This website is operated by Koch Media GmbH, Gewerbegebiet 1, 6604 Hoefen, Austria (“Koch Media”).
1. Collecting of Personal and non-personal Data
The data Koch Media collects depends on what products you use and how you use them. We collect both personal and non-personal user data. Personal data collected by Koch Media is discussed below in Section A. Non-personal data is discussed below in Section B. The controller of the personal data collected is Koch Media GmbH, Gewerbegebiet 1, 6604 Hoefen, Austria.
A. Personal Data collected by Koch Media
Personal data is information that identifies you and that may be used to contact you on-line or off-line. Koch Media may collect personal information from our online visitors during: Gaming and other user behavior including gaming results; Warranty registration and requests; Customer support and/or technical service requests; Player match up and other head-to-head online competitions; Registration for games and/or special game-specific events; Newsletter subscriptions, referral services, and other marketing surveys and email campaigns; Registration for Koch Media and/or other service accounts; Product, service and/or subscription orders; Service requests from third party service providers on our site; and otherwise through use of our websites, games, mobile or online services where personal information is required for use and/or participation.
The data includes information which is related or applicable to an individual person or creates a connection to that person. Information collected will vary depending upon the activity and may include your name, user name, email address, password, phone number, home address, birth date, mobile phone number, security questions and answers, demographic details for instance in response to surveys about our products, information you provide when seeking help from us such as your name and records of the issues you experience, and credit card information but will only be saved when needed and to the extent that it is necessary. Additional data such as age and hobbies may be requested within the framework of other actions (e.g., “Player of the Month”) and, published, only with your permission, on the Web or in printed media. In any case, you will be specifically notified in case of irregular collection of data. Koch Media employees are not authorized to request additional user data, such as banking information or passwords.
Any access by you of the Koch Media websites and any retrieval of a file may collect access data on this process in the protocol file on our servers and is stored as follows: Internet Protocol, address / IP address, page from which the file was requested, date, time, browser type and operating system, the page you visited, transferred data quantity, access status (file transferred, file not found, etc.). In general, we use log files to monitor traffic on our websites and to troubleshoot technical problems and to generate statistics which help Koch Media to adapt the services offered to your requirements. In the event of user abuse of our websites, however, we may block certain IP addresses.
When you participate in social features (such as chat), the information that you disclose is public information. We may store and access it, and it may be read, copied, collected or used by other users without your consent. Please make sure your privacy settings reflect your preferences.
When you participate in online multiplayer games your in-game profile information, gameplay and statistics are visible to all.
We may also receive other personal data from third parties in connection with the operation and distribution of our products, games and services that we use to supplement personal data provided directly by you. As with all other data, we use this data only for purposes consistent with this policy.
Inventory data, utilization data and statement data are collected, processed and used and this is done, as far as required, even beyond the fulfilment of an agreement. Koch Media reserves the right to store IP addresses and log files for a reasonable period of time after making use of the website to monitor whether you complies with all terms and conditions, in particular to ensure proper processing of the payment that you have authorized. This process especially serves to prevent or clarify any cases of abuse and to allow these data to be appropriately passed on to the competent authorities in specific instances. If available, IP addresses and console IDs may be used to personally identify you in order to enforce legal requirements. For the rest, as far as possible, any other evaluation of the data takes place in an anonymized form. Provided there is no pending prosecution action and no preliminary proceedings have been initiated for abuse, the IP addresses, log files and the corresponding internet information are saved for a period of maximum of six months within the scope of our legal obligations regarding data storage.
B. Non-Personal data collected by Koch Media
Non-personal data, alone, 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.
Koch Media collects non-personal data in addition to personal information inter alia when you actively provide it in the context of various online, off-line and/or mobile activities including online and mobile purchases, game registration and marketing surveys, for instance.
+ Third Party Ad Serving Technology
+ Google Remarketing
Our websites may use Google’s remarketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on the websites of the Google partner network. Likewise users that are similar to the visitors of our websites can be addressed. The advertising will be displayed using cookies. The information generated by the cookie about the website use will be transmitted to and stored on servers in the United States by Google. In the event that the IP address is transferred, it will be reduced by the last 3 digits. Using cookies, the user behavior on a website can be analyzed and subsequently utilized to provide targeted product recommendations and advertising based on the user’s interests.
