Privacy Policy - WeQ STUDIOS

Contact Us

Privacy Policy

1. General Information about Data Protection at WeQ

Data protection is of paramount importance to WeQ Global Tech GmbH.

As a company in the field of online and mobile gaming, it is essential for us and our users that the provisions of the General Data Protection Regulation (GDPR) and the respective national data protection laws are complied within our work.

This privacy statement is directed to you as a data subject (“You”) and the public as to the legal basis upon which and in what way, to what extent and for what purpose we as the Controller process personal data and what rights You have when You play our games, visit our website and use related services, which we here collectively call the Service.

2. Controller

The Controller within the meaning of the Art 4 (7) GDPR and other national data protection laws of the Member States is:

WeQ Global Tech GmbH
Schwedter Str. 263
10119 Berlin
E-Mail:  privacy@weq.com
Website: https://weqstudios.com/

3. Data Protection Officer

Our company has appointed a Data Protection Officer in accordance with Art 37 GDPR, which can be contacted as follows:

Der externe Datenschutzbeauftragte
c/o WeQ Global Tech Sub GmbH
Schwedter Str. 263
10119 Berlin

E-Mail: privacy@weq.com

4. Scope of processing of personal data

We collect and use your personal data only to the extent necessary for the provision of a functioning Services.

Personal data are available data pertaining to You personally as our user or third parties, such as name, e-mail, address, user behaviour and IP address.

The processing of personal data takes place exclusively on a statutory basis and, insofar as no such laws exist for the specific processing, with your consent as the data subject concerned.

In some cases we use external service providers to process your data (“processors”). These have been carefully selected and commissioned by us, are contractually bound by data processing agreements, are subject to our directives and are regularly checked.

a) Scope of the processing of personal data when You visit our website for informational purposes

In the case of merely informational use of our website, we only collect the personal data that your browser transfers to our server. We collect the following data, which are technically necessary for us to display our website to You as a (potential) customer and to ensure its stability and security:

  • The IP adress;
  • The date and time of your request;
  • The access status/HTTP status code;
  • The respective quantity of data transferred;
  • The website from which the request comes;
  • The browser used by you;
  • Your operating system;
  • The language and version of the browser software;

We collect and use this data exclusively in non-personal form during your informational visit. This is done to enable the use of the internet pages You have accessed (connection establishment), to permanently guarantee system security and stability, to enable the technical administration of the IT infrastructure, for statistical purposes and to improve our website and our services. Your IP address will only be evaluated for attacks on the network infrastructure and for statistical purposes, without any conclusions about your person being possible. In addition, we use cookies when You visit our website:

The aforementioned data will not be stored together with other personal data of yours.

The legal basis for the above processing is: Article 6 (1) sentence 1 lit. f GDPR. Our legitimate interest is based on the purposes listed above for data collection. Under no circumstances do we use the data collected for the purpose of drawing conclusions about you personally.

b) Scope of the processing of personal data when registering for our services

In the event of a registration on our website, the recognisable output and input mask data are collected and processed for our own purposes. In this context, we collect the following data in order to implement the contract to be concluded with you as the customer:

  • The name of the company;
  • The business address of the company;
  • The telephone number of the company;
  • The e-mail address of the person registering;
  • A password for subsequent login;
  • The first and last name of the person registering;
  • The job title of the person registering;
  • The IP address;
  • The date and time of registration;

In the event of a registered user login, the following data is collected in order to execute the contract concluded with this user:

  • The e-mail address of the registered person;
  • The password of the registered person;
  • The IP address;
  • The date and time of the login;

The aforementioned data will not be stored together with other personal data of yours.

The legal basis for the above processing is: Article 6(1) sentence 1 lit. b GDPR.

We also forward the above data in the context of contract data processing. Your personal data are used exclusively for internal purposes by our contract data processor (Art. 4 (8) GDPR). Any processing in the context of contract data processing is attributable to us as the Controller.

c) Scope of the processing of personal data when you contact us or when You submit a game

In the event of contact via our website or submitting a video footage of a game on our website, the recognisable data of the input mask of our contact form are collected and processed for our own purposes. In this context, we collect the following data if you contact us in order to process your inquiry:

  • Your first and last name;
  • Your e-mail address;
  • Your telephone number;
  • Your company;

We collect the following data if you are submitting a video footage of a game in order to process your inquiry:

  • The title of the game;
  • Your e-mail address;
  • Your IP address;
  • The link of the video footage;
  • Website URL;

In the context of the send procedure, your consent is obtained and You are referred to this privacy statement in order for the data to be processed.

In the case of contact via the e-mail address specified on our website, your e-mail address and any further personal data submitted by You are stored and processed to answer your inquiry.

The aforementioned data will not be stored together with other personal data of yours.

