Privacy policy games

 

1.  Data protection

We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

 

This privacy policy applies to the processing of personal data ("data processing") by us when you use our online games ("games"). It explains the type, purpose and scope of data processing in the context of using the games.

 

2.  Controller and data protection officer

"Controller" 'means the legal person which, alone or jointly with others, determines the purposes and means of the processing of personal data;

 

Controller of our games is:

 

Tivola Games GmbH

Oeverseestrasse 10-12

22769 Hamburg

Website: www.tivola.de

Mail: mail@tivola.de

 

The external data protection officer of the controller is :

 

Prof. Dr. Christian Rauda

Board-Certified Attorney for Information Technology Law

GRAEF Rechtsanwälte Digital Part GmbB

Jungfrauenthal 8

20149 Hamburg

Phone +49.40.80 6000 9-0.

 

3.  General information on data processing

In the following, we would like to inform you about the general principles of data processing.

 

a.  Scope of data processing

We only process your personal data insofar as this is necessary for the provision and use of our games with their content and services.

 

b.  Legal basis for data processing

Insofar as we obtain your consent for data processing, Art. 6 para. 1 sentence 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for data processing.

 

Art. 6 para. 1 sentence 1 lit. b GDPR serves as the legal basis for data processing that is necessary for the fulfilment of a contract to which you are a party. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

 

Insofar as data processing is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 sentence 1 lit. c GDPR serves as the legal basis.

 

If the data processing is necessary to safeguard a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not outweigh the former interest, Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis for the processing.

 

c.  Storage period and deletion of personal data

Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which we are subject. Personal data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the personal data for the conclusion or fulfilment of a contract.

 

4.  Specific data processing

The following data processing takes place during our games:

 

a.  Download the games

Our games are provided via the Google, Apple and Amazon platforms. The platforms also offer the option of in-app purchases and other services of their own. We have no influence on their data processing and the respective platform operator is responsible for data protection. Their respective terms of use and privacy policy apply.

 

You can find the Google Play Store's privacy policy here: https://policies.google.com/privacy?hl=de

 

You can find the Apple AppStore's privacy policy here: https://support.apple.com/de-de/HT211970

 

You can find the Amazon.de Appstore privacy policy here: https://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=201909010 and special information regarding children here: https://www.amazon.de/gp/help/customer/display.html?nodeId=202185560

 

Some games are also offered via the following app sales platforms:

 

  • handy-games.com of www.handy-games.com GmbH, i_Park Klingholz 13, 97232 Giebelstadt (regarding the games: Animal Rescue Heros - Boulder Rush, Chess & Mate, Dog Hotel, Dog World, Dolphins of the Caribbean, Dream Job: Kid´s Doctor, Dream Job: Veterinarian, Fantasy Baby Animals, Grandpa and the Zombies, Horse Hotel, Horse World 3D, Horse World: Show Jumping, Pet Hotel, Pet World 3D, Teddy the Panda, Wildlife: Africa, Wildlife: America).
  • playaway.com of Playaway Products LLC, based in 31999 Aurora Road, Solon, OHIO, USA (regarding the games: Horse World 3D, Dog World 3D, Fantasy Baby Animals, Wildlife: America, Hippo Sports, Red Panda, Wildlife: Africa, Pet World, Dolphins of the Caribbean, Chess& Mate; Grandpa and the Zombies; Animal Rescue Heros - Boulder Rush, Max und die Geheimformel, Konzentration).

 

We have no influence on their data processing and the respective platform operator is responsible for data protection. Their respective terms of use and data protection notices apply.

 

b.  Operation of the games

The use of our games requires data processing without which the game cannot be operated. This data processing is required in particular to make the game available and playable in the first place, to recognise and correct errors, to retrieve scores or to link in-app purchases to the player account.

 

The following categories of personal data may be processed for this purpose:

 

  • Account name
  • Internal ID
  • Number and content of in-app purchases
  • Country in which the game was downloaded
  • Type of end device used (iPhone, iPad, etc.)
  • Model number
  • Operating system of the end device
  • Language settings of the end device
  • Date of the download
  • App version
  • Days since download ("Age of the account")
  • Duration of use of the game
  • Number of views of the game

 

 

Personal data is processed on the basis of the user agreement that you accepted when you opened the game for the first time and thus in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.

 

The personal data will be deleted as soon as there is no longer a reason for processing. This is typically the case when the contractual relationship ends, unless legal regulations require longer storage.

