P2Gamer respects your privacy and works hard to safeguard the privacy of your data. We realize that the exciting growth of the Internet and online services raise questions concerning the nature, use, and confidentiality of information collected about consumers. We want you to know that we apply our long-standing commitment to safeguarding privacy to our online and Internet activities.
By providing your Personal Information to us, you are consenting to this Privacy Statement and the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Statement.
The use of the Internet pages of P2Gamer is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and under the country-specific data protection regulations applicable to P2Gamer. Through this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, using this data protection declaration, of the rights to which they are entitled.
As the controller, P2Gamer has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
In addition to GDPR, please note that we collect, store and handle personal information of individuals by the Personal Data Protection Act 2010 (“PDPA”) and the laws of Singapore.
The data protection declaration of P2Gamer is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and partners. To ensure this, we would like to begin by explaining the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of Processing
Restriction of processing is the marking of stored personal data to limit their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or Controller Responsible for the Processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other bodies which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
The processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
The recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry by Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.
Third-party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the Controller
Controller for the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection this is:
3. Information We Collect from You
We value your trust in providing us your personal information. P2Gamer does not share, disclose or sell any personally-identifiable information (such as your name, address, telephone number or e-mail address) collected online on P2Gamer’ sites with other unaffiliated companies or organizations for non-P2Gamer marketing or fraud protection purposes. Because this information is a critical part of our business, it would be treated like our other assets in the context of a merger, sale or other corporate reorganization or legal proceeding.
We collect Personal Data that is relevant to providing our Services for anti-fraud Purpose to ClearSale refer to https://clear.sale/privacy-shield-policy and https://www.clear.sale/privacypolicy. We process Personal Data compatible with us providing the Services or as otherwise notified to you. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed from ClearSale’s Services, accurate, complete, and current.
Information on Children and Underage Adolescents
Children and underage adolescents may be users of our products and services, provided that they are duly authorized by their parents or guardians or that their parents or guardians act on their behalf. If their parents or guardians of these children become aware of unauthorized data processing, they may submit their inquiries or complaints to [email protected]
When Can We Collect Your Personal Information?
We may collect personal information directly from you when you:-
communicate with us (for example when you submit an application form to become our customer, or when you contact us for any inquiries including by calling our customer service)
register or subscribe for a specific Product and/or Service or our publications (for example, newsletters)
participate in any of our surveys
enter into or participate in any competitions, contests or loyalty programs run/organized by P2Gamer
register interest and/or request for information of (through our online Websites or other available channels) or subscribe to our Products and/or Services
respond to any marketing materials we send out
visit or browse our websites
*lodge a complaint with us
provide feedback to us (for example via our websites or in hard copy)
Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with or are connected with you (credit reference agencies or financial institutions), and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.
How Can We Collect Your Personal Information?
P2Gamer collects information online by asking you for it, for example, when you order a service, apply for a job, or respond to a survey, offer or other promotion. A customer’s name, address (postal and e-mail) and telephone number are the most important pieces of information, but we might request other information, based on, for example, the service(s) being ordered or promoted.
Cookies: P2Gamer may also use “cookies” and similar technology to obtain information about your visits to our sites or your responses to e-mail from us – both individually and in aggregated data that does not identify you. These reporting tools tell us the parts of our web sites or e-mails in which you showed an interest or took some action, and help us improve the quality and usefulness of our sites.
Content: You also provide us information in the content you post to the website. Your content (such as reviews, photos, and videos) and metadata about your content will be viewed by other users. P2Gamer can, but has no obligation, to monitor your content you post on the website. We can remove any information you post for any reason or no reason.
Payment Method: You will also be asked to submit Personal Information depending on the payment method you choose when accessing, purchasing or subscribing to one of our products or services. For example, if you choose to pay for a product/service by credit card, you will be required to provide us the name of your credit card issuer, credit card number, billing address, CVV number, and expiration date.
Log Files: When you use the website, our servers automatically record certain information sent by your web browser. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the website, domain names, landing pages, pages viewed, mobile carrier, and other such information.
