Privacy Policy  

I. General Information 

This privacy policy applies to the use of our games on all platforms. Additional privacy information may be available for individual games. In such cases we provide that individual information in the respective games or their respective websites.  

1. Responsible Entity  

Below we explain to you which personal data is collected and processed by us when using our games and services.  

Assemble Entertainment GmbH 
Ostring 3  
65205 Wiesbaden  
Germany  

eMail: [email protected] 
 

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person, this means all information that relates to a person. 

2. Legal Basis

As far as a legal basis is mentioned in this Privacy Policy, they relate to the General Data Protection Regulation.  

We collect and process personal data based on the following statutory regulations: 

• Consent according to Article 6 paragraph 1  (a) General Data Protection Regulation (GDPR). Consent is any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, which indicates that the data subject consents to the processing of his personal data.  

• Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 (b) GDPR, this means that the data is required so that we can fulfill the contractual obligations to you or we need the data to prepare a contract closure with you. 

• Processing to fulfill legal obligations under Article 6 para. 1 (c) GDPR, this means that a processing of the data is required by law or other regulations. 

• Processing for the protection of legitimate interests in accordance with Article 6 para. 1 (f) GDPR, this means that processing is necessary to safeguard legitimate interests on our part or by third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail. 

3. Rights of affected 

You are entitled to the following rights with regard to the processing of data by us in accordance with the respectively listed articles of the General Data Protection Regulation: 

• Information Right pursuant to Article 15 GDPR, i.e. the right to be informed about how your personal data is processed and which personal data is processed by us,  

• Right of rectification pursuant to Article 16 GDPR - i.e. the right to request the rectification of inaccurate personal data relating to you without undue delay, including the completion of incomplete data,  

• Right to erasure ("right to be forgotten") pursuant to Article 17 GDPR - i.e. the right to request the erasure of your personal data, provided that certain conditions are met, 

• Right to restriction of processing pursuant to Article 18 GDPR - i.e. the right to request the restriction of the processing of your personal data, provided that certain conditions are met, 

• Right to data portability pursuant to Article 20 GDPR - i.e. the right to demand that you receive your personal data that you have provided in a structured, common and machine-readable format and the right to transfer it to a third party, provided that certain conditions are met, 

• Right to object in accordance with Article 21 GDPR - i.e. the right to object to the processing of your personal data where the processing is based on our legitimate interests, provided that certain conditions are met.  

• Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating the GDPR. 

4. Data Erasure and Storage Duration 

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage is deleted. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the processor is subject. Blocking or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract. 

II. Actual data processing 

All data transfer is encrypted.  

1. Platform Operator Data Collection  

Subject to any platform you use for playing our game (e.g. Steam, Microsoft Xbox, Sony Playstation) such platforms may independently collect data though such data is not collected by our software or by us and is subject to the respective license terms or terms of use of the respective operator. 

2. Date collected when using our Game 

(a) Scope of data collection 

When using our game we will collect general analytics data which include: 

• actions taken in the game 

• play time and length and numbers of playing sessions 

• country of residence 

• hardware information 

• operating system 

• IP adress 

The IP address is only collected for the transfer of data and the analysis of the location and then anonymized. We use an analytic software operated by a service provider based in the United States of America.  

(b) Legal Basis 

Legal basis is Art. 6 para- 1 (a) and (f) GDPR.  

The legitimate interest is to enable us to improve our game based on the playing experience of our players.  

The legal basis for the transfer of data to our service provider is Art. 26 (3), (6) GDPR in conjunction with the use of the standard clauses of the EU Commission. 

(c) Purpose of data processing 

The purpose is to use such aggregated data to analyze what parts of our game our players prefer, if parts of our games are not accessible or should be improved.  

(d) Duration of storage 

The data is anonymized upon after using the IP address to analyse the user’s country of origin.  

(e) Objection and removal possibility 

You may at any time deactivate the analytics functions in the option menu of our games.  

3. Contacting us via E-Mail & Newsletter 

(a) Scope of data processing 

If you contact us via email or provide us on other channels with your e-mail address for support for any of our games or other questions, we may subsequently use your e-mail address to send you e-mails regarding the reason for you contacting us. Such e-mail addresses as well as the content of your messages is stored for with our e-mail service provider who may also process data outside of the European Union, especially in the United States of America. 

It is also possible to subscribe to a free newsletter for our games, which provides information about our existing and upcoming games. When subscribing to the newsletter, the data from the input mask is transmitted to us. In this case, the date and time of registration for the newsletter as well as the IP address used will also be stored. In the context of the confirmation of the newsletter registration, the date and time at which you click on the confirmation link for the newsletter registration as well as the IP address used are also stored. 

In order to send the newsletter, your e-mail address will be passed on to an external service provider, who will send the newsletter on our behalf. No further use is made by the service provider. The service provider is based within the United States of America.  

(b) Legal basis 

The legal basis for the processing of data when registering directly for the newsletter is Art. 6 para. 1 lit a GDPR. 

The legal basis for the transfer of data to our newsletter service provider as well as our e-mail service provider, is Art. 28 Para. 3 , 6 GDPR in conjunction with the use of the standard clauses of the EU Commission. 

