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Data Privacy Statement
THQ Nordic Mobile GmbH

We are committed to complying with legal data protection regulations and strive to always adhere to the principles of data avoidance and data minimization.

Name and address of the controller and the data protection officer

a) The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states of the European Union as well as other data protection regulations is:

  • THQ Nordic Mobile GmbH
  • i_Park Klingholz 13
  • 97232 Giebelstadt
  • Phone: +49 9334 9757–0
  • Telefax: +49 9334 9757–19
  • E-Mail: info@thqnordicmobile.com

b) The data protection officer of the controller is:

2. Glossary

We have designed our privacy policy according to the principles of clarity and transparency. Should any ambiguities remain regarding the use of various terms, the corresponding definitions can be found here https://dsgvo-gesetz.de/art-4-dsgvo/.

3. Legal basis for the processing of personal data

We process your personal data, such as your first and last name, email address, and IP address, only if there is a legal basis for doing so. According to the General Data Protection Regulation (GDPR), the following regulations are particularly relevant:

  • Article 6 paragraph 1 sentence 1 letter a GDPR: The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Article 6 paragraph 1 sentence 1 letter b GDPR: Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Article 6(1)(c) GDPR: Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Article 6(1)(d) GDPR: Processing is necessary to protect the vital interests of the data subject or of another natural person.
  • Article 6(1)(e) GDPR: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Article 6(1)(f) GDPR: processing is necessary for the purposes of the legitimate interests pursued by the controller 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, in particular where the data subject is a child.

However, at the relevant points in this privacy policy, we will always remind you of the legal basis on which your personal data is processed.

4. Disclosure of personal data

he transfer of personal data also constitutes processing within the meaning of section 3 above. However, we would like to inform you separately about the issue of transferring data to third parties. The protection of your personal data is very important to us. For this reason, we are particularly careful when it comes to transferring your data to third parties.

Data is only shared with third parties if there is a legal basis for processing. For example, we share personal data with individuals or companies that act as data processors for us in accordance with Article 28 of the GDPR. A data processor is anyone who processes personal data on our behalf – that is, in particular, under our instructions and control.

In accordance with the GDPR regulations, we conclude a contract with each of our data processors to obligate them to comply with data protection regulations and thus guarantee comprehensive protection for your data.

5. Storage period and deletion

We store all personal data that you provide to us only for as long as it is needed to fulfill the purposes for which this data was provided, or as long as required by law. Once the purpose has been fulfilled and/or the statutory retention periods have expired, the data will be deleted or blocked by us.

What data do we have about you, what data is visible to us, and what happens to your personal data?

6.1. When starting the app

Our app offers the opportunity to earn rewards by watching short advertisements. However, to provide this feature, we need to contact our advertising partners' servers when you launch the game. This involves exchanging your data, which may include information such as your device ID or IP address.

Without this exchange, we are unable to provide you with this feature. Sharing your data is therefore necessary for us to fulfill our contractual obligations to you, as our app would not function without this feature. This processing is therefore based on Article 6(1)(b) GDPR. Furthermore, without these advertisements, we cannot provide you with our app at all. This data processing is also based on our legitimate interest, which is not overridden by any right or interest of yours, so the data processing is based on Article 6(1)(f) GDPR.

We work with the following advertising providers. To give you more information, we have also linked the privacy policies and further details about each provider.

Unity Ads

is a service of Unity Software Inc., 116 New Montgomery St, Suite 300, San Francisco, CA 94105, USA;
German office: Unity Technologies GmbH c/o Design Offices Munich, Campus Königsplatz, Brienner Str. 45, 3rd floor, 80333 Munich.
This provider processes, among other things, your device ID and IP address.
Contact form: https://unity.com/contact-us
Privacy policy: https://unity.com/legal/privacy-policy

Chartboost

is a service of Chartboost Inc., 85 2nd Street, Suite 100, San Francisco, CA 94105, USA;
European office: Chartboost Inc., Paleisstraat 1, 5th Floor, 1012 RB Amsterdam, Netherlands.
Contact form: https://www.chartboost.com/contact-us/
GDPR FAQ: https://answers.chartboost.com/en-us/articles/115001489613
Terms of Use: https://answers.chartboost.com/en-us/articles/200780239
Privacy Policy: https://answers.chartboost.com/en-us/articles/200780269

ironSource

is a service provided by ironSource Ltd., 121 Menachem Begin, Azrieli Sarona Tower, Tel Aviv, Israel;
European office: ironSource Ltd., 56–60 St John Street, Grant House, London, England.
This provider processes, among other things, your device ID and IP address.
Contact form: https://www.ironsrc.com/contact/
Privacy policy: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Fyber

is a service provided by Fyber NV, Johannisstraße 20, 10117 Berlin, Germany, Tel.: +49 30 6098555-0; Email: info@fyber.com.
This provider processes, among other things, your IP address.
GDPR FAQs: https://www.fyber.com/gdpr-faqs/
Privacy Policy: https://www.fyber.com/legal/privacy-policy/

AdColony

is a service provided by AdColony Inc., 11400 W. Olympic Blvd., 12th Floor, Los Angeles, CA 90064, USA;
German office: AdColony Inc., Neue Schönhauserstraße 3-5, 10178 Berlin.
This provider processes, among other things, your device ID.
Contact form: https://www.adcolony.com/contact-us/
GDPR FAQ: https://www.adcolony.com/gdpr/
Privacy policy: https://www.adcolony.com/privacy-policy/