Geo-Location Information: When you use the website by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
How Can We Use Your Information
P2Gamer uses the personally-identifiable information collected online principally to provide you with the service(s) you have ordered and to let you know about other offerings that may be of interest to you. Postal and e-mail address information, for example, enables communication about services offered and ordered, as well as the proper provisioning and billing of those services. At any point in time, should you feel the need to opt-out future communications with P2Gamer, options are given within to exclude those communicated messages to you.
We also provide personally-identifiable online information in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with P2Gamer’ services, or with our customers’ or others’ use of them.
Our primary purpose in collecting personal information is to provide you with a customized experience that is safe, smooth, and efficient. You agree that we may use your personal information to:
Provide the services and customer support you request;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent potentially prohibited or illegal activities;
Enforce our User Agreement, other agreements, and policies;
Customize, measure, and improve our services and the Site’s content and layout;
Protect our rights, property, and safety, including that of our employees, users, or others;
Tell you about or provide targeted marketing, service updates, and promotional offers based on your communication preferences; and
Compare information for accuracy, and verify it with third parties.
What We Request from You
We request you to provide us accurate and complete information about yourself and any other person whose personal information you provide us and for updating when it becomes incorrect or out of date by contacting us. This obligation is a condition to the provision of our Products and/or Services to you and/or any other person authorized or permitted by you or your organization/company to use the Products and/or Services.
We Promise Privacy and Security
Both of us together play an important role in protecting against online fraud. You should be careful that any information including your User ID, Password, Security Device and/or Security Code are not compromised by ensuring that you do not knowingly or accidentally share, provide or facilitate unauthorized use of it. Do not share your User ID, Password, Security Device and/or Security Code or allow access or use of it/them by others.
At P2Gamer, we use encryption, firewalls and other technology and security procedures to help protect the accuracy and security of your personal information and prevent unauthorized access or improper use. For example, you will note that while using some features of the P2Gamer’s web site you will need to submit a password or some other type of authenticating information.
Disclosure of Your Information (If Needed)
When you have provided Personal Information to us for a particular purpose, we may disclose your information to other companies that we have engaged to assist us in fulfilling your request. This may include but is not limited to, fulfillment houses, billing services, transaction managers, credit verification services, and other third-party service providers. We may also disclose any of your Personal Information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect the legitimate legal interests of P2Gamer.
Notices to the Changes in Privacy Policies
The data subject may, at any time, prevent the setting of cookies through our website through a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
5. Collection of General Data and Information
The website of P2Gamer collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time (so-called timestamp) of access to the Internet site, (6) an Internet protocol address (IP address), (7) the internet service provider (ISP) of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, P2Gamer does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, P2Gamer analyzes anonymously collected data and information statistically, to increase the data protection and data security of our enterprise and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
6. Registration on our Website
The data subject can register on the website of the controller with an indication of personal data. Which personal data are transmitted to the controller is determined by the respective sign-up form used for the registration which can be obtained from https://www.p2gamer.com/login. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and his purposes. The controller may request transfer to one or more processors that also use personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. Besides, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller’s employees, are available to the data subject in this respect as contact persons.
7. Subscription to our Newsletters
On the website of P2Gamer, users are allowed to subscribe to our newsletter. The input section used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
P2Gamer informs its customers and partners regularly using a newsletter about product offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double-opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. Also, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For revocation of consent, a corresponding link (‘unsubscribe’) is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in a different way.
The newsletter of P2Gamer contains tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, P2Gamer may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up (clicked on) by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the shipping of the newsletter, as well as to continuously adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued using the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. P2Gamer automatically regards a withdrawal from the receipt of the newsletter as a revocation.
9. Contact Possibility via the Website
The website of P2Gamer contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the data controller are stored for processing or contacting the data subject. There is no transfer of this personal data to third parties.
10. Subscription to comments in the Blog on the Website
The comments made in the blog of P2Gamer may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favor of this option. The option to subscribe to comments may be terminated at any time.
11. Routine Erasure and Blocking of Personal Data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased by legal requirements.
12. Rights of the Data Subject
Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Right of Access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to complain about a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.
