Koch Media is serious about protecting users’ privacy and personal data. Our data protection practices comply with the legal regulations of the respective country of residence and the EU General Data Protection Regulation (GDPR). We process your data only for the purposes described herein. We will only collect the information we need to provide our services to you and to pursue our legitimate interests. We will not send you advertising nor will we share your information with third parties without your consent or other legal basis.
If you have further questions or comments regarding privacy or to assert your legal rights, please contact Koch Media’s data protection officer,
Mr. Liang Zhang
to reach below
Koch Media GmbH
Lochhamer Str. 9
Tel .: +49 89 24 24 5 405
Fax .: +49 89 24 24 5 3405
1. Personal and non-personal data
What data Koch Media collects depends on what services you use. We collect personal as well as non-personal user data. Personal data collected by Koch Media is discussed in Section A below. Non-personal data is discussed below in Section B.
The data controller of the collected personal data is Koch Media GmbH, Gewerbegebiet 1, 6604 Hoefen, Austria.
A. Personal Data collected by Koch Media
What is Personal Data
Personal Data means any information relating to an identified or identifiable natural person. Personal Data is one that identifies you directly or indirectly (also in conjunction with other data) and that can be used to contact you online or offline.
How does Koch Media collect Personal Data?
Koch Media collects and uses Personal Data of our users only insofar as it is necessary for the provision of our services and to fulfill our obligations. The collection and use of Personal Data takes place regularly only with your consent. An exception applies to cases in which prior consent is not possible or where the processing of the data is permitted by law, for example in pursue of our legitimate interests.
Lawful grounds for the processing of your data
Insofar as we obtain the consent of the data subject for processing of Personal Data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as lawful ground.
If the processing of Personal Data is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO serves as lawful ground. This also applies to processing operations prior to entering into a contract.
Insofar as processing of Personal Data is required to fulfill a legal obligation that is subject to our company, Art. 6 para. 1 lit. c DSGVO serves as lawful ground.
If processing is necessary to pursue the legitimate interests of our company or a third party, and if the interests, fundamental rights and freedoms of the data subject do not prevail over our interest, Art. 6 para. 1 lit. f DSGVO serves as lawful ground for processing.
How long will your data be stored / Revocation of consent
Your Personal Data will be deleted or blocked as soon as the purpose of processing is achieved. It may also be stored if provided for by the European or national legislator in EU regulations, laws or other regulations to which we are subject. Blocking or deletion of the data also takes place when a storage period prescribed by the laws mentioned expires, unless there is a need for further storage of the data for conclusion or fulfillment of the contract. Is the right to process Personal Data based on your consent in accordance with Art. 6 para. 1 lit. a GDPR the data will be deleted or blocked as soon as the purpose of the storage is canceled or if you revoke your consent. A revocation is possible at any time. Please contact our data protection officer for any inquiries. For more information please see Your Legal Rights.
What kind of Personal Data is collected by Koch Media
What Koch Media collects depends on the service you use:
You can create an online account for our games to play online and / or to enhance your gaming experience. For this we collect and process your data when registering and creating the account. These include for example
– e-mail address;
– postal address;
– date of birth;
– mobile phone number;
– payment information.
When you participate in online multiplayer games, your game-related profile information, game data, and stats are public. You can interact with your teammates in a variety of ways. We log the game data to ensure the stability and technical improvement of our games and for backup purposes. Personal Data can also be stored in this process. These data are collected only for the purposes stated above and will not be passed on to third parties.
We collect information about which games are played, information about the playing time and which advertisements or links are clicked on. A personal identification of the user is based on the data stored in the cookie.
Some of our services and / or products require an online account. As far as you voluntarily use our online services, we process your data with your consent in accordance with. Art. 6 para. 1 lit. a GDPR.
You may delete your user account and/or your public information at any time.
Social Media Linking
Koch Media uses its own metrics analysis tools and other analytic technologies to collect non-personally identifiable information when you use our online products and services or play our games on your PC, console and mobile device. This is for analysis and statistics purposes. A user-based profile is not created. For more information see Cookies / Pixels.
When you visit our websites, access data is recorded in the log file on our servers. We record: Internet protocol, address / IP address, page from which the file was requested, date, time, browser type and operating system, page visited, data transfer, access status (file transfer, file not found, etc.).
We use the log files to ensure the functionality of the website, to monitor traffic on our websites, to resolve technical issues, and to generate statistics that help us tailor our services to your needs. This is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.
