Data privacy statement of astragon Entertainment GmbH - HOWL

1. General information

Welcome! Thank you for your interest in our game. We are astragon Entertainment GmbH, Am Wehrhahn. 33, D-40211 Düsseldorf. You can contact us at: info@astragon.de

Our commitment

Protecting your privacy is of utmost importance to us. Therefore, complying with the statutory data privacy regulations forms a natural foundation of our day-to-day work. It is, however, moreover paramount to us that you at all times know which personal data we gather, why we gather it, and how we process it. We will be happy to explain to you what rights you have and how to exercise them, as well.

What is personal data?

To put it briefly, anything whereby you, as an individual, can be identified, whether due to the information itself or in connection with other information. Examples of this include your name, e-mail address, or also a customer ID, but even the point in time at which you visit our website if that is saved together with your IP address. We constantly endeavour to gather as little personal data as possible. Simultaneously, we are informing you in this document, in depth, on your personal data, if we gather any.

Why is this document so long?

The legislative authority requires us to describe the following to you in regard to all personal data individually:

-          which personal data we gather (= the nature of the data gathered)

-          which law or ordinance or regulation permits us to do so (= the legal basis)

-          why we gather said data (= the intended use)

-          what exactly happens to your data (= the nature of the processing)

-          how long we save your personal data

-          what rights you have in regard to your personal data (= the rights of data subjects)

We need to list all the steps individually. This is why this document is very extensive.

1. Controller and Corporate Data Protection Officer

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) are we, the company

astragon Entertainment GmbH

Am Wehrhahn. 33, D-40211 Düsseldorf

info@astragon.de

If you have any questions regarding data protection please contact our Corporate Data Protection Officer. Our Corporate Data Protection Officer is

Benjamin Wolf

datenschutz@astragon.de

2. Legal basis

We gather and process personal data based on the most up-to-date European law. You will find the entire legal basis specified below in the General Data Protection Regulation (GDPR). Depending upon the purpose for gathering the data, one or more of the legal bases below will apply:

• Consent pursuant to Art. 6(1)(a) General Data Protection Regulation (GDPR).

Consent is a declaration of intent. This can be given in writing in the form of a statement, or also by way of any other clearly affirmative action. In whatever way the consent is given, it needs to be given voluntarily, apply to a specific case, and unmistakably express that the data subject is in agreement with the processing of the personal data concerned. For that purpose, the data subject needs to be adequately informed and understand the consent.

• The necessity of fulfilling the contract or taking preparatory measures pursuant to Art. 6(1)(b) GDPR

This means: The data is necessary so that we can fulfil the contractual obligations towards you or we need the data to prepare for concluding an agreement with you.

• Processing to fulfil legal obligations pursuant to Art. 6(1)(c) GDPR

This means: The processing of the data is, for example, mandatory for us based on a law or other regulation.

• Processing in order to preserve legitimate interests pursuant to Art. 6(1)(f) GDPR

This means: The processing of the data is necessary in order to, on the one hand, preserve legitimate interests on our part or on the part of a third party, as long as your interests or basic rights and basic freedoms, which make the protection of personal data necessary, do not outweigh the latter.

3. Rights of data subjects

As far as your personal data is concerned, you are the data subject. You have the following rights in regard to the processing of data by us in the scope in accordance with the respective article of the General Data Protection Regulation cited:

• The right to information pursuant to Art. 15 GDPR
• The right to correction pursuant to Art. 16 GDPR
• The right to deletion (“Right to be forgotten”) pursuant to Art. 17 GDPR
• The right to limit the processing pursuant to Art. 18 GDPR
• The right to data portability pursuant to Art. 20 GDPR
• The right of opposition pursuant to Art. 21 GDPR

Notwithstanding any other legal remedy under administrative or judicial law, you are entitled to file an appeal with a supervisory authority, in particular in the EU Member State that is your place of residence, your place of work or the place of the presumed infringement if you are of the opinion that the processing of the personal data concerned infringes the GDPR.

4. Deletion of data and duration of storage

The personal data of the data subject is deleted or blocked once the purpose of the storage lapses. It may, moreover, be stored beyond that time if this has been stipulated by the European or national legislative authority in EU ordinances, laws or other regulations to which the Controller is subject. The data may also be blocked or deleted if a storage period stipulated by said standards expires, unless the necessity for further storage of the data for concluding an agreement or fulfilling an agreement exists.

2. Specific data processing

1. Do we gather personal data if you play our games on a mobile phone or tablet?

When you use our games on a mobile phone or tablet with the Google Android or Apple iOS operating systems, we do not gather any additional personal data. Please infer whether, and to what extent, personal data is gathered and processed by Apple or Google in the context of using the games from the respective data privacy policies of the relevant provider. This may in particular be the case if you use the convenience functions of Apple or Google that are integrated into the game, e.g. logging in to the Game Center, saving game statuses, etc. We have no access to such data that is gathered by Apple or Google.