to assert your rights described below, please contact us at [email protected]. You can contact our data protection officer at [email protected] or using our postal address with the addition “The data protection officer.”

(3) If you contact us by email or using a contact form, we save the data you give us (your email address, if applicable your name, and your phone number) so that we can answer your questions. We erase the data collected in this context when it is no longer necessary to save it, or limit its processing if statutory data storage regulations apply.

(4) If we use service providers for individual functions of our offer, or if we wish to use your data for advertising purposes, we will inform you in detail below about the processes involved here. We also inform you below about the storage duration criteria that apply. We also inform you below about the storage duration criteria that apply.

§ 2 Your rights

(1) You have the following rights in relation to your personal data:

    – Right to request,
    – Right to rectification or erasure,
    – Right to restriction of processing,
    – Right to object to processing,
    – Right to data portability.

(2) Furthermore, you have the right to complain to a data protection supervisory authority about our processing of your personal data.

§ 3 Download and subsequent offline use of our mobile app

(1) Download from the app store

When you download the app, the required information is transferred to the app store, in particular the login data of your account, if applicable payment information, individual device ID and information about your download (e.g. time of the download). We have no influence on this data collection and are not responsible for it. We only process the data in as far as it is necessary for downloading the mobile app to your mobile terminal device. It is not saved beyond this extent. The legal basis is Art. 6 Section 1 p. 1 lit. b of the GDPR.

(2) Subsequent (offline) use

The app is downloaded to your mobile terminal device and can generally be used without internet access, possibly with a restricted range of functions. No personal data is collected during offline use.

§ 4 Special functions and use in online mode

(1) If you use the app in online mode, i.e. when connected to the internet, or you use special functions, additional data processing may take place. We explain this in more detail below.

(2) In some cases, we use external service providers to process your data. We select these service providers carefully and commit them to observe our instructions. We regularly check their compliance.

(3) If our service provider or partner is based in a country outside the European Economic Area (EEA), we inform you below about the consequences of this.

(4) Specifically:
a. Storage of user, payment, and game data (Ravensburger)

In order to be able to provide you with the game functions, we store user information (the user ID), information about purchasing processes (in-game currencies and assets acquired) and information on the current score (especially the game progress) on our servers. The legal basis for this processing is Art. 6 Section 1 p. 1 lit. b GDPR. Furthermore, we evaluate information about your purchasing processes for accounting and product optimization purposes. This evaluation is not linked to you personally. The legal basis for this processing is Art. 6 Section 1 p. 1 lit. f GDPR.

We do not receive any notification if you uninstall the app. Furthermore, we want to allow you to opt back into the game later (including re-access to your in-game currencies and assets). For these reasons, we routinely save your ID with the associated payment and game data for an unlimited time. We treat your data confidentially and erase it if you revoke the rights to its use or if we remove the app from our range and no statutory storage regulations apply. The legal basis for processing is Art. 6 Section 1 p. 1 lit. f GDPR.

b. Recommendations for similar apps (Ravensburger)

If you use the app in online mode, the app communicates with our server using a tool programmed by us. We use this tool for marketing purposes, i.e. to send recommendations for other apps to your device which are displayed while you use the app (e.g. via the buttons “More” or “News” available in the main menu; in rare cases also in the form of pop-ups). These recommendations are not personalized, but compiled based on the app you use. The app sends the following information to our server: the app in which the tool was opened, the type of device (e.g. iPad, iPhone) the app is installed on, as well as which country and language are set on the device. No third party is involved in this communication process. In this context, logfiles are saved to our server, however they are saved without any IP address or specific device ID and therefore anonymously. The legal basis for processing is Art. 6 Section 1 p. 1 lit. f GDPR.

c. Use of social gaming functions (Apple, Google, Amazon, Facebook)

Our app offers you the option of using social gaming functions. If you wish to do so, you must log in to the specific social gaming network with your account. As soon as you have done this, the app will provide additional functions such as successes, winner lists, and multiplayer games. It will also access personal data (within a restricted profile) from the social gaming network (e.g. your alias, profile picture, friends who use the app). You may be asked to grant separate permission for access to this data. As soon as you log out of the social gaming network, we have no further access to the restricted profile mentioned above. The additional functionality is then also no longer available. The legal basis for processing is Art. 6 Section 1 p. 1 lit. b GDPR.

Furthermore, we may link the ID of your social gaming account to your user ID (details on this are described in § 4 Section 4 lit. a) in order to enable you to use this app across installations and if appropriate also across platforms. We do not use the data provided by social gaming platform operators for other purposes. The legal basis for processing is Art. 6 Section 1 p. 1 lit. b GDPR.