If you are using our mobile Apps we may additionally use so-called mobile tracking technologies. With the help of these services, we collect data on the usage of our apps to be able to constantly improve our offers. While using our apps, information transmitted to us by your device are collected and analyzed. In this respect, the following data are gathered: IP address, which is anonymized right away, MAC address, anonymized Device ID (IDentifier For Advertisers – IDFA or Google Advertiser ID – GAID), browser type, language settings, internet service provider, network status, time zone, URL of the entry and exit pages, date of access and time spent, clickstream data, and other statistical information about the use of our services. A direct individual identification is not possible. The data collected this way are used to create anonymous user profiles. The data collected with the tracking technologies will not be used to personally identify any visitor of our websites without their explicit consent. The collection and storing of the data can at any time be disabled with effect for the future by adjusting the settings of your mobile device as follows:
In the case of a mobile device of Apple: Open the settings of your mobile device (e.g. iPhone or iPad) and select the menu item “Privacy”. Under “Advertising“ you can turn off the Ad Tracking.
In the case of Android devices: Open the settings in your App list and tap on the “Ad” button. When the Ad window has opened, you can deactivate the Google Advertising ID.
+ Analytic Metrics Tool and Other Technologies
Koch Media may use its own proprietary analytic metrics tool and other analytics technologies to collect non-personal information when you use our online products and services and/or play our games on your PC, console and/or mobile device.
+ Facebook plugins
Koch Media uses social plugins, e.g. 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 from one of the Facebook logos.
If a user accesses one of our websites that contains one of these plugins, its internet browser connects directly with the Facebook servers. Facebook sends the content of the plugins directly to the user’s browser and back. Since we have absolutely no control over the amount of data that Facebook collects with the help of these plugins, we would like to share our latest knowledge with the user:
The plugins that are incorporated mean that Facebook receives notification that the user has called up the appropriate page on our website. If the user is logged in on Facebook at the same time, Facebook can allocate the visit to the user’s personal Facebook account. If the user interacts with the plugins, such as by pressing the “like”; button or posting a comment, that information is immediately transmitted by the browser directly to Facebook, where it is saved. If the user is not using Facebook, the service can still collect and store the IP address. More information on how much data is collected and why, and how it is then processed and used by Facebook, as well as details about the users’ rights and the settings available for protecting users’ privacy, can be obtained from Facebook’s data protection policy at www.facebook.com/policy.php.
If a user has signed up to Facebook but does not want Facebook to collect data via Koch Media‘s website and link it up with the data stored on Facebook, it must log off Facebook before visiting Koch Media.
If a user does not belong to Facebook or has not (yet) consented there to having its data collected and used, do not click on Facebook plugins.
+ Facebook Pixel
Our website uses also the so-called Facebook Pixel of Facebook. The Facebook Pixel is a part of code which is implemented in our website. Its aim is to show conversions (i.e. it shows which devices have been used by an user to do an action), to create so-called lookalike audiences (i.e. to reach users with ads which have similar traits like other customers) and to generate comprehensive statistics about the use of our website. If you visit our website the Facebook Pixel directly creates a connection to the servers of Facebook. In this case the Facebook server is informed that you have visited our website and Facebook allocates that information to your personal Facebook profile. Further information about the collection and use of your personal data via Facebook as well as about your rights and possibilities can be found here: https://www.facebook.com/about/privacy/. You can deactivate the function as described under: https://en-gb.facebook.com/business/help/1415256572060999?helpref=uf_permalink. For that you have to be registered with your Facebook account.
+ Twitter Conversion Tracking
We use the Conversion Tracking service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). This tracking records if a user of our website clicks on a link posted by Twitter. In this way, both we and Twitter can see if a registration has taken place. The identity of the user remains anonymous. In addition, we use Twitter’s Tailored Audiences service. This enables us to appeal to our website’s users with targeted advertisements. To do this, Twitter uses a code snippet (tag) which we have integrated into our website. No personal data are collected during this process. Tailored Audiences is also used to create lookalike targeting lists.