 

We use the following processors to operate the games:

 

(1) Unity

For our games

 

  • Horse World – My Riding Horse
  • Dog World – My Cute Puppy
  • Dog Hotel – Play with Dogs
  • PetWorld – Fantasy Animals
  • PetWorld – WildLife America
  • Hippo Sports
  • Teddy the Panda
  • Horse Hotel – care for horses
  • CatHotel – play with cute cats
  • PetWorld: WildLife Afrika
  • Pet World – My Animal Hospital
  • Fury Zoo 
  • Pet Hotel – My Animal Pension
  • Pet World – My animal shelter
  • Horse World – Show Jumping
  • Dolphins of the Caribbean
  • DogWorld: Dress Up
  • Oscar besucht Familie Pinguin
  • Chess & Mate
  • Grandpa and the Zombies
  • Elfcraft - Match 3 Stones
  • Hidden Objects: Pharaoh Amulet
  • Tiny Labyrinth Rats: LabRATory
  • Princess Lillifee and the Fairy Ball
  • Vincelot: A Knight's Adventure
  • Max and the Secret Formula
  • Dog Biscuit
  • Cat-A-Pult: toss 8-bit kittens
  • Salmon Race
  • Pet-A-Pult - Pixel Challenge
  • Man-At-Snow - Snow At Home
  • Pet World - My Red Panda
  • Petventures – Animal Stories
  • Wildshade: fantasy horse races
  • Buster's Journey: find objects
  • Cat Rescue Story: pet game
  • Candy Cat Tennis – 8-bit bash
  • Wordie: guess the word
  • Food It - cats idle empire
  • Wunderkröte
  • Horse Village – Wildshade
  • Hoof It! - Save the cow!
  • Concentration
  • Dreamjob Kid's Doctor
  • Dreaamjob Veterianrian
  • Puzzle fun with Capt'n Sharky
  • Puzzle with Princess Lillifee
  • Lernerfolg Grundschule
    • Lernerfolg Grundschule Schule
    • Grundschule Deutsch / Premium
    • Grundschule Englisch / Premium
    • Grundschule Mathe / Premium
  • Lernerfolg Vorschule
    • Capt’n Sharky – Erste Zahlen
    • Capt’n Sharky Buchstaben
    • Capt’n Sharky Logikspiele
    • Capt’n Sharky: Erstes Englisch
    • Prinzessin Lillifee Buchstaben
    • Prinzessin Lillifee Englisch
    • Prinzessin Lillifee Logikspiele
    • Prinzessin Lillifee Zahlen

 

we use the processor Unity Technologies S.F., 30 3rd Street, San Francisco, CA 94103, USA, ("Unity"), which provides the server storage. Further information on the processing of personal data at Unity for players and app users can be found in Unity's privacy policy: https://unity.com/de/legal/game-player-and-app-user-privacy-policy

 

(2) MS Azure Playfab Online Service

For our games

 

  • Petventures
  • Wildshade
  • Busters Journey

 

we use the processor Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 Munich, ("MS Azure"). Further information on the processing of personal data at MS Azure can be found in MS Azure's privacy policy: https://azure.microsoft.com/de-de/explore/trusted-cloud/privacy/

 

(3) Google Cloud Platform

For our games

 

  • Cat Rescue
  • Horse Village
  • Petventures
  • CatHotel
  • Cat-A-Pult
  • Chess and Mate
  • DogHotel
  • Elfcraft
  • HorseHotel
  • My Red Panda
  • PetHotel
  • PetWorld

we use the processor Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google Cloud"). Further information on the processing of personal data by Google Cloud can be found in Google's privacy policy: https://policies.google.com/privacy

 

c. Account creation

The use of some games requires the creation of an account, for others this is optional. In particular, this enables us to allocate any scores to the respective player and allows the player to play the game on different end devices.

 

The following categories of personal data may be processed for this purpose:

 

  • Account name selected by you
  • E-mail address
  • Internal ID (unique user ID that is generated when the account is created)

 

Data processing is carried out on the basis of the user agreement and thus in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.

 

Creating an account is mandatory for the following games:

 

  • Wildshade
  • Petventures
  • Horse Village
  • Busters Journey

 

Creating an account is optional for the following game:

 

  • Cat Rescue

 

In this case (without an account), however, not all functions of the game can be used.

 

d. Creation of aggregated information

We create aggregated statistical information from the personal data available to us. We use this statistical information for various purposes, such as game optimisation, improving our marketing campaigns and similar purposes. The aggregated information is no longer personal data.

