A. Explanation of data protection at LowPolyCube
This privacy policy is an automated direct translation from the German version. The German version is to be considered as the legally binding document, this transcription is only published for you convenience.
The actual privacy policy begins under point B. (Click here to jump there directly …). Before we get into the privacy policy, however, here are a few words in advance.
I. Our philosophy
We strongly believe that a privacy policy should be understandable and provide the user with the opportunity to understand in advance what they are getting into, because we believe in a free and secure internet where everyone has full control over their data.
We have therefore set ourselves the goal of making our data protection declaration as detailed and comprehensive as possible but also only as comprehensive as necessary. In individual cases, this can cause considerable difficulties. If you are of the opinion that individual explanations are not sufficiently clear, then bear with us; the General Data Protection Regulation imposes an incredibly large catalogue of obligations on even small data processors like us, which we want to implement to the best of our knowledge and belief. Therefore, we also always ask for feedback on whether you think our data processing is sufficiently transparent.
We welcome any enquiry regarding the data we process.
II. Our goals
Specifically, we have set the following goals:
1. Principle: Maximum data economy
From a convinced point of view, we believe that data protection should be the standard. Therefore, if possible, we only want to collect data when it is absolutely necessary for reasons of data security or to provide our services.
Only if someone would like to use further services or voluntarily support us in improving our products, we collect further data after explicit consent by the person concerned and even then only such data that fulfils the purpose we want to achieve together.
We actively oppose the indiscriminate “hoarding” of data.
2. Maximum transparency
In our opinion, data processing is also only a problem if the data subject is not informed about this and therefore has no possibility to regain control over his or her data. A power imbalance between the data processor and the user only arises if the data is withheld in an abusive manner and processed in secret. Therefore, we want to achieve the greatest possible transparency in the handling of your data; for an appreciative cooperation.
3. Highest possible data security
Unfortunately, data are volatile objects by their very nature. There is no absolute guarantee that something will happen to data that shouldn’t happen to it. What can be guaranteed, however, is that all parties involved do their best and adhere to the best standards of data security, which should keep data security as high as possible.
We therefore rely on modern encryption, security-optimized compliance processes and the principle that any data not collected cannot be lost. And if, despite everything, unfortunate circumstances lead to data being processed incorrectly, we bear responsibility for this and deal with the elimination of these circumstances in a transparent manner.
B. Privacy policy
I. Name and address of the person responsible
The responsible person 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:
LowPolyCube
Mainstraße 16
64297 Darmstadt
Germany
Email: lowpolycube@gmail. com
Name of the data protection officer: Dario Bloch, who can be contacted at the above address.
Contact the Data Protection Officer with your data protection enquiry directly here:
II. General information on data processing
1. Scope of the processing of personal data
We process personal data of our users only insofar as this is necessary for the provision of a functional website, as well as the online functions of our games and other content and services. The processing of personal data of our users takes place regularly only after consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by legal regulations.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (DSGVO) serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person make it necessary to process personal data, Article 6(1)(d) DSGVO serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.
3. Data deletion and storage period
The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or performance of a contract.
In detail, we comply with the following deletion periods automatically and without your involvement:
III. Provision & security of the website
1. Description and scope of data processing
When the login pages of our website are called up, our system automatically records data and information from the computer system of the calling computer to the following extent:
(1) Our system collects and stores the user’s IP address if the login fails.
(2) When you call up a page on our website that contains a login form, data is processed by Google LLC as part of a CAPTCHA procedure in accordance with their privacy policy.
2. Legal basis for data processing
The legal basis for the temporary storage of the data and the log files as well as the collection of data by Google LLC is Art. 6 (1) lit. f DSGVO.
3. Purpose of the data processing
The temporary storage of the IP address by the system is necessary to ensure data integrity and security as well as functionality of the website. For this purpose, the IP address of a user must remain stored if a login attempt fails, as it could be an unauthorized attempt to gain unauthorized access to our data system.