Right to Rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including using providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Right to Erasure (Right to be Forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary concerning the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing according to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or the data subject objects to the processing according to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected about the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by P2Gamer, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of P2Gamer or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of P2Gamer or another employee will arrange the necessary measures in individual cases.
Right of Restriction of Processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead.
The controller no longer needs the personal data for the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing according to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by P2Gamer, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of P2Gamer or another employee will arrange the restriction of the processing.
Right to Data Portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability according to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by P2Gamer or another employee.
Right to Object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profile based on these provisions.
P2Gamer shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If P2Gamer processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profile to the extent that it is related to such direct marketing. If the data subject objects to P2Gamer to the processing for direct marketing purposes, P2Gamer will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by P2Gamer for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may directly contact the Data Protection Officer of P2Gamer or another employee. Also, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated Individual Decision-Making, Including Profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, P2Gamer shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of P2Gamer or another employee of the controller.
Right to Withdraw Data Protection Consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of P2Gamer or another employee of the controller.
13. Data Protection Provisions about the Application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.
A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. Also, it is explained there what setting options Facebook offers to protect the privacy of the data subject.
14. Data Protection Provisions about the Application and use of Google Analytics
On this website, the controller has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such as personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time using a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. Also, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following link https://www.google.com/analytics/.
15. Data Protection Provisions about the Application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing, therefore, allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, inter alia, for the insertion of interest-relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time through a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. Besides, cookies already in use by Google may be deleted at any time via a web browser or other software programs.
Also, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.
Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
16. Data Protection Provisions about the Application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are used to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, using a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. Also, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest-based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
17. Data Protection Provisions about the Application and use of Twitter
On this website, the controller has integrated components of Twitter. Twitter messages (tweets) are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.
If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.
Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.
The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.
18. Data Protection Provisions about the use of P2Gamer
We use a tracking pixel. A tracking pixel is a miniature graphic embedded in a web page to enable log file recording and log file analysis to subsequently perform statistical analysis. P2Gamer also sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. The setting of the cookie enables us to analyze the usage of our website. Using the data obtained, usage profiles are created. The usage profiles are used to analyze visitor behavior and enable improvement of our Internet offer. Data collected through the P2Gamer component are not used to identify the data subject without first obtaining separate and explicit consent from the data subject. These data will not be merged with personal data or with other data that contains the same usage profile. By default, P2Gamer identifies the companies, not the individuals, who are accessing the website, and presents firmographic information. Personal information is only collected and stored based on opt-in preferences. With each call-up to one of the individual pages of this website, the Internet browser on the information technology system of the data subject is programmatically requested to submit data for online analysis to the P2Gamer component. During this technical procedure, P2Gamer gains knowledge of visitor information, such as the requesting IP address, which inter alia, serves to understand the origin of visitors and clicks. The cookie is used to store anonymized information, such as the access time, and the frequency of visits to our website. With each visit of our Internet pages, these visitor data, including the IP address of the Internet access used by the data subject, are logged and stored by the P2Gamer server.
The data subject may prevent the setting of cookies through our website at any time using a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent P2Gamer from setting a cookie on the information technology system of the data subject. Also, cookies already in use by P2Gamer may be deleted at any time via a web browser or other software programs. If the controller chooses “P2Gamer” as a lead identification option for their website, we might transmit personal data of the data subject to P2Gamer. By implementing this lead identification option, the controller agrees to the transfer of personal data required for lead identification. The personal data transmitted to P2Gamer is usually first name, last name, email address, IP address, telephone number, mobile phone number, or other data necessary for lead identification processing. The transmission of the data is aimed at Lead identification. The controller can transfer personal data to P2Gamer, in particular, if a legitimate interest in the product or service of the controller is given.
19 Legal Basis for the Processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third parties. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
20. The Legitimate Interests Pursued by the Controller or by a Third Party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
21. Period for Which the Personal Data Will be Stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
22. Provision of Personal Data as Statutory or Contractual Requirement; Requirement Necessary to enter into a contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide such Data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
23. Existence of Automated Decision-Making
As a responsible company, we do not use automatic decision-making or profiling.