The legal basis for contacting you via e-mail and storing such communication if you provided us your e-mail address is Art. 6 para 1 lit. a, b, c or f GDPR, which depends on the content and the relation, as your consent is provided when contacting us, the communication may relate to an ongoing contract or may be considered a trade document in accordance with trade and tax law which we are obliged to store, but also it may be in our legitimate interest in case we wish to document our legal compliance.  

(c) Purpose of the data processing 

The purpose of storing the e-mail address is to enable electronic contact for information purposes. The date and IP address of the registration as well as the confirmation of the registration are recorded in order to document the consent to the newsletter dispatch in an evidence-proof manner and to exclude misuse. The information is passed on to the service provider for the purpose of sending the newsletter in bulk. In case the communication is considered a trade document the purpose is also to comply with mandatory storage obligations.  

(d) Duration of storage 

Insofar as you have expressly consented to receive the newsletter, we will only delete or block the e-mail address for dispatch if you revoke your consent. The data of the confirmation of the newsletter order will be stored for the same length of time. We will delete email communication after 2 years, unless such communication has to be stored for longer under applicable tax and trade laws.

(e) Possibility of objection and removal 

You can object to the use with effect for the future of each newsletter by clicking on a link provided there. You can also object to future use by sending an e-mail to [ADD EMAIL]. In the case of an objection by e-mail, the implementation of the deletion or blocking may take up to 2 working days; during this period, mailings may still be made. 

If you request us to delete email communication with you we will comply accordingly, unless we are legally obliged to store such data or it is required for legal defense.  

4. Websites including contests 

(a) Scope of Data Collection 

When visiting our website, the following data is collected and stored by our web server: 

• Information about the browser type and version used 

• The operating system of the user 

• The IP address of the user 

• Date and time of access 

The data is stored in the log files of of our hosting provider. This data is not stored or processed together with other personal data of the user. Our hosting provider is Automatic Inc., based in the United States of America. . 

(b) Legal basis 

The legal basis for processing the data is Art. 6 para. 1 (f) GDPR.  

The legal basis for the transfer of data to Automatic Inc. is Article 28 para. 3, 6 and 7, Article 46 para. 2 (c) GDPR. The standard contractual clauses of the EU Commission are used in contractual relation with the provider. 

The legitimate interest within the meaning of Art. 6 para. 1 (f) GDPR therefore lies in the functionality of our website and its availability. 

(c) Purpose of data processing 

The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user's IP address must be kept for the duration of the session. 

The data is stored in order to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context. 

(d) Duration of storage 

The logfiles will be deleted after sixty days at the latest, unless there is a need to keep the data for the aforementioned purpose due to specific events. 

(e) Objection and removal possibility 

The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no possibility of objection by the user. 

5. Website Analytics 

(a) Scope of data processing 

Our websites uses Google Analytics, a web analytics service provided by Google Ireland Ltd. ("Google"). This software collects information about how you use the website and compiles various statistics. The increased usage data include in particular the concrete selection of links, the length of stay on individual pages and the order of use of the website, the frequency of the page request.  This data is collected together with your IP address.  

In particular, the following information is collected: 

- Information about the type of browser and the version used 

- The operating system of the user 

- The user's Internet service provider 

- The IP address of the user 

- Date and time of access 

- Websites from which the user's system accesses our website  

- Websites that are accessed by the user's system via our website 

Google Analytics uses so-called "cookies", text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by cookies about your use of this website is usually transmitted to a Google server in the USA and stored there. 

We have activated a so-called IP anonymization on the website, this means that the IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area prior to retransmission to the USA. 

Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google itself describes here https://www.google.com/policies/privacy/ its data processing activity. 

(b) The data processing is essentially carried out by Google itself. Despite IP anonymization, the data is not anonymous and can be merged with other data by Google. Google can use the data for any of its own purposes, such as profiling, as well as link it with other data such as any Google accounts and also pass it on to associated US companies, e.g. Google LLC. Legal basis 

The legal basis for the processing of data when using the website is Article 6 para. 1 (a) GDPR in the form of your express consent.  

The legal basis for the transfer of data to Google is Art. 26 GDPR and Art. 6 para. 1 (a) GDPR. For any subprocessing done by Google outside of the EU Google employs the standard contractual clauses of the EU commission.  

(c) Purpose of data processing 

The purpose of the processing is to analyze this website and the usage behavior of its visitors. 

(d) Duration of storage 

We ourselves no longer have access to personal data after anonymization by Google. With regard to a use by Google, the duration of the storage is not known. 

 (e) Objection and removal possibility 

You can prevent the storage of cookies, including the generation and transmission of data to Google, by restricting or prohibiting the use of cookies in your browser software. This may result in the deactivation of non-Google-related cookies as well as the inability to use all functions of this website to the full extent. 

You can prevent the collection of the data generated by the cookie regarding your use (including your IP address) and their transmission to Google as well as the processing of this data by Google by downloading the browser plugin available under the following link and to install [Http://tools.google.com/dlpage/gaoptout?hl=de].  

Updated: 28.03.2023