We do not store this data together with other Personal Data of the user. If it comes to an abuse of our websites, we can block IP addresses if necessary. The data is stored only for a limited period of time and only for as long as necessary to ensure the safety and functionality of our websites.
On our websites, we use active Java Script content from external providers. By visiting our websites these external providers may receive Personal Data about your visit. In this case, processing of data outside the European Economic Area (EEA) is possible. You can prevent this by using a java script blocker such as install the browser plugin ‘NoScript’ (www.noscript.net) or disable java script in your browser. This can lead to functional restrictions on websites
Registration / Customer Service
When you register for a Koch Media service or call our support team, Koch Media collects and uses necessary data to provide the service. This may include information such as name, company name, e-mail address, telephone number, mailing address or payment information. We only store them for as long as we need them to provide the respective service.
E-mail contact / contact form
You can contact us by e-mail or through our contact form at any time. In this case, the Personal Data transmitted by e-mail or with your inquiry will be stored. The data is used exclusively for communication.
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. This is e.g. the case when the respective communication is finished.
You can object to the storage of your data at any time or revoke your consent.
You can sign up for our free newsletter on our websites. In addition to your e-mail address, we collect and save the time of the submission of your consent. Only then can we document that you have voluntarily registered.
Your data will not be shared and will only be used to send newsletters.
If you purchase goods or services on our web pages and deposit your e-mail address, this can subsequently be used by us for sending a newsletter. In such a case, the newsletter will only send direct mail for our own and similar goods or services.
Our newsletters includes a so-called “web beacon”. This is a pixel-sized file that we use to analyze the reach and success of our newsletter and tailor it to your needs. This is our legitimate interest pursuant Art. 6 para. 1 lit. f GDPR. This data will only be forwarded to us anonymously. A user analysis is not possible on the basis of this data.
We store your data only as long as the subscription to the newsletter is active. You can cancel the subscription at any time. You will find a unsubscribe link in each newsletter.
Public information (online multiplayer games, community forum, blogs, Facebook, Twitter, etc.)
For all public information, including user-generated content, the following applies:
You can decide whether to post information about yourself on Koch Media websites or in games, in public online chat rooms, blogs, forums, message boards, or similar forums on our pages or other social media platforms. Everyone can have access or view this public information. Information that you provide in this form is public information and you must not expect privacy or confidentiality.
Please make sure your privacy settings reflect your attitude.
You may object to your data being processed by Koch Media at any time or revoke your consent. For more information, see Your Legal Rights.
Sales of products
For the distribution of our own or partner products we process personal data which we have collected directly from you or which has been collected by a third party and subsequently transmitted to us. We need this information, among other things, to process the payment and deliver the products.
Inventory, usage and statement data are, if necessary, also processed beyond the fulfillment of a contract. Koch Media reserves the right to save IP addresses and log files for a limited period of time after using the website. This is to monitor and control that you comply with our terms and conditions, in particular to ensure proper execution of the payment you have authorized. This process serves, in particular, to prevent or clarify cases of abuse and, in certain cases, to transmit this data to the competent authorities. To enforce regulatory compliance, IP addresses and console IDs, if available, can be used to personally identify you. Incidentally, any other evaluation of the data takes place anonymously. If no law enforcement action is taken and no abuse pre-trial has been initiated, the IP addresses, log files and related Internet information will be stored for a maximum of six months under our statutory data retention obligation.
Cookies / Pixels
– to offer our services;
– to ensure that our websites function properly;
– learn more about our users and their interests;
– and to make interesting offers and inform about our services.
Cookies are small files that are used in your internet browser to track movements within web pages and to allow analysis of web page usage. We may associate Cookie information with personally identifiable information.
The processing of Personal Data using Cookies and similar tracking technologies serves our legitimate interest and is based on Art. 6 para. 1 lit. f GDPR.
Restrict / Deactivate Cookies
Most browsers are automatically set to accept Cookies. If you do not wish to have Cookies stored on your computer or to be informed about their storage, you can prevent the installation of Cookies by adapting your browser software accordingly. In your browser settings, activate the option “Do not accept cookies” or “Do Not Track” (different depending on your browser). The instructions of your browser manufacturer will give you more information on how this works. However, we would like to point out that by preventing Cookies you may not be able to use all the functions of the website to the fullest extent.