As we do not receive any notification if you uninstall the app, we routinely store the ID of your social gaming account for an unlimited time. If, after reinstalling the app, you use the same login to authenticate yourself in the same social gaming network, you can once again access your data linked to your social network ID. We treat your data confidentially and erase it if you revoke the rights to its use or if we remove the app from our range and no statutory storage regulations apply. The legal basis for processing is Art. 6 Section 1 p. 1 lit. f GDPR.

Information about third-party suppliers:

Apple Game Center: Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA. Data protection information: https://www.apple.com/legal/privacy/; conditions of use for Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/.

Google Play Games: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data protection information: https://policies.google.com/privacy; conditions of use for Google Play: https://play.google.com/intl/de-DE_de/about/play-terms.html; Google complies with the EU-US Privacy Shield. For more details go to: https://www.privacyshield.gov/EU-US-Framework.

Amazon GameCircle: Amazon.com, Inc., PO Box 81226, Seattle, WA 98108-1226, USA. Data protection information: https://www.amazon.com/gp/help/customer/display.html?nodeId=468496; conditions of use for Amazon GameCircle: https://www.amazon.com/gp/help/customer/display.html?nodeId=201487670; Amazon complies with the EU-US Privacy Shield. For more details go to: https://www.privacyshield.gov/EU-US-Framework.

Facebook: Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA. Data protection information: http://www.facebook.com/policy.php; further information on data collection: https://www.facebook.com/help/1642635852727373/; Facebook complies with the EU-US Privacy Shield. For more details go to: https://www.privacyshield.gov/EU-US-Framework.

d. Use of in-app purchases (Apple, Google, Amazon, Facebook)

This app offers you the option of in-app purchases. To use this option, you need further communication with the platform provider, and therefore a connection to the internet. The provider sends us information about the course of the payment (e.g. cancellation, completion), and if the purchase is completed also the invoice information (e.g. article, price). We link this information about your purchasing activities to your user ID and store it partly on our servers (details are described in § 4 Section 4 lit. a). We do not receive information on means of payment (e.g. credit card data) because payments are made directly between you and the platform provider. We do not use the data transferred by your platform provider for any other purpose. The legal basis for processing is Art. 6 Section 1 p. 1 lit. b GDPR.

We do not receive any notification if you uninstall the app. Furthermore, we want to allow you to opt back into the game later (including re-access to your in-game currencies and assets). For these reasons, we routinely save the information about your purchases for an unlimited time. We treat your data confidentially and erase it if you revoke the rights to its use or if we remove the app from our range and no statutory storage regulations apply. The legal basis for processing is Art. 6 Section 1 p. 1 lit. f GDPR.

Information about third-party suppliers:

Apple App Store: Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA. Data protection information: https://www.apple.com/legal/privacy/

Google Play: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data protection information: https://policies.google.com/privacy; Google complies with the EU-US Privacy Shield. For more details, go to: https://www.privacyshield.gov/EU-US-Framework.

Amazon Appstore: Amazon.com, Inc., PO Box 81226, Seattle, WA 98108-1226, USA. Data protection information: https://www.amazon.com/gp/help/customer/display.html?nodeId=468496; Amazon complies with the EU-US Privacy Shield. For more details, go to: https://www.privacyshield.gov/EU-US-Framework.

Facebook Game Payments: Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA. Data protection information: http://www.facebook.com/policy.php; Facebook complies with the EU-US Privacy Shield. For more details, go to: https://www.privacyshield.gov/EU-US-Framework.

e. Using push messages (Apple, Google, Amazon)

For communication purposes, we use push messages in our app. We use the messaging service of the specific platform to implement this. To enable this, we ask you to give your permission in a popup the first time you use this functionality.

If you give your permission, we will from time to time send you information about new features, changes, and special events and activities connected with the app and the further Ravensburger portfolio. If you do not give your permission, you will not receive any messages from us. At a later date, you can retroactively grant or retract permission both in the Options menu of the app and in the operating system settings of your device.

