Privacy Policy

This Privacy Policy applies to the collection, processing and use of User data related to the use of the website, games, In-App services, and other services („Services“) provided by www.handy-games.com GmbH („HandyGames“). The Services particularly enable Users to receive information about and play games and to communicate with each other. HandyGames respects your privacy rights. For details please see our Privacy Policy below.

1. Scope of application

This Privacy Policy applies to all Services operated by HandyGames and addresses all Users of the Services („Users“ or „you“). If other offers of HandyGames have a differing Privacy Policy, the differing Privacy Policy published on that offer shall apply. The Services may contain cross-references („links“) to offers of third party providers. By clicking on such links, you leave the Services. In such a case, HandyGames does not take any responsibility for the content and compliance with data protection laws of these offers. This Privacy Policy does not apply to those offers.

2. Collection, processing and use of your data for the Services

  1. HandyGames will only collect, process or use your data pursuant to the applicable data protection laws, such as the German Data Protection Act („BDSG“) and the Telemedia Act („TMG“). Besides that, we will provide the data security standards required by the BDSG.
  2. HandyGames will only collect, process or use any data referring to you as a person for the purpose of fulfilling the User contract, i.e. the establishment, performance and ending of the contract (including billing for the Services, where applicable). HandyGames will not disclose your personal data to third parties unless HandyGames is required by law or unless you have consented to any other use. Collection, usage and processing of the data are carried out in electronic form.
  3. Personal data which may be collected by HandyGames for the purpose of fulfilling the User contract could be your name and your e-mail-address. Any additional data you provide to HandyGames for completing your profile or when uploading content, you provide voluntarily to HandyGames. HandyGames assigns a User-ID to each User by which HandyGames can identify the User and his or her requests during the use of the Services. In addition, relevant data is used in order to gain knowledge on malfunctions or on an abuse of the Services. HandyGames also uses personal data in the course of ending the contractual relationship with a User to the extent necessary to terminate the obligatory relationship.
  4. HandyGames may give Users the opportunity to register for the Services via Facebook Connect. In this case, HandyGames may collect, process or use data, the User published in his or her Facebook profile. Vice versa HandyGames may submit information on the participation in the Services to Facebook. Such information and other personal data may be made publicly accessible on Facebook for other Facebook users. Please review the data protection declaration of Facebook on this.
  5. When using the Services, HandyGames collects information on how you use the Services in order to enable and bill for the proper and contractual use of the Services („usage data“). Usage data is, in particular, characteristics for purposes of identifying the User, information concerning the beginning and end, as well as the scope of the respective use, IP-address, used device, particular identifiers of the device and information concerning the Services used by the User. For example, the location of the Users could be identified and, when communicating with other Users of the Services, the location could be transmitted to these other Users together with the information you send to them.
  6. HandyGames may collect and use payment data insofar as this is required for billing. In order to conduct In-App purchases such as the purchase of virtual goods, HandyGames currently works with payment-providers such as Google or Apple. In this case, HandyGames is entitled to transfer any data which is required for billing the Services via a third party payment provider to that provider, if applicable. Some payment providers may collect the necessary billing data directly from the User. In such cases, the terms and conditions and data protection declarations of those payment providers apply. In addition to that, HandyGames may involve offer based services, such as SponsorPay, which collect the User-ID of each User and/or the User’s unique identifier. Such User-ID or unique identifier cannot be connected to an individual by the offer based services provider. Further to that, HandyGames will not pass on User data, or the content of private messages in Services, to any third party unless required by law or if the User has consented to it.
  7. HandyGames is entitled to transmit and store personal User data to bodies in other member states of the European Union or within the European Economic Area, as well as to bodies in other states that guarantee an adequate level of data protection exclusively for the purposes stated in this Privacy Policy. Besides that, HandyGames will not transmit personal data of Users to any third parties unless explicitly set out in this Privacy Policy.

3. Advertising

  1. Services may be partly financed through advertising. Advertising messages may therefore appear throughout the use of the Services. HandyGames may display personalized advertising matched to the actions you perform and content you upload when using the Services.
  2. HandyGames will only send third party advertising to your e-mail address upon your prior consent.