The legal basis for the above processing is: Art 6 (1) sentence 1 lit. a GDPR (contact form) and Art. 6 (1) lit. f GDPR (e-mail contact). Our legitimate interest results from the processing of the message you sent to us.

d) Scope of processing of personal data when you subscribe to our newsletter

In the event of subscribing to our newsletter, the recognisable data of the input mask of our subscription form are collected and processed for our own purposes. In this context, we collect the following data in order to process your inquiry:

  • Your e-mail address
  • Your first and last Name (optional)
  • Your preferences of how to be informed by us

In the context of the subscription, your consent is obtained (Art 6 (1) sentence 1 lit. a GDPR) and You are referred to this privacy statement in order for the above data to be processed.

Subscription to our newsletter follows a so-called double opt-in procedure. This means, that after registration You will receive an e-mail asking You to confirm your registration. This confirmation is necessary so that no one can log-in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP-address.

The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 (1) lit. f GDPR. We want to provide a user-friendly and secure newsletter system that serves both – our business interests and the expectations of users and also allows us to provide proof of consent.

Sending of our newsletter and the performance measurement associated with it is based on the Your consent pursuant to Art. 6 (1) lit. a, Art. 7 GDPR in conjunction with § 7 (2) No. 3 German Fair Trade Practices Act (UWG) or on the basis of the legal permission pursuant to § 7 (3) UWG.

You may cancel the receipt of our newsletter at any time, i.e. by revoking your consent. You will find a link to unsubscribe from our newsletter at the end of each newsletter. We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete, in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims.

An individual application to unsubscribe is possible at any time, provided that at the same time the former existence of a consent is confirmed. Please use the e-mail address indicated in sec. 8 of this privacy policy.

Our newsletter is sent out with the e-mail service provider “MailChimp”, a newsletter delivery platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. The data protection regulations of MailChimp can be viewed at https://mailchimp.com/legal/privacy/.

The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee to currently comply with the European data protection level. Membership can be looked up here: https://www.privacyshield.gov/list.

MailChimp is used on the basis of our legitimate interests according to Art. 6 (1) lit. f GDPR and within the scope of Art. 28 (3) GDPR (Order Processing).

MailChimp may use recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, MailChimp does not use the data of our newsletter recipients for contacting them or to pass the data on to third parties.

Our newsletters contain a so-called “Web-Beacon”, i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened or, as we use MailChimp, from its server. When the Web-Beacon is being retrieved, certain technical information, such as Your browser type and Your operating system, as well as Your IP address and time of retrieval are initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked upon. For technical reasons, this information can be assigned to the recipient. However, it is neither our endeavour, nor MailChimp´s endeavour to observe individual recipients. The evaluations help us to recognize the reading habits of our newsletter recipients, to adapt our contents accordingly or to send different contents according to the interests evaluated.

d) Use of cookies

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. If a user visits a website, a cookie can be stored on the user’s operating system. This cookie contains a characteristic string that uniquely identifies the browser when the website is revisited.

You have full control over the use of cookies. Modifying the settings in your Internet browser allows You to disable or restrict the transfer of cookies. Previously stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are disabled, it may no longer be possible to use all of the features of the website to the full extent.

e) Analytics services

For the purpose of needs-oriented design and ongoing optimisation of our Service, we use Google Analytics, a web analytics service provided by Google, Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”).

Google Analytics uses cookies and created pseudonymised usage profiles to enable analysis of Your use of the Service. The information generated by the cookie regarding Your use of the Service (such as browser type/version, operating system used, referrer URL, host name of the accessing computer and time of the server request) are generally sent to a Google server in the USA and stored there.

Because IP anonymisation (IP masking) is activated on the Service, your IP address is first truncated by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area.

On behalf of us as the operator of the Service, Google shall use this information to evaluate your use of the Service, compile reports on Service activities and provide further services relating to Service activity and Internet usage for the Service operator. The IP address transmitted from your browser within the context of Google shall not be combined with other data by Google. The information may be forwarded to third parties, provided that this is required by law or insofar as such third parties process the information on a contract basis.

Google Analytics cookies are stored on the basis of Art. 6 Par. 1 lit. f DSGVO. Our legitimate interest is based on an analysis of Your user behaviour in order to optimise both our Service and its advertising.

You can prevent the saving of cookies by selecting the appropriate setting in your browser software; however, we would point out that You may then be unable to fully use all functions of this website. You can also prevent the capture of data generated by the cookie pertaining to Your use of the site (including your abbreviated IP address) by Google and the processing of these data by Google by downloading and installing the available browser deactivation add-on from the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information is available in the Google privacy statement: https://www.google.com/intl/en/policies/privacy/.

g) Scope of processing personal data for purposes of In-Game-Advertising

Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:

  • the make, model and operating system of your device;
  • properties of your device, such as screen size and orientation, audio volume and battery;
  • the mobile network operator linked to your device;
  • the Games played;
  • the country, time zone and locale settings on your device (i.e. country and preferred language);
  • network connection type and speed;
  • IP Address;
  • MAC address;
  • internet browser used to access the Games; and
  • the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

We may process mentioned data to show you advertisements for third party services.