We also use Flash Cookies – also known as “locally shared items” – on our websites. Flash Cookies are small files, much like browser cookies, and are used to customize the design of web pages and store those requests. Flash Cookies only collect aggregated data. Like normal Cookies, Flash Cookies are small files on your computer. You can prevent Flash Cookies by adjusting your settings in the Macromedia Website Privacy Settings panel at www.macromedia.com.
Technically necessary Cookies
Analysis, tracking and advertising cookies
Koch Media uses its own metrics analysis tools and other analytic technologies when you use our online products and services or play our games on your PC, console and mobile device. These data are anonymous and not personal.
Third Party Cookies
Third Party Advertising Services
Google’s retargeting tools
Our websites use Google Inc.’s Google AdSense Resale Technology, 1600 Amphitheater Parkway Mountain View, CA 94043, USA (“Google”). This technology enables targeted ads to be shown to users who have already visited our online services and are interested in our services. Likewise users who are similar to the visitors of our websites can be addressed. Advertising is displayed using cookies. The information generated by the Cookie about the use of the website is transmitted to Google’s servers in the USA and stored there. If the IP address is transmitted, it will be shortened by the last 3 digits. With Cookies, the user behavior on a website can be analyzed and then used to deliver targeted product recommendations and advertising based on the interests of the user.
Google Tag Manager
Koch Media uses the Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage web page tags from one interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect personally identifiable information. The tool triggers other tags, which may collect data. Google Tag Manager does not access this data. If disabled at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager.
Koch Media uses Google Analytics, a web analytics service provided by Google Inc. “1600 Amphitheater Parkway Mountain View, CA 94043, USA (” Google “). The use includes the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID, thus analyzing the activities of a user across devices. These tools use “Cookies”, which are text files placed on your computer that allow the website to analyze how users use the website.
The information generated by the Cookie about the use of the website (including your IP address) is transmitted to and stored by Google’s servers in the United States or in certain other countries. If IP anonymization is enabled, Google will, for IP address within a Member State of the European Union and other parties to the Agreement on the European Economic Area, abbreviate / anonymize the last eight digits of the IP address. Only in exceptional cases will the full IP address be sent and shortened to Google servers in the United States or certain other countries. Google will use this information on behalf of the website’s provider to evaluate your use of the website, to compile reports on the website activity for website operators and to use the website provider other services related to website activity and the Internet Use.
Our legitimate interest in data processing also lies in these purposes.
Please note, however, that you will not be able to use the full functionality of this website. In addition, you can prevent the collection and use of data (cookies and IP addresses) by downloading and installing the browser plug-in at https://tools.google.com/dlpage/gaoptout?hl=en-US. Opt-out cookies prevent future collection of your data when you visit this website.
To prevent Universal Analytics tracking across devices, you must opt-out on all systems you use.
For more information, see Cookies.
Koch Media uses social media plugins. For example, the “Like” button from the social networking site facebook.com. These plugins are operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins can be identified by one of the Facebook logos.
When an user accesses one of our web pages containing one of these plugins, the internet browser connects directly to the Facebook servers. Facebook sends the contents of the plugins directly to the user’s browser and back.
If you have activated scripts in your browser and have not installed a script blocker, your browser will forward your Personal Data to Facebook without any separate request. If logged-in, an immediate assignment of the data to the Facebook profile is possible. Since we have absolutely no control over the amount of data that Facebook collects with the help of these plugins, we would like to inform the user about our current level of knowledge:
If you do not want Facebook to collect data from the Koch Media website and link it to the information stored on Facebook, please log out of your Facebook account before visiting our websites and block the execution of Facebook script content in your browser.
If you are not logged in to Facebook or have not (yet) agreed to your data being collected and used, you should not click on Facebook plug-ins.
Koch Media also uses Facebook Pixels. The Facebook Pixel is part of the code implemented in our website. Its goal is to show conversions (it shows which devices were used by a user in an action) to create a so-called lookalike audience (ie, to reach users with advertisements that have features similar to other customers and to generate comprehensive statistics on the use of our website.
When you visit our website, the Facebook Pixel creates a direct link to the Facebook servers. In this case, the Facebook server will be informed that you have visited our website and Facebook will assign this information to your personal Facebook profile. This process is designed to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and may help to optimize future advertising efforts.
Our legitimate interest in data processing also lies in these purposes.
The data collected is anonymous to us, so do not provide us with any conclusions about the identity of the users.
For more information see Cookies.
Further information about the collection and use of your personal data via Facebook as well as your rights and options can be found here: https://www.facebook.com/about/privacy/. How to disable the feature is explained here: https://en-en.facebook.com/business/help/1415256572060999?helpref=uf_permalink. For this you must be logged in with your Facebook account.