Google

AdMob is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, 94043, USA;
German office: Google LLC, Unter den Linden 14, 10117 Berlin; Tel.: +49 30 303 986 300.
Contact information: https://www.google.de/contact/
GDPR information: https://support.google.com/admob/answer/7666366
Google's privacy policy: https://policies.google.com/privacy?hl=de&gl=ZZ

6.2 When logging in via a Google Play or Apple Game Center account

In our apps, you have the option to log in with your Google Play Store or Apple Game Center account. This unlocks additional features such as achievements and leaderboards. During the login process, your data is transmitted to Google or Apple. We do not otherwise process this data and have no access to the data you transmit. This transfer of your data is based on Article 6 Paragraph 1 Sentence 1 Letter b GDPR, as this transfer is necessary to provide the Play Store and Game Center features and occurs at your request. Furthermore, this transfer is based on Article 6 Paragraph 1 Sentence 1 Letter f GDPR, as we have a legitimate interest in providing these features and no overriding interests or rights of yours conflict with this. In particular, this transfer occurs exclusively at your initiative.

Further information on data processing by Google and Apple can be found in their respective privacy policies:
Google: https://policies.google.com/privacy
Apple: https://www.apple.com/de/privacy/

7. Google Firebase and Analytics

Using Google Firebase

We use Firebase from Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, 94043, USA for our app, so certain data such as your IP address, your device ID, etc. are processed in a database on Google Firebase's servers.

In this context, we do not process any of your personal data, but only use anonymized data sets from all users of our app to optimize our app. You can find more information about Firebase in the Google Firebase Terms of Service here:
https://firebase.google.com/terms/

The legal basis for processing this data is our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR, as we constantly want to improve our app and create a better and more pleasant user environment for you.

7.2. Use of Google Analytics

In some of our apps, we use Google Analytics, an analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter referred to as "Google". Google Analytics uses cookies in this context (see section 8). The information generated by the cookie about your use of the app, such as

  • Name and version of the device used
  • Device operating system
  • IP address of the requesting device
  • Time of server request

are usually transferred to a Google server in the USA and stored there.

Since we have activated IP anonymization in our app, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

On our behalf, Google will use this information to evaluate your use of our app, to compile reports on app activity, and to provide us with other services relating to app and internet usage. The IP address transmitted by your device as part of Google Analytics will not be merged with other Google data.

8. Rights of the person concerned

You have the following rights:

a. Information

In accordance with Article 15 of the GDPR, you have the right to request information about your personal data processed by us. This right of access includes information about

  • the processing purposes
  • the categories of personal data
  • the recipients or categories of recipients to whom your data has been or will be disclosed
  • the planned storage duration or at least the criteria for determining the storage duration
  • the existence of a right to rectification, erasure, restriction of processing or objection
  • the existence of a right to lodge a complaint with a supervisory authority
  • the origin of your personal data, if it was not collected from us
  • the existence of automated decision-making, including profiling, and, where applicable, meaningful information about its details.

b. Correction

According to Article 16 of the GDPR, you have the right to immediate rectification of inaccurate or incomplete personal data stored by us.

c. Deletion

According to Article 17 of the GDPR, you have the right to request the immediate erasure of your personal data from us, unless further processing is necessary for one of the following reasons:

  • The personal data are still necessary for the purposes for which they were collected or otherwise processed.
  • to exercise the right to freedom of expression and information
  • for compliance with a legal obligation which requires processing under the law of the European Union or of the Member States to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • for reasons of public interest in the area of ​​public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, insofar as the right referred to in point (a) is likely to render impossible or seriously impair the achievement of the objectives of this processing.
  • for the establishment, exercise or defense of legal claims

d. Restriction of processing

In accordance with Article 18 of the GDPR, you can request the restriction of the processing of your personal data for one of the following reasons:

  • They dispute the accuracy of your personal data.
  • The processing is unlawful and you object to the deletion of your personal data.
  • We no longer need the personal data for the purposes of processing, but you need it to establish, exercise or defend legal claims.
  • You object to the processing pursuant to Article 21(1) GDPR.

e. Instruction

If you have requested the rectification or erasure of your personal data or a restriction of processing pursuant to Articles 16, 17(1) and 18 of the GDPR, we will communicate this to all recipients to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort. You can request that we inform you about these recipients.

f. Transmission

You have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to request the transfer of this data to a third party, provided that the processing was carried out using automated procedures and is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR.

g. Cancellation

In accordance with Article 7(3) of the GDPR, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. We will no longer be permitted to process data based on your withdrawn consent.

h. Complaint

According to Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes the GDPR.

i. Contradiction

If your personal data is processed based on legitimate interests pursuant to Article 6(1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, provided there are grounds relating to your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which we will implement without requiring you to specify your particular situation. If you wish to exercise your right to withdraw consent or object, simply send an email to mailto:info@thqnordicmobile.com

j. Automated decision-making in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  • is necessary for the conclusion or performance of a contract between you and us
  • is permitted under the laws of the European Union or the Member States to which we are subject, and these laws contain appropriate measures to safeguard your rights and freedoms and your legitimate interests.
  • with your express consent

Changes to the privacy policy

Should we change the privacy policy, this will be indicated in the app.

Effective: September 20, 2018