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Legal Notice

Published by:

Ravensburger AG
Robert-Bosch-Str. 1
88214 Ravensburg

E-Mail: info@ravensburger.de

Authorized representatives:
Clemens Maier (chief executive officer), Hanspeter Mürle

Chairman of the supervisory board:
Prof. Dr. Dieter Kurz

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 support@ravensburger-digital.com. You can contact our data protection officer at datenschutzbeauftragte@ravensburger.de 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. 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.

f. 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.

§ 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).