Twitter conversion Tracking
We use Twitter Inc.’s Conversion Tracking Service, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). This tracking records when a user of our website clicks on a link posted by Twitter. In this way, we and Twitter can see if a login has taken place. The identity of the user remains anonymous. In addition, we use the Tailored Audiences Service from Twitter. This allows us to approach our website users with targeted ads. To do this, Twitter uses a code snippet (tag) that we have integrated into our website. During this process, no personal data will be collected. Tailored Audiences is also used to create meaningful target lists.
This is also our legitimate interest in processing your data.
You can customize your privacy settings for custom ads at this link: https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-ads
Twitter also supports “Do not Track” (DNT). If you have activated this option in your browser, Twitter will not receive browser-related information (browser cookie ID) from web partners with which it can tailor ads for you.
Mobile Tracking Technologies
In our mobile apps we use so-called mobile tracking technologies. We use these services to collect data about the use of our apps so we can constantly improve our offerings. When using our apps, the data you submit will be collected and analyzed.
In this regard, the following data is compiled: IP address that is immediately anonymized, MAC address, anonymized device ID (identifier for advertisers – IDFA or Google Advertiser ID – GAID), browser type, language settings, ISP, network status, time zone , URL of entry and exit pages, date of access and time, clickstream data and other statistical information about the use of our services.
A direct individual identification based on this data is not possible. The data collected in this way is used to create anonymous user profiles. The data collected by the tracking technologies will not be used to personally identify a visitor to our web pages without his express consent. The capture and storage of the data can be disabled at any time with future effect by adjusting your mobile device’s settings as follows:
If it’s an Apple mobile device (IFDA): Open your mobile device settings (such as iPhone or iPad) and select the “Privacy” menu item. Under “Advertising,” you can turn off ad tracking.
For Android devices: Open the settings in your app list and tap the “Show” button. If the ad window is open, you can disable the Google Advertising ID.
You can also reset your IFDA or Google Ad ID or assign a new one in the settings.
Your Legal Rights
You can revoke a given consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.
You can also request information from us at any time as to which Personal Data we process from you (Right of Access, Art. 15 GDPR). Insofar as the data concerning you is incorrect or incomplete, you have a Right of Rectification (Art. 16 GDPR). In certain cases, you have the right to request a restriction of processing. Details can be found in Art. 18 para. 1 DSGVO.
You can demand that the Personal Data concerning you shall be deleted immediately (Right to Erasure, Art. 17 GDPR). In particular, we are required to immediately erase this information if the data is no longer necessary for the purposes for which it was collected or if you revoke your consent. Further deletion obligations can be found in Art. 17 para. 1 DSGVO.
If you have the right to rectify, delete or restrict the processing by us, we are obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort (Notification Obligation, Art. 19 GDPR). You also have the right at any time, for reasons arising from your particular situation, to prevent and object the processing of your Personal Data, pursuant to Art. 6 para. 1 lit. e or f DSGVO.
You also have the right to receive personally identifiable information you provide to us in a structured, common and machine-readable format. You also have the right to transfer this data to another person without hindrance (Right to Data Portability, Art. 20 GDPR).
Without prejudice to any other administrative or judicial remedy, you have the right to file a complain to a supervisory authority, in particular in the Member State of residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is violates the GDPR.
Please direct your data protection request to the data protection officer of Koch Media.
B. Non-personal information collected by Koch Media
Non-personal data cannot be used to identify or contact you. Koch Media collects non-personal data about your use of our online, off-line and mobile games and services both on our website and in the course of game play and software usage (on PC, mobile and console platforms).
Koch Media may collect certain non-personal data including gender, zip code, information about your computer, hardware, software, such as your hardware settings and components, platform, media, browser information, including your browser type and the language you prefer, referring and exit pages, including landing pages and pages viewed and used devices including device event information, including crash reports, request and referral URL’s and system activity details (e.g. whether you encountered an error playing our games or lost internet access). We also collect other Non-personal data such as feature usage, game play statistics and scores, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles or through purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies that we use to supplement personal data provided directly by you.
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.
In addition to personal information, Koch Media collects, among other things, non-personal information when you actively enter it into various online, offline or mobile activities, including online and mobile purchases, game registration and marketing surveys.
2. Security of data
We adhere to generally accepted industry standards to protect the personal information we provide in both transmission and storage.
