Data privacy statement of astragon Entertainment GmbH - HOWL

1. General information

Thank you for your interest in our games and welcome! We are astragon Entertainment GmbH, Am Wehrhahn 33, D-40211 Düsseldorf. You can reach us via info@astragon.de

Our aim

Protecting your privacy is paramount to us. Therefore, compliance with the legal provisions on data protection is fundamental for us. In addition, it is important to us that you know at all times which personal data we collect and why and how we process it. We will also be happy to explain to you what rights you have and how you can exercise them.

What is personal data?

In short, anything that identifies you as an individual, whether through the information itself or in connection with other information. Examples of this are your name, your e-mail address or a customer number, but also the time at which you started a multiplayer game when it is stored together with your IP address. We always try to collect as few personally identifiable information as possible. But we also like to inform you in detail in this document about your personal data when we collect them.

Why is this document so long?

In regard to all personal data, we are required by law to describe to you in detail:

-          What kind of personal data do we collect? (= type of data collected)

-          Which law, rule or regulation allows us to do so (= legal basis)

-          Why we collect this data (= purpose of use)

-          What exactly happens to your data (= type of processing)

-          How long do we store your personal data

-          What rights you have with regard to your personal data (= rights of data subjects)

We are required to list each step individually. That is the reason why this document is very comprehensive.

1. Competent supervisory authority & company data protection officer

Responsible in terms of the European General Data Protection Regulation (GDPR) are we,

astragon Entertainment GmbH

Am Wehrhahn 33, D-40211 Düsseldorf.

info@astragon.de

For all data protection inquiries, please contact our company data protection office. Contact details:

datenschutz@astragon.de

Benjamin Wolf

2. Legal basis

We collect and process personal data on the basis of the current European law. The following legal bases can be found in the General Data Protection Regulation (GDPR). Depending on the purpose of the data collection, one or more of the following legal bases apply:

• The data subject has given consent to the processing of his or her personal data as referred to in Art. 6 (1)(a) General Data Protection Regulation (GDPR).

Consent is an expression of will. This can be done in writing in form of a statement or with another clear affirmative action. Either way, the consent must be voluntary, apply to a specific case, and must clearly state that the data subject agrees to the processing of his or her respective personal data. For this purpose, the data subject must be sufficiently informed and understand the consent.

• Processing is necessary for the performance of a contract prior to entering into a contract as referred to in Art. 6 (1)(b) GDPR.

That means: The data is required so that we can fulfill our contractual obligations towards you or we need the data to prepare a contract with you.

• Processing is necessary for compliance with a legal obligation as referred to in Art. 6 (1)(c) GDPR

That means: For example, we are required by law or other regulations to process the data.

• Processing is necessary for the purposes of the legitimate interests as referred to in Art. 6 (1)(f) GDPR

That means: The processing of data is necessary to protect the legitimate interests of us or third parties, unless your interests or fundamental rights and freedoms that require the protection of personal data prevail.

3. Rights of the data subject

When it comes to your personal data, you are the data subject. You are entitled to the following rights with regard to the data processed by us in accordance with the articles of the General Data Protection Regulation referred to in each case:

• Information Right pursuant to Article 15 GDPR, i.e. the right to be informed about how your personal data is processed and which personal data is processed by us,
• Right of rectification pursuant to Article 16 GDPR - i.e. the right to request the rectification of inaccurate personal data relating to you without undue delay, including the completion of incomplete data,
• Right to erasure ("right to be forgotten") pursuant to Article 17 GDPR - i.e. the right to request the erasure of your personal data, provided that certain conditions are met,
• Right to restriction of processing pursuant to Article 18 GDPR - i.e. the right to request the restriction of the processing of your personal data, provided that certain conditions are met,
• Right to data portability pursuant to Article 20 GDPR - i.e. the right to demand that you receive your personal data that you have provided in a structured, common and machine-readable format and the right to transfer it to a third party, provided that certain conditions are met,
• Right to object in accordance with Article 21 GDPR - i.e. the right to object to the processing of your personal data where the processing is based on our legitimate interests, provided that certain conditions are met.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular with the EU Member State of your place of residence, place of work or place of alleged infringement, if you believe that the processing of your personal data violates the GDPR.

4. Data erasure and storage time

Personal data must be erased if they are no longer necessary in relation to the purposes for which they were collected or otherwise processed. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. The data will also be blocked or erased if a storage period required by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

2. Specific data processing

1. Do we collect personal information when you play our games on a console?

We do not collect any personal data when you use our games on a Sony console. If and to what extent personal data are collected and processed by Sony in the context of the use of games or other services, please read the respective privacy statements of the respective provider.