2. Storage of security of personal data
We are committed to data security within the framework of applicable data protection laws. Your data are protected against unauthorized access and loss through the use of various electronic, technical, physical, administrative and contractual measures. Koch Media has taken the necessary technical and organizational precautions to ensure that the regulations for data privacy are respected both internally as well as by external service providers. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and in storage. Please note however that no electronic communications or method of electronic storage, are totally secure. We remind you that, despite our high standards, information that you voluntarily provide on the Web are never guaranteed to be 100% secure. There is always the potential danger that third persons may obtain unauthorized access. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security. Koch Media is not responsible or liable for the disclosure of data due to data transmission errors and/or unauthorized access by third parties.
3. Data processing
Once you have completed a declaration of consent, Koch Media collect, store, and process personal and Non-personal data for the purpose of individual information and management. We use your personal and non-personal information, both individually and combined together, in the following ways:
To operate our business and to enhance and personalize your game experience inter alia to: operate, improve and develop our games, websites and services, fulfill your specific requests, facilitate sharing on social networks and purchase orders, serve and measure the effectiveness of advertising, provide game experiences that you may like, facilitate your gameplay on multiple devices when available, identify, fix, and troubleshoot bugs and service errors, provide software updates and to send you purchase confirmation and other account-related information. Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies. Further to provide you support, including to: help identify and troubleshoot problems with your account or games; to survey your opinions through surveys or questionnaires; communicate with you and respond to your specific requests or questions; and manage and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties. In addition, if you choose to receive communications from us about Koch Media products and news, the personal information you provide will allow us to send you messages about things including new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest and we will personalize our communications with you, including present offers and/or information relating to games you might like, make recommendations to you; and personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
You may send Koch Media a message that you no longer wish to receive such information at any time with effect for the future (For contact information, refer to clause 11). In addition, you always have the option to de-register via a special link located directly in the information about the game or in the newsletter to stop any further receipt.
Your participation in tournaments or other online game events is also conditional upon our collection, use, storage, transmission and public display of statistical data (such as your scores, rankings and achievements) generated through your participation. For security purposes, data that could be used for identification (e.g., IP address, date, and time) are stored on our servers when you are granted access. We reserve the right to conduct statistical analysis of anonymous data sets. Personal data is not used for any other purposes, apart from legal or official requirements.
All employees of Koch Media are obliged to comply with data security and the data protection provisions and are instructed accordingly. In the event of payment transactions, your data is transferred encrypted through the use of the SSL process.
4. Sharing of personal data with third parties
Your personal data will be disclosed worldwide to companies of the Koch Group (subsidiaries, affiliates and the parental company). 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.
Payment processing takes place via external service providers (e.g. credit card companies, banks, Paypal). Your protected interests are considered according to the legal provisions. External service providers are obliged to treat your data confidentially and securely and may only use your data as far as this is required to fulfil their duties. In the event of payment arrears, Koch Media will, if necessary, instruct a collection company or a lawyer to collect the payable amount. The required data are passed for this purpose and utilized in compliance with all data protection guidelines.
In other instances, your personal data will not be shared with third parties without your express consent. We may, however, share non-personal data in the aggregate (in a form that does not personally identify you) with third parties.
Koch Media may also disclose personal data to law enforcement, or the appropriate civil authorities to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, reputation, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, fraud protection and/or comply with a judicial proceeding, court order, or legal process served on Koch Media.
5. Public Information including user Generated Content (Forums, Blogs)
6. Right of withdrawal
You may correct or delete data that you have entrusted with us at any time. Please send an e-mail requesting deletion of your account data to firstname.lastname@example.org. We will be happy to review, update or remove information as appropriate. We remind you that the remonstrance of certain data for certain periods of time is stipulated to resolve disputes, enforce our user agreement, and due to technical and legal requirements. These data may only be deleted following legally stipulated time periods.
7. Non-liability for Third Party Sites
10. Third Party Products and/or Services
11. Questions and comments
You will always have the option to require an overview including all collected data. At your request or Koch Media’s own initiative, we can complete, correct or delete incomplete, incorrect and/or outdated personal data, you will find more details regarding this matter in clause 6. “Right of withdrawal”. For any further questions, concerns, or comments on the topic of data protection, please contact Koch Media’s data protection representative Liang Zhang at email@example.com.
September 05, 2017