Headup
GmbH Privacy Policy
I.
Name and
address of the person responsible
The controller within the meaning of the General Data
Protection Regulation and other national data protection laws of the member
states as well as other data protection regulations is the:
Headup GmbH
Nordstr. 102
52353 Düren
Germany
E-mail: info@headupgames.com
Website: http://headupgames.com
II.
Name and
address of the data protection officer
Mr Frederik
Bocklaff
c/o NIMROD Attorneys
at Law
Bockslaff Kupferberg GbR
Emser Street 9
10719 Berlin
Phone: +49 (0) 30 544 61 793
Fax: +49 (0) 30 544 61 794
E-Mail: info@nimrod-rechtsanwaelte.de
III.
Definitions
1) "Personal data" means any information
relating to an identified or identifiable natural person (hereinafter referred
to as "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 (e.g. cookie) or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that
natural person.
2) "Processing" means 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.
3) The "controller" is the natural or legal
person, public authority, agency or other body which, alone or jointly with
others, determines the purposes and means of the processing of personal data.
4) "Special categories of personal data" are
data revealing your racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, health or sex life, as well as
genetic data, biometric data for the purpose of uniquely identifying a natural
person
IV.
Data processing
in our game
In the
following we inform you about the collection of personal data when using our
game. The controller pursuant to Art. 4 No. 7 GDPR is Headup GmbH, see I.
When using
our game, we do not actively collect or store personal data for tracking,
analytics, profiling or marketing purposes.
However,
certain technical data (such as IP addresses or platform-related identifiers)
may be processed automatically by the gaming platform operator in order to enable the download and operation of the game.
Such
processing is limited to what is technically necessary to deliver the game
functionality.
V.
How data is captured
Personal data is
processed only insofar as this is technically required for:
VI.
How data is used
We use personal data
solely for the purpose of providing the game and fulfilling contractual
obligations pursuant to Art. 6(1)(b) GDPR.
We do not use personal
data for advertising, analytics, profiling or marketing purposes.
VII.
How data is shared
Personal data may be
processed by the respective gaming platform operator in its own responsibility.
We do not sell, rent or commercially disclose personal data.
Please note that some
gaming platform operators may process personal data in countries outside the
European Union. Such processing is carried out under the responsibility of the
respective platform operator and subject to their applicable data protection
safeguards.
VIII.
Data retention
We do not store
personal data beyond what is technically necessary. Where personal data is
processed for technical reasons, such data is either processed temporarily
during the session or stored only as long as required by legal obligations. Support-related
communications may be stored for the duration necessary to process the request
and comply with legal retention obligations.
IX. Technical requirements, setting up an account with a
gaming platform operator
In order
to use the
content and services of Headup, you must have Internet access and a user
account with a gaming platform operator. We offer our content and services via
the following gaming platform operators, although not all content may be
available via every platform.
Please note
The controller for all data collected, used and
processed in connection with the data collected, used and processed by the
gaming platform operators is the respective gaming platform operator. The
respective gaming platform operator is responsible for the processing of
personal data within its own platform environment. Headup does not have access
to or control over such data processing. The contact details and privacy policy
of the individual gaming platform operators can be found here:
https://store.steampowered.com/?l=german
https://store.steampowered.com/privacy_agreement/german/
https://support.gog.com/hc/de/articles/212632109-Datenschutzrichtlinie?product=gog
https://www.epicgames.com/site/de/home
https://www.epicgames.com/site/de/privacypolicy
https://store.playstation.com/de-de/pages/latest/
https://www.playstation.com/de-de/legal/privacy-policy/
https://www.xbox.com/de-DE/microsoft-store
https://privacy.microsoft.com/de-de/privacystatement
https://store.nintendo.de/de/privacy-and-cookies
https://www.apple.com/de/app-store/
https://www.apple.com/de/legal/privacy/
https://policies.google.com/privacy
X.
Contact for data
protection inquiries
If you have any
questions regarding data protection or wish to exercise your rights, you can
contact us at:
Headup GmbH
Nordstr. 102
52353 Düren
Germany
Email:
info@headupgames.com
You may also contact
our Data Protection Officer at:
info@nimrod-rechtsanwaelte.de
XI.