The collection of data by Google LLC as part of the CAPTCHA process is necessary to ensure data integrity and security and functionality of the website by preventing unauthorized logins.
These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f DSGVO.
4. retention period
The data we collect is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data to secure the website, this is the case when an attack could be assessed as unlikely.
The data collected by Google LLC is stored in accordance with their privacy policy.
5. Possibility of objection and removal
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
IV. use of cookies
1. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.
We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
Log-in information is stored and transmitted in the cookies.
2. Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f DSGVO. (c) the purpose of the data processing.
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We only need cookies to enable logins.
This purpose is also our legitimate interest in processing the personal data according to Art. 6 (1) lit. f DSGVO.
3. Duration of storage, possibility of objection and elimination
Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website in full.
V. Contact form and e-mail contact
1. Description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. The contact form is operated and provided by Google LLC in accordance with their privacy policy.
For the processing of data, your consent is obtained during the submission process and reference is made to this privacy policy.
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the personal data of the user transmitted with the e-mail will be stored.
2. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) lit. f DSGVO. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DSGVO.
3. Purpose of the data processing
The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
4. retention period
The duration of the storage is one month to the end of the month after the completion of the processing of the request.
5. Possibility of objection and removal
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
The deletion request can be made informally by e-mail or by any other means of contact.
All personal data stored in the course of contacting us will be deleted in this case.
VI. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights towards the controller:
1. Right to information
You may request confirmation from the controller as to whether personal data relating to you is being processed by us.
If there is such processing, you can request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the envisaged duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the duration of the storage;
(5) the existence of a right to obtain the rectification or erasure of personal data concerning you, a right to obtain the restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.
Insofar as an individual application collects data expressly also for research or scientific purposes, this right of access may be restricted to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the restriction is necessary for the fulfilment of the research or statistical purposes.
In individual cases, complete information about data cannot be provided even if the data is stored in such a way that it is secured against special or easily identifiable retrieval if this is done to ensure a higher level of protection of the personal data. This may be the case in particular if data is stored in a decentralised manner, i.e. outside a secure access area by us, or if data is stored in such a pseudonymised manner that retrieval is not possible without additional data or data that cannot be assigned to us. In the event of a request for information by the entitled party, the possibility of such an incomplete request on our part will be pointed out separately when answering the request and an explanation will be given as to why retrieval cannot or is not possible in the specific case.
2. right of rectification
You have a right of rectification and/or completion vis-Ã -vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
Your right of rectification may be limited to the extent that it is likely to make impossible or seriously prejudice the achievement of the research or statistical purposes and the limitation is necessary for the fulfilment of the research or statistical purposes.
3. Right to restrict processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defence of legal claims; or
(4) if you have objected to the processing pursuant to Article 21(1) DSGVO and it is not yet clear whether the legitimate grounds of the controller override your grounds.
Where the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or of a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
Your right to restrict processing may be limited to the extent that it is likely to render impossible or seriously impede the achievement of the research or statistical purposes and the restriction is necessary for the fulfillment of the research or statistical purposes.
4. Right of cancellation
Obligation to delete
You may request the controller to delete the personal data concerning you without delay, and the controller is obliged to delete such data without delay if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a DSGVO and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you has been collected in relation to information society services offered pursuant to Art. 8(1) DSGVO.
Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
Exceptions
The right to erasure does not exist insofar as the processing is necessary
(1 ) On the exercise of the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
(5) to assert, exercise or defend legal claims.
5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of these recipients by the controller.
6. Right to data portability
You have the right to obtain the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance by the controller to whom the personal data has been provided, provided that
(1) the processing is based on consent pursuant to Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO and
(2) the processing is carried out by automated means.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons.
The right to data portability shall not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
You also have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) DSGVO.
Your right to object may be limited to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the limitation is necessary for the fulfilment of the research or statistical purposes.
8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. Automated decision in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is authorised by Union or Member State legislation to which the controller is subject and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests; or
(3) is done with your express consent.
However, these decisions must not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.