In order to be able to address you properly in this communication, we receive a device and app-specific push messaging ID from the platform operator, which we link to your user ID for technical implementation of the communication (details are described in § 4 Section 4 lit. a). We do not use your data transferred by the platform provider for any other purposes. We treat your data confidentially and erase it if you revoke the rights to its use or if we remove the app from our range and no statutory storage regulations apply. The legal basis for processing is Art. 6 Section 1 p. 1 lit. a GDPR.

f. Analyzing user behavior (Countly Analytics)

For marketing and optimization purposes, we use the Countly Analytics software solution in our app. For this reason, the app is integrated in the relevant Countly SDK. When you are online, we collect the following data in pseudonymous form and store it on our servers:

    • Device/app-specific information: hardware (make, model, resolution), operating system     (vendor, version), app (version, errors)

    • Use-specific information: installation, configuration (country, language), use (distribution/     duration/ frequency/ return rate/ gaming decisions), monetarization (distribution/ type/     frequency/ conversion rate)

We can use the data collected with the aid of this tool to create user profiles in pseudonymous form. We exclusively process these internally for the above purposes and do not pass them on to third parties. Without your separately granted permission, this profile is not used to personally identify you and it is not linked to your personal data. You can at any time disallow data collection and storage for the future. The legal basis for the data processing is Art. 6, Section 1 p. 1 lit. f GDPR.

g. Recording user behavior (Facebook Analytics)

For marketing and optimization purposes, we use Facebook Analytics in our app. For this reason, the app is integrated in the Facebook Software Development Kit (SDK) provided by Facebook. When you are online, our app sends the following data in pseudonymous form to Facebook:

    • Device/app-specific information: hardware (make, model, resolution), operating system     (vendor, version), app (version, errors)

    • Use-specific information: installation, configuration (country, language), use (distribution/     duration/ frequency/ return rate/ gaming decisions), monetarization (distribution/ type/     frequency/ conversion rate)

We can use the data collected with the aid of this tool to create user profiles in pseudonymous form. The advertising ID provided by the terminal device’s operating system is used as the pseudonym (depending on the operating system, the name can vary). However, our app does not use the advertising ID to optimize advertising; it is discarded by Facebook. This is because our app prohibits Facebook from using the advertising ID for optimized advertising purposes. Therefore, the individual user can not be precisely determined at any time. You can at any time disallow data collection and storage for the future. The legal basis for the data processing is Art. 6, Section 1 p. 1 lit. f GDPR.

Information about the third party provider:

Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA. Data protection information: http://www.facebook.com/policy.php; Facebook complies with the EU-US Privacy Shield. For more details, go to: https://www.privacyshield.gov/EU-US-Framework.

h. Access to the camera

The first time you use the corresponding functionality in our app, a popup asks you for permission to use your camera. If you do not give permission, we do not receive access to your camera. In this case, you may not be able to use all the functions of our app. At a later date, you can retrospectively grant or revoke permission in your device’s operating system settings.
If you permit access to your camera, the app only accesses it to the extent necessary for providing the functionality. We treat your data with strict confidentiality. As soon as you revoke permission for use, the app can no longer access your camera. In this case, the additional functionality is no longer available.

The legal basis for processing is Art. 6 Section 1 p. 1 lit. a GDPR.

Safety information: Especially in the case of camera-based applications it may present a risk when you use the app during driving, walking or in other situations where you can be distracted from or misinterpret events in the real world.

i. Access to the microphone

The first time you use the corresponding functionality in our app, a popup asks you for permission to use your microphone. If you do not give permission, we do not receive access to your microphone. In this case, you may not be able to use all the functions of our app. At a later date, you can retrospectively grant or revoke permission in your device’s operating system settings.

If you permit access to your microphone, the app only accesses it to the extent necessary for providing the functionality. We treat your data with strict confidentiality. As soon as you revoke permission for use, the app can no longer access your microphone. In this case, the additional functionality is no longer available.

The legal basis for processing is Art. 6 Section 1 p. 1 lit. a GDPR.

j. Access to the photo library

The first time you use the corresponding functionality in our app, a popup asks you for permission to access your photo library. If you do not give permission, we do not receive access to your photos. In this case, you may not be able to use all the functions of our app. At a later date, you can retrospectively grant or revoke permission in your device’s operating system settings.

If you permit access to your photo library, the app only accesses your data to the extent necessary for providing the functionality. We treat your data with strict confidentiality. As soon as you revoke permission for use, the app can no longer access your photo library. In this case, the additional functionality is no longer available.

The legal basis for processing is Art. 6 Section 1 p. 1 lit. a GDPR.

k. Access to your music library

The first time you use the corresponding functionality in our app, a popup asks you for permission to access your music library. If you do not give permission, we do not receive access to your music. In this case, you may not be able to use all the functions of our app. At a later date, you can retrospectively grant or revoke permission in your device’s operating system settings.

If you permit access to your music library, the app only accesses your data to the extent necessary for providing the functionality. We treat your data with strict confidentiality. As soon as you revoke permission for use, the app can no longer access your music library. In this case, the additional functionality is no longer available.