Data subject
rights and your right to lodge a complaint with the supervisory authority
As a person affected by the processing of your personal data, you can
assert the following rights against us in accordance with the GDPR and the
respective national regulations ("data subject rights"):
1)
Rights of data subjects
a) Right to information in
accordance with Art. 15 GDPR: You have the right to request information about
the personal data stored concerning you, in particular about
- the purposes of processing
- the data categories
- the recipients to whom your
data is transferred, in particular recipients in third
countries or international organisations
- the planned storage duration
or, if not possible, the criteria for determining this duration
- the existence of a right to
rectification or erasure of the data or to restriction of processing or a right
to object to such processing
- the existence of a right of
appeal to a supervisory authority
- the origin of the data if we
have not collected it directly from you
- the existence of automated
decision-making, including profiling, and in particular meaningful information
about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject
- the appropriate safeguards
pursuant to Art. 46 GDPR when transferring your data to a third country or an
international organisation.
The exceptions according to § 34 BDSG apply.
b) Right to rectification in
accordance with Art. 16 GDPR: You can demand that we rectify incorrect personal
data concerning you without undue delay and, if necessary, complete incomplete
personal data.
c) Right to erasure in accordance
with Art. 17 GDPR: You can request that we erase your personal data if the
legal requirements for this are met. This may be the case, for example, if
- the personal data are no longer
necessary in relation to the purposes for which they were collected or
otherwise processed
- you withdraw your consent,
which is the basis for the data processing, and there is no other legal basis
for the processing
- you object to the processing of
your personal data and there are no overriding legitimate grounds for the
processing, or you object to data processing for direct marketing purposes
- the personal data have been
processed unlawfully
- the deletion of the data is
necessary to fulfil a legal obligation under Union law or the law of the Member
States
- the data was collected in
relation to information society services offered pursuant to Art. 8 (1) GDPR.
The exceptions of Art. 17 para. 3 GDPR apply.
d) Right to restriction of
processing pursuant to Art. 18 GDPR: You can request that we restrict the
processing of your personal data if
- you contest the accuracy of the
personal data for as long as we need to verify the accuracy of the data
- the processing is unlawful and
you oppose the erasure of your personal data and request the restriction of
their use instead
- we no longer need your personal
data, but you need it to assert, exercise or defend legal claims
- you have objected to processing
pending the verification whether our legitimate grounds override yours.
e) Right to data portability
pursuant to Art. 20 GDPR: At your request, we will provide you with your
personal data that you have provided to us in a structured, commonly used and
machine-readable format so that you can transfer it to another controller. However,
you are only entitled to this right if the data processing is based on your
consent or is necessary to fulfil a contract and the processing is carried out
using automated procedures.
f) Right of revocation in
accordance with Art. 7 para. 3 GDPR: You have the right to revoke your consent
to us at any time. As a result, we will no longer continue the data processing
based on this consent in the future.
g) Right to object in accordance
with Art. 21 GDPR: If your personal data is processed on the
basis of legitimate interests in accordance with Art. 6 para. 1 sentence
1 lit. f) GDPR, you have the right to object to the processing of your personal
data if there are reasons for this arising from your particular
situation or if the objection is directed against direct advertising or
against profiling, insofar as it is associated with such direct advertising. In
the event of an objection, we will no longer process your personal data unless
we can demonstrate compelling legitimate grounds for the processing which
override your interests or we need your personal data for the establishment,
exercise or defence of legal claims.
For profiling, the exception of § 37 BDSG applies.
If you wish to exercise your right of cancellation or
objection, simply send an e-mail to info@headupgames.com.
h) You also have the right under
Art. 77 GDPR to lodge a complaint with a supervisory authority. As a rule, you
can contact the supervisory authority of your usual place of residence or
workplace.
2) Deadlines for the fulfilment of data subject rights
We generally fulfil requests within one month. However, this period may
be extended due to the specific rights of the data subject or the complexity of
your enquiry. In this case, we will inform you of the reasons for this within
the one-month period.