 

The following categories of personal data may be used for aggregation:

 

  • Android ID
  • Device type
  • Operating system of the end device
  • Version of the operating system of the end device
  • Language setting of the end device
  • Facebook ID
  • Audio setting of the end device
  • List of other games published by Phoenix that have been played
  • Graphics settings of the end device
  • Installation source of the game
  • IP address of the end device
  • Marketing-specific attribution information (if the user has installed the game after viewing an advert)
  • Google Advertising ID
  • Apple IDFA (ID from Apple for advertisers)
  • IDFV (ID from Apple for providers)
  • Amazon ID
  • Paying user status
  • Player name
  • Days since download
  • Setting for push notifications
  • Country in which the game was downloaded
  • Date of the download
  • Version of the app that was downloaded
  • Amount of real money spent
  • Playing time
  • Number of games
  • Number of purchases
  • Country in which the user uses the app
  • Current app version
  • Date of purchase
  • Game progression

 

The creation of aggregated statistical information is based on our legitimate interest in enabling versatile analyses and evaluation of our games, Art. 6 para. 1 sentence 1 lit. f GDPR. Your interests do not outweigh this either, as the aggregation of the data removes the personal reference and thus enables data-saving further processing.

 

The aggregated information is created by the service providers assigned to the respective games in section 4. b.

 

e. Elimination of individual errors

In some cases, it is not sufficient to process only aggregated information in order to rectify game errors that occur with an individual user; it is also necessary to view and evaluate personal data.

 

Depending on the error, the following categories of personal data may be processed for this purpose:

 

  • Android ID
  • Device type
  • Operating system of the end device
  • Version of the operating system of the end device
  • Language setting of the end device
  • Audio setting of the end device
  • Graphics settings of the end device
  • Installation source of the game
  • IP address of the end device
  • Google Advertising ID (advertising ID from Google)
  • Apple IDFA (ID from Apple for advertisers)
  • IDFV (ID from Apple for providers)
  • Amazon ID
  • Paying user status
  • Player name
  • Days since download
  • Setting for push notifications
  • Country in which the game was downloaded
  • Date of download or in-app purchase
  • Version of the app that was downloaded
  • Amount of real money spent
  • Playing time
  • Number of games
  • Number of purchases
  • Country in which the user uses the app
  • Current app version
  • Date of purchase
  • Game Progression

 

Data processing is carried out on the basis of the user agreement that you accepted when you first opened the game and thus in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.

 

The processing of personal data for troubleshooting purposes is carried out by the service providers assigned to the respective games in section 4. b.

 

f.  Fraud Detection

We screen and validate personal data in order to identify any misuse of our games.

 

The following personal data may be processed for this purpose:

 

  • Android ID
  • Device type
  • Operating system of the end device
  • Version of the operating system of the end device
  • Language setting of the end device
  • Audio setting of the end device
  • List of other games published by the respective controller that have been played
  • Graphics settings of the end device
  • Installation source of the game
  • IP address of the end device
  • Google Advertising ID
  • Apple IDFA (ID from Apple for advertisers)
  • IDFV (ID from Apple for providers)
  • Amazon ID
  • Paying user status
  • Player name
  • Days since download
  • Setting for push notifications
  • Country in which the game was downloaded
  • Date of the download
  • Version of the app that was downloaded
  • Amount of real money spent
  • Playing time
  • Number of games
  • Number of purchases
  • Country in which the user uses the app
  • Current app version

 

The processing of personal data is based on our legitimate interest, Art. 6 para. 1 sentence 1 lit. f GDPR. We have an interest in detecting misuse of our games. One of the reasons for this is that misuse could also constitute violations of legal norms.

 

Processing for the purpose of fraud detection is carried out by the service providers assigned to the respective games in section 4. b.

 

g.  Advertising

We use various types of analysis and advertising tools to successfully offer advertising in our games and to place adverts on other websites.

 

The following categories of personal data may be processed for this purpose:

 

  • Android ID
  • Amazon ID
  • Apple ID
  • Type of end device used (iPhone, iPad, etc.)
  • Installation source of the game (source from which the user downloaded the app).
  • Game identifier
  • Country code
  • IP address of the end device
  • Google Advertising ID
  • Marketing-specific attribution information (if the user has installed the game after viewing an advert)
  • Paying user status
  • User name
  • Country in which the user has registered
  • Date on which the user registered
  • Time at which the user registered

 

The legal basis for the processing is your freely given consent (Art. 6 para. 1 sentence 1 lit. a GDPR). You can withdraw your consent at any time. The legality of the data processing operations that have already taken place remains unaffected by the withdrawal.