4. Data logging for internal system purposes and statistical purposes

HandyGames automatically records information, namely usage data. For advertising, market research, improvement of existing and creation of new innovative products, HandyGames may create aggregated anonymized data. Besides that, HandyGames uses the tools Flurry Analytics and Google Analytics to track the usage of the Services in order to optimize the Services for the Users. All data is used in anonymized form.

Google Analytics is a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “Cookies”, text files, which are stored on the User’s device and which enable an analysis of the use of the Services by the User. By activating IP anonymization on the Services, the IP address of the User will however be shortened by Google within the member states of the European Union or other contracting states of the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a server in the US and shortened there. Google will, on behalf of HandyGames, use the information to analyze the use of the Services by the User, in order to compile reports about the activities of Users on the Services and in order to provide further services associated with the use of the Services and the internet. Google will in no way combine the IP address of a User with other data of Google. Users can prevent the installation of the cookies by a corresponding setting of the browser software; HandyGames however points out that in this case Users can if applicable not use all functions of the Services of HandyGames in full. The Users can object to the collection and use of their IP address by Google Analytics by downloading and installing the browser plugin available here:

Alternatively to using the browser plugin or in the browser on mobile devices, you may click the following link to prevent the collection by Google Analytics in the future:

[INSERT MOBILE OPT-OUT LINK]

Flurry Analytics is an analytics tool provided by Flurry Inc., 360 Third Street, Suite 750, San Francisco, CA 94107, USA (“Flurry”) which can be used for collecting and storing interaction and session data of the Services. Flurry will use the information to analyze the use of the Services by the User, in order to compile reports about the activities of Users on the Services. The information is used to improve the content and usability of the Services and to optimize them. Please note that cookies are used for that purpose. The session and interaction data are processed at no time in personal form but anonymously. The collection of your information by the Flurry Analytics’ technology and the processing of this data can be prevented for the future by clicking on the following link and following the description given:

5. Communication between Users

Please note that if you upload content within the Services, this information may be publicly accessible and can be seen by other Users. Therefore, be careful with the information you disclose to other Users.

6. Social Plugins

The Services of HandyGames use so-called plugins of the company Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). This allows you to recommend these Services to friends on Facebook. For example, if the „Like“ button is clicked, the information is displayed on Facebook that you recommend our Services.

If you visit our Services, which contain such a social plugin of Facebook, your device establishes a direct connection to the servers of Facebook. The content of the social plugin is transferred directly by Facebook to your browser which embeds the latter into the Services. Therefore we have no influence on the data Facebook is collecting with the help of this social plugin and we inform you according to our state of knowledge: Facebook is, through the integration of the social plugin, aware which of the Services you did access. While you are logged in to your Facebook account, Facebook can assign your visit to your Facebook account. If you interact with the social plugin, such as click on the “Like” button or leave a comment, the corresponding information with this interaction is transmitted from your device directly to Facebook and is stored there. If you have no account on Facebook your IP address will be, according to Facebook, anonymously stored in Germany. If you have an account on Facebook and you do not wish that Facebook collects information about you through this Services you must log out of your Facebook account before using the Services.

For more detailed information for what purpose and to what extent Facebook uses your data as well as your rights with respect and settings options for protecting your privacy please refer to the Facebook privacy policy at https://www.facebook.com/about/privacy/.

7. Data Security

HandyGames would like to point out that data protection and data security cannot be guaranteed for data transmissions outside of our sphere of authority, such as your mobile network. You are aware that your mobile carrier, or unauthorized third parties may have access to the data stored on the servers or transmitted through HandyGames and used in the Services.

8. Rights of Users

Upon request, HandyGames will promptly inform you about all data collected with reference to your person free of charge. This information will generally be provided in electronic form, usually via e-mail. Furthermore you can contact HandyGames if you want to correct your data because it is false or if you request the blocking or deletion of data with reference to your person.

In such cases, please send HandyGames an e-mail with your request to: support@handy-games.com.

9. Declaration of Consent

By using the Services, you consent to the abovementioned collection, processing and use of your data.

10. Amendment of the Privacy Policy

HandyGames reserves the right to amend this Privacy Policy at any time, but HandyGames will always preserve the principles of data protection as stated above. Therefore, HandyGames recommends that Users review the current Privacy Policy regularly, which will be published on the respective website. HandyGames will inform the Users in advance before a use of personal data exceeding this declaration takes place.

Giebelstadt, 12. Oktober 2014