The legal basis for processing is Art. 6 Section 1 p. 1 lit. a GDPR.

l. Integration of Vuforia

In order to implement visual recognition (image, markers, and objects), visual tracking, and mixed or augmented reality functions, the Vuforia SDK of third-party supplier PTC Inc. (in the following: PTC) is integrated in the app. Furthermore, in order to provide its functions, the Vuforia SDK requires access to your device’s camera (details on this are described in § 4 Section 4 lit. h).

While you use the app, certain information is saved and used by PTC as well as companies associated with PTC and their service providers. When you are online (although only while the Vuforia process is running in the app), the Vuforia SDK sends the following data to PTC in pseudonymous form (for details on the data logged, go to https://developer.vuforia.com/legal/statistics):

    • Device/app-specific information: hardware (e.g. make, model, resolution), operating system     (e.g. vendor, version), app (e.g. ID, version), Vuforia SDK (e.g. version, errors)

    • Use-specific information: configuration (country, language), localization (your IP address for     the purpose of country or regional localization, but not determination of your concrete     location), use of Vuforia (start, end, duration, frequency of camera use and recognition     processes)

At any time, you can prevent the data collection and saving with effect for the future by revoking the rights to use of the camera (in the operating system settings of your device). Then the Vuforia SDK is no longer used, and you no longer have access to the additional functionality. The legal basis for the data processing is Art. 6, Section 1 p. 1 lit. b GDPR.

PTC, companies associated with PTC, and PTC‘s service providers use the information described above to (a) offer the software and services, (b) enable provision of new products, updates, extras, and other services, (c) offer software, services, and other products. We do not have any influence over the collection and use of the statistics data by the third-party supplier PTC described above. The legal basis for the data processing is Art. 6, Section 1 p. 1 lit. f GDPR.

Information about third-party suppliers:

PTC Inc., 140 Kendrick Street, Needham, MA 02494, USA. Data protection information: https://www.ptc.com/en/documents/policies/privacy; conditions of use of Vuforia: https://developer.vuforia.com/legal/tos.

m. Integration of Everyplay

In order to enable you to record your own and view other players’ gameplay replays (recordings of past game situations), Everyplay SDK as well as the Everyplay overlay (for display of the Everyplay platform) from the third-party supplier Unity Technologies (in the following: Unity) are integrated in the app. In order to be able to provide certain optional features of its functionality, (enhancement of your own recordings with audio and video commentaries), the Everyplay SDK requires access to your device’s camera (details of this are described in § 4 Section 4 lit. h) and microphone (details of this are described in § 4 Section 4 lit. i).

It is possible to view third-party content without an Everyplay account using either the Everyplay menu integrated in the app, or the Everyplay platform (https://everyplay.com/). You can record your own gameplay replays by recording the video and audio output of your device. This data is only stored temporarily on your device, not permanently. You can either erase this data (then the video and audio material is immediately deleted) or upload it to the Everyplay platform. For uploading, you need your own Everyplay account, which is generated via the Everyplay SDK. This can be done completely anonymously without entering personal data, or you can choose to personalize your account. However, personalization is not necessary for provision of the app functionality.

The content you upload is saved and processed within the Everyplay platform on the Unity servers. We have no direct influence on their implementation. You can revoke permission to save and process data at any time with effect for the future. To do this, use the integrated Everyplay menu to delete either individual gameplay replays or your entire Everyplay account. The legal basis for the data processing is Art. 6, Section 1 p. 1 lit. a, f GDPR.

Information about third-party suppliers:

Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA. Data protection information: https://unity3d.com/de/legal/privacy-policy; conditions of use for Everyplay: https://everyplay.com/terms-of-service.

§ 5 Objection or revocation of the processing of your data 

(1) If you have issued your consent to the processing of your data, you can withdraw this consent at any time. Once you have issued this revocation, it affects the admissibility of the processing of your personal data by us.

(2) If we base the processing of your personal data on the balancing of interests (Art. 6 (1) lit. f GDPR), you can object to this processing. This is the case when processing the data is especially not necessary for fulfilling a contract with you. We describe this in the following description of functions. If you express such an objection, we request that you give us the reasons why you do not wish us to process your personal data as we normally do. After you have submitted your objection with reasons, we will examine the circumstances and will either cease or alter the data processing, or explain to you our compelling legitimate grounds for continuing to process the data.

(3) Of course you can object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can inform us about your objection of processing for advertising purposes using the contact data given in § 1 (2).