Privacy Policy

1. Name and contact data of the controllers responsible for processing, as well as the company data protection officer

 

This data protection information applies to data processing by:

 

Controller:

 

Daedalic Entertainment GmbH,

Papenreye 51,

22453 Hamburg,

represented by the CEO Carsten Fichtelmann and the COO Stephan Harms,  

        

e-mail:    info@daedalic.com,

tel:      +49 40 432 612 70,

fax:     +49 40 432 612 7

 

The companies’ data protection officer is

Frederik Bockslaff     


who can be reached under:


Nimrod Rechtsanwälte,                                 

Emser Straße 9,                                     

10719 Berlin,


e-mail:     info@nimrod-rechtsanwaelte.de,

tel:      +49 (0)30 544 61 793,

fax:     +49 (0)30 544 61 794.
 


2. Collection and storage of personal data and the purpose of their use

The controller has integrated BuffPanel to this game. BuffPanel is a service, that measures the influence of online marketing campaigns on real user traffic. This is done by attributing user clicks on links generated by BuffPanel with actual user activity in the game. Personal data is furthermore collected by BuffPanel when the data subject runs the game.

The operator of the BuffPanel component is Cellende, s.r.o, Zálužická 1, 821 01 Bratislava, Slovakia.

The following personal data will be tracked by the BuffPanel application:

  • Event timestamp

  • Game Token

  • IP address (one-way hashed)

  • Player ID (randomly generated UUID)

  • Common HTTP headers (sent by browsers to any website visited by the data subject)

  • Optionally al list of DLCs the data subject has installed with purchase timestamps.

 

Any personal data collected by BuffPanel will be anonymized.

The data subject may prevent the tracking at any time by placing the following line in its host file:

0.0.0.0 api.buffpanel.com

Further information and the applicable data protection provisions of BuffPanel may be retrieved under

https://buffpanel.com/players-faq/

https://buffpanel.com/privacy-policy/.

The processing of personal data for the purpose stated above occurs in accordance with Art. 6 (1) lit. f GDPR for the purpose of our legitimate interests. The legitimate interest of the controller results from the necessity of monitoring the effectiveness of applied marketing strategies.

 

 


3. Forwarding data

The personal data processed by the controller will be forwarded to BuffPanel and its subcontractors.

BuffPanel does not transfer personal data outside the EU and/or European Economic Area where not necessary. However, some of its subcontractors might be based or their servers might be located in the United States of America (U.S.). As such, the US is regarded as a third party not ensuring an adequate level of protection. Companies certified under the EU-US Privacy Shield mechanism according to the Commission (EU) are regarded as ensuring an adequate level of protection. Any transfer of personal data outside the European Economic Area through BuffPanel is done only under strict compliance with the GDPR. BuffPanel ensures the third-party recipients are either certified under the EU-US Privacy Shield, concluded EU model clauses with BuffPanel or follows equivalent safeguards in place.

 


4. Data subject rights


You have the right:

  • pursuant to Art. 15 GDPR, to demand information about your personal data that we have processed. In particular, you can obtain information about the purposes of the processing, The categories of personal data concerned, the recipients or category of recipients to whom you data have been or will be disclosed, the envisaged period for which the data will be stored, the existence of the right to request rectification, erasure, or restriction of the processing, or to object to it, the right to lodge a complaint with a supervisory authority, the source of your data, if these have not been collected by us, and on the existence of automated decision-making, including profiling, and any other meaningful information about their details or the logic involved;

  • pursuant to Art. 16 GDPR, to demand the immediate rectification or completion of inaccurate personal data stored by us;

  • pursuant to Art. 17 GDPR, to demand the erasure of personal data stored by us, unless their processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defence of legal claims;

  • pursuant to Art. 18 GDPR, to demand the restriction of the processing of your personal data in cases where you contest the accuracy of the data, where the processing is unlawful yet you oppose the erasure of the personal data, where we no longer need the data but you still require them to establish, exercise or defend legal claims, or where you have objected to the processing of the data pursuant to Art. 21 GDPR;

  • pursuant to Art. 20 GDPR, to obtain your personal data that you have provided to us in a structured, commonly used and machine-readable format and to demand the transfer of these data to another controller;

  • pursuant to Art. 7 (3) GDPR, to withdraw your consent at any time, which will mean that in future we may no longer carry out the data processing that was contingent upon this consent and

  • pursuant to Art. 77 GDPR, to lodge a complaint with a supervisory authority. In general you can contact the supervisory authority of your usual residence or place of employment, or that of our company headquarters for this purpose.

 


5. Right of objection


Insofar as your personal data is processed on the basis of legitimate interests in accordance with Art. 6 (1) lit. f GDPR, you have the right, under Art. 21 GDPR, to object to the processing of your personal data, provided there are reasons relating to your particular situation or if the objection relates to direct marketing. In the latter case, you have a general right to object, which shall be implemented by us without any reference to a particular situation.


If you wish to avail of your right to withdraw or object, an e-mail to info@nimrod-rechtsanwaelte.de will suffice.