 

The personal data will be processed for advertising purposes until you withdraw your consent. If the personal data is no longer required for any further purposes, it will be deleted.

 

To display personalized advertising for the game

 

  • Horse Village

 

we use the Google Ad Mob service of the processor Google LLC at 1600 Amphi-theatre Parkway Mountain View, CA 94043, USA ("Google AdMob"). Further information on the processing of personal data by Google AdMob can be found in Google AdMob's privacy policy: https://policies.google.com/privacy

 

We use the following services to display non-personalised advertising:

 

(1)  Unity

For our games

 

  • Horse World 3D
  • DogHotel
  • Wilde Life: America
  • Horse Hotel
  • CatHotel
  • Wild Life: Africa
  • PW Tierklinik
  • PetHotel
  • PetWorld 3D
  • Show Jumping
  • Elfcraft
  • Animal Rescure Hero
  • Cat-A-Pult
  • Salmon Race
  • RedPanda
  • Petventures
  • Wildshade
  • Hidden Game AniWor Buster’s Journey
  • Cat Rescue
  • Fury Zoo
  • Candy Cat
  • Horse Village
  • Wordie
  • Hoo fit!

 

we use the processor Unity Ads of Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA ("Unity"). Further information on the processing of personal data at Unity can be found in Unity's privacy policy: https://unity.com/legal/privacy-policy

 

(2)  ironSource

For our games

 

  • Horse World 3D
  • Dog World 3D
  • DogHotel
  • Wilde Life: America
  • Horse Hotel
  • CatHotel
  • PW Tierklinik
  • PetHotel
  • PetWorld 3D
  • Show Jumping
  • Elfcraft
  • Animal Rescure Hero
  • Cat-A-Pult

 

we use the processor ironSource, Derech Menachem Begin 121, Tel Aviv 6513307, Israel ("ironSource"). Further information on the processing of personal data by ironSource can be found in ironSource's privacy policy: https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#step-1

 

(3)  Google AdMob

For our games

 

  • Horse World 3D
  • Dog World 3D
  • Dog Hotel
  • Fantasy Baby Animals
  • Wilde Life: America
  • Hippo Sports
  • Cat Hotel
  • Wild Life: Africa
  • PW Tierklinik
  • PetWorld 3D
  • Grandpa and the Zombies
  • Animal Rescure Hero
  • Cat-A-Pult
  • Salmon Race
  • Pet-A-Pult
  • Man-At-Snow
  • Fury Zoo
  • Candy Cat
  • Hoof it!

 

we use the processor Google LLC at 1600 Amphitheatre Parkway Mountain View, CA 94043, USA ("Google AdMob"). Further information on the processing of personal data by Google AdMob can be found in Google AdMob's privacy policy: https://policies.google.com/privacy

 

(4)  Vungle

For our game

 

  • Dog Hotel

 

we use the processor Vungle Limited, 4th Floor, Farringdon Point, 33 Farringdon Road, London, England, EC1M 3JF ("Vungle"). Further information on the processing of personal data at Vungle can be found in Vungle's privacy policy: https://vungle.com/privacy/

 

(5)  AppLovin

For our games

 

  • Dog Hotel
  • Cat Hotel
  • Pet Hotel
  • Show Jump

 

we use the processor Applovin Corporation, 1100 Page Mill Road, Palo Alot, CA 94304, USA ("AppLovin"). Further information on the processing of personal data by AppLovin can be found in AppLovin's privacy policy: https://www.applovin.com/privacy/

 

h.  Support requests

You can send us support enquiries. Your details will be stored by us exclusively for the purpose of processing the support enquiry and in the event of follow-up questions.

 

The following categories of personal data may be processed for this purpose:

 

  • E-mail address
  • User name
  • Contents of your enquiry
  • Operating system and version
  • Device type
  • Saved user ID
  • Money spent on in-game purchases
  • IP address
  • Place of registration
  • Location

 

The legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. f GDPR. Our interest in responding to your enquiry corresponds to your interest. Since you are writing to us, it is in your interest to receive a response and you are aware that we need to process your data in order to respond to your enquiry. If you have accepted our terms of use, the processing is based on Art. 6 para. 1 sentence 1 lit. b GDPR.