The information we collect about you may be used to understand how advertisements placed in our Games have performed or how many people have viewed certain advertisements. We aggregate this information so that it does not personally identify you or permit you to be treated individually.

We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :

If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.

Such advertisements allow us to offer you our Services for free. The legal basis for the use of those services of these partners is based on our legitimate interests according to Art. 6 (1) lit. f GDPR and within the scope of Art. 28 (3) GDPR and Section 62 BDSG (new) [German Federal Data Protection Act].

h)Scope of processing personal data in case of any installation(s) of third party mobile apps advertised on our mobile game applications.

In the case of the installation of a third party mobile app advertised on one of our apps, Google might process necessary tracking data trough Firebase, which is  a mobile service of Google Inc.. Firebase uses the Instance ID of your mobile device to identify individual installations of an mobile app. Since each Instance ID is unique to a particular app and device, they give Firebase a way to refer to specific app instances. The information generated by the instance ID about your use of this mobile app is generally transmitted to and stored by Google on servers in the United States. Your IP address transmitted by this mobile app in the context of Firebase will not be merged with other data of Google.

Legal basis for the use of Firebase is Art. 6 Par. 1 S. 1 lit. a or f GDPR. Our legitimate interest is based on an analysis of Your user behaviour in order to optimise our gaming marketing campaigns and for campaign tracking purposes.

If IP anonymization is activated on the mobile app, your IP address will be anonymised beforehand within the Member States of the European Union or in other states party to the Agreement of the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. IP anonymization is active on all mobile apps within our gaming marketing campaigns. On behalf of us, Google will use this information to evaluate your use of the mobile app, to compile reports on mobile app activity and to provide other services relating to the mobile app. The IP address transmitted by the mobile app in the context of Google Analytics will not be merged with other Google data.

We use the Firebase service Analytics to provide analytics and attribution information in case you use a mobile device with Android operating systems. Firebase Analytics collects Mobile ad IDs, Android mobile device IDs, Instance IDs, Analytics App Instance IDs. Firebase Analytics retains ID-associated data for 60 days and retains aggregate reporting and campaign data without automatic expiration, unless the mobile app provider changes its retention preference in its Analytics settings or deletes its project.

We use the firebase service dynamic links that uses device specs IDs in case you have a mobile device with iOs operating system to facilitate use of newly-installed mobile apps. Dynamic Links only stores devices specs temporarily, to provide the service.

We use the Firebase service Performance Monitoring that uses Instance IDs to monitor the mobile app’s function and to react on specific instances. Performance monitoring retains instance-associated events for 30 days. Firebase retains Instance IDs until we request deletion. After that, the personal data are deleted by firebase within 180 days.

You can prevent Google from collecting the data generated by the Instance ID and relating to your use of the mobile app (including your IP address) and from processing this data by opting-out in this mobile app’s settings.

Further information on the data collected and used by Google Firebase:

https://firebase.google.com/terms/data-processing-terms

https://firebase.google.com/terms/

https://firebase.google.com/support/privacy/manage-iids

https://firebase.google.com/support/privacy/

5. Third Party Website

WeQ uses social media Webpages to aquire new Users. When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.

The legal basis for the use of those services of these partners is based on our legitimate interests according to Art. 6 (1) lit. f GDPR and within the scope of Art. 28 (3) GDPR.

6. Data deletion and storage duration

The personal data of the affected person are generally deleted or disabled as soon as the purpose of storage expires.

Furthermore, storage may also occur if so required by European or national law under European Union regulations, laws or other provisions to which the Responsible Body is subject.

Blocking or deletion of data is carried out even if a storage period specified by the standards referred to expires, unless there is a need for further storage of the data in order to conclude or execute a contract.

7. Your general rights

You may contact WeQ at any time and request:

  • Information about your personal data stored and processed by WeQ; or
  • Correction or deletion of your personal data stored by WeQ

However, WeQ may retain, store and process your personal data as necessary to the extend required by law, to resolve disputes or if necessary for the performance of any agreement between WeQ and You. Please use contract details as indicated in sect. 3 of this privacy policy.

Your EU Data subject rights

As an EU resident, You are granted the following rights against us in respect of the relevant data:

  • The right to information;
  • The right of correction or deletion;
  • The right to the restriction of processing;
  • The right to revoke Your consent;
  • The right to object to the processing;
  • The right to data portability;

You can assert all of these rights by contacting our Data Protection Officer at privacy@weq.com.

You also have the right to complain to a data protection supervisory authority in regard to the processing of your personal data by us.

The data protection authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin.

State: 17/05/2018 / Version 1.1