All Koch Media employees are required to comply with data security and privacy practices, and have appropriate instructions and are trained on a regular basis.
For payment transactions, your data is encrypted using the SSL process. Our employees are not authorized to request further user data such as bank details or passwords.
Persons requiring access for technical, business, or editorial maintenance of the server and portal are legally bound by a confidentiality and non-disclosure agreement
Please note, however, that no electronic communication or electronic storage method is completely secure. We remind you that despite our high standards, information that you voluntarily provide on the Web is never guaranteed to be 100% secure. There is always the danger that third parties will gain unauthorized access. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee absolute security. Koch Media is not responsible or liable for the disclosure of data due to data transmission errors or unauthorized access by third parties.
3. Disclosure of personal data to third parties
Your personal information is shared globally with companies of the Koch Group (to affiliates, affiliates and the parent company). Due to the corporate structure, all companies of the Koch Group have a legitimate interest in the transfer pursuant to Art. 6 para. 1 lit. f DSGVO. From time to time, Koch Media employs third party contractors to collect personal data on our behalf to provide email delivery, product, or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. Koch Media will only pass your personal and/or billing-related data to third parties, external service providers and investigative authorities as far as this is required to fulfil the agreement. We ask some third party contractors, such as credit agencies or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors’ needs and preferences. When our third party contractors collect and/or have access to the personal information you provide to Koch Media, Koch Media requires that they adhere to our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement. These third parties are prohibited from using your personal data for any other purpose without your specific consent. Therefore, you may opt in to allow us to share your Personal Data with these companies and organizations that provide products or services that we believe may be of interest to you. To opt out of further communications from a marketing partner or sponsor with whom your information has been shared, please contact that partner or sponsor directly. In any case, you will be notified before your personal data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your data with that party.
In other cases, your personal information will only be disclosed to third parties with your express consent. However, we may share non-personally identifiable information (in a form that you do not personally identify) with third parties.
Koch Media may also disclose Personal Data to law enforcement agencies or the relevant civil authorities to enforce legal rights and to comply with the law, or to comply with a decision by a government agency or other competent authority, or if we have reason to believe that disclosure is required to respond to potential or actual violations or interference with our rights, property, reputation, business operations, users or others who may be harmed, or if we believe disclosures are required to protect our rights or us against fraud, or to comply with any Koch Media lawsuit, court order or legal process served.
Data transmission to a country outside the European Economic Area (EEA)
Koch Media is part of a global organization, and the computer systems on which we collect, store and use information are predominantly in the EEA. In certain circumstances, we may use data storage facilities outside the EEA (for example, in the US or Asia).
Your personal data will only be transferred to third countries if this is absolutely necessary for the fulfillment of the purpose of the contract or if you have explicitly consented to the transmission. When submitting your data to a third country, we comply in particular with Articles 44 – 49 GDPR.
More information can be found under the item Your Legal Rights.
4. Revocation / Deletion of your data
You have the right to correct or deleted data that you have entrusted with us at any time. Please send an e-mail to firstname.lastname@example.org to our data protection officer for requesting the deletion or correction of your account details. You can also make your inquiries by phone or post. We will gladly review, update or remove the information. We remind you that it is required to keep certain data for certain periods in order to settle disputes, enforce our User Agreement and technical and regulatory requirements. This data may only be deleted after periods of time specified by law.
Further information can be found under the point Your Legal Rights.
5. Non-liability for third parties
Protecting the privacy of children is particularly important to us. Koch Media understands that parents, guardians or other adults often use our family services, including for use by minors. If a child under the age of 16 (or below the minimum age in the Member State concerned, which can be lower) submits Personal Data to Koch Media and we learn that such Personal Data contains information of a child below 16 (or below the minimum age in the area, which could be lower) and there is no effective consent, we will delete the data as soon as possible. It is our policy to comply with any applicable law protecting minors.
The consent of children under the age of 16 is only lawful if the parents have given their consent. Each member state of the EU can reduce the age to a maximum of 13.
Koch Media, taking into account the available technology, makes efforts to make sure that the parents have given their consent to children. Nevertheless, we would like to make parents aware that age verifications can be technically bypassed. Please do not leave your children unattended on the Internet and explain their importance to the proper handling of their data.
8. Third Party Products and/or Services
9. Questions and comments
If you have any questions, concerns or remarks about data privacy, please contact our data protection officer Mr. Liang Zhang by email to email@example.com.