 

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. This is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

 

i.   In Game Chat

In our game

 

  • Horse Village

 

we provide a chat function as one of our services. The following data may be processed:

 

  • User name
  • Content of the chat
  • Saved user ID

 

Data processing is carried out on the basis of the user agreement that you accepted when you first opened the game and thus in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR. The chat data will be deleted as soon as the deletion has been requested by a corresponding email to the Photon in-game chat service.

 

To provide the chat function, we use the Photon in-game chat service of our processor Exit Games, Inc, 111 SW 5th Ave. STE 3150, Porland OR 97204, USA ("Photon"). Further information on the processing of personal data by Photon can be found in Photon's privacy policy:

https://dashboard.photonengine.com/account/privacyandcookiepolicy

 

j.  External links

Our games may contain links to external websites or services of third parties over whose content, data protection and security standards we have no influence. Therefore, please inform yourself on the websites or services of the respective providers about the privacy policies provided there.

 

The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognisable at the time of linking. Should we become aware of any legal infringements, we will remove the corresponding link immediately.

 

These external links are for entertainment purposes only and a visit to the relevant websites or services is not mandatory in order to play the game.

 

5.  Data processing in third countries

We sometimes use processors to provide our content and services. For technical reasons, some of these processors have servers in third countries to which connections are established in special situations. In some cases, your personal data is also processed.

 

Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, which has been confirmed by the EU Commission by means of an adequacy decision pursuant to Art. 46 GDPR, EU standard contractual clauses are concluded with the companies concerned in third countries in order to establish appropriate safeguards within the meaning of Art. 46 GDPR. A copy of the EU standard contractual clauses can be found here: https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32021D0914&from=DE. It is noteworthy in this respect that some companies from the USA are certified in accordance with the EU/US Data Privacy Framework.

 

We have concluded EU standard contractual clauses with the following processors or those processors have concluded EU standard contractual clauses with their sub-processors processing in third countries or the data is processed on the basis of an adequacy decision or on the basis of an EU/US Data Privacy Framework certification:

 

  • Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, Irland
  • ironSource, Derech Menachem Begin 121, Tel Aviv 6513307, Israel
  • Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Irland
  • Vungle Limited, 4th Floor, Farringdon Point, 33 Farringdon Road, London, England, EC1M 3JF
  • Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA
  • Applovin Corporation, 1100 Page Mill Road, Palo Alot, CA 94304, USA
  • Exit Games, Inc., 111 SW 5th Ave. STE 3150, Portland OR 97204, USA

 

6. Your rights

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights with respect to us as the controller:

a.  Right of access

In accordance with Art. 15 GDPR, you have the right to request information about the personal data we process. In particular, you can request to be informed regarding:

 

  • the purposes of the processing;

 

  • the categories of personal data concerned;

 

  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations (in this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR),

 

  • the planned storage period;

 

  • the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing;

 

  • the right to lodge a complaint with a supervisory authority;

 

  • if the personal data are not collected from you, to about the source of the personal data;

 

  • the existence of automated decision-making, including profiling, referred to in Art. 22 para. 1 and 4 GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

 

b.  Right to rectification

In accordance with Art. 16 GDPR, you have the right to have your personal data corrected and/or completed if it is incorrect or incomplete. We must carry out the correction without delay.

c.  Right to restriction of processing

In accordance with Art. 18 GDPR, you have the right to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful.

 

If the processing has been restricted, you will be informed before the restriction is lifted.

 

d.  Right to erasure

In accordance with Art. 17 GDPR, you have the right to erasure of your personal data, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims.

e.  Right to information

If you have asserted the right to rectification, erasure or restriction of processing against us, we are obliged to notify all recipients to whom the personal data have been disclosed of the rectification, erasure of the personal data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

f.   Right to data portability

In accordance with Art. 20 GDPR, you have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller.

g.  Right to object

In accordance with Art. 21 GDPR, you have the right to object to the processing if the processing is carried out on the basis of Art. 6 para. 1 sentence 1 lit. e or lit. f GDPR.

h.  Right to withdraw the consent

You have the right to withdraw your consent at any time according to Art. 7 para. 3 GDPR. The withdraw does not affect the lawfulness of prior processing carried out on the basis of the consent.

 

i.   Right to complain to a supervisory authority

In accordance with Art. 77 GDPR, you have the right to complain to a data protection supervisory authority about our processing of your personal data.

 

 

December 2023