Privacy Policy
1. Controller
The controller responsible for data processing is:
Managing Directors: Christoph Tschierschwitz, Jerome Wolff
2. General Information on Data Processing
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. The use of our mobile game "TransferKings" is generally possible without providing personal data. Where personal data is collected, this is always done on a voluntary basis and with your consent.
3. Legal Basis for Processing
The processing of personal data is based on the following legal bases:
- Art. 6(1)(a) GDPR - User consent
- Art. 6(1)(b) GDPR - Contract performance and pre-contractual measures
- Art. 6(1)(f) GDPR - Legitimate interests (e.g., improving our services, security)
4. Data Collected and Purpose of Processing
4.1 Unity Game Services
Our game uses Unity Game Services from Unity Technologies. The following data may be collected:
- Device ID and hardware information
- Operating system and version
- Game progress and statistics
- In-app purchases
- Crash reports and performance data
The processing of personal data is based on the following legal bases:: Art. 6(1)(f) GDPR (legitimate interest in the functionality and improvement of the game)
More information: https://unity.com/legal/privacy-policy
4.2 Google Analytics
We use Google Analytics to analyze user behavior. Google Analytics uses cookies and collects:
- Usage statistics
- Device type and operating system
- Approximate location (country/city)
- In-app interactions
- Session duration and frequency
The processing of personal data is based on the following legal bases:: Art. 6(1)(a) GDPR (consent)
More information: https://policies.google.com/privacy
4.3 Google Play Store
When using the Google Play Store, Google's privacy policy applies. Google collects:
- Download and installation data
- Device information
- Payment information for in-app purchases
- Ratings and reviews
More information: https://policies.google.com/privacy
4.4 Apple App Store
When using the Apple App Store, Apple's privacy policy applies. Apple collects:
- Download and installation data
- Apple ID-related information
- Payment information for in-app purchases
- Device information
More information: https://www.apple.com/legal/privacy/
4.5 Vercel Analytics
For the web presence of the game, we use Vercel Analytics. The following is collected:
- Page views and navigation
- Device and browser information
- Performance metrics
- Anonymized usage data
The processing of personal data is based on the following legal bases:: Art. 6(1)(f) GDPR (legitimate interest)
More information: https://vercel.com/legal/privacy-policy
4.6 ironSource (Ads Network)
We use ironSource as our advertising network. The following data may be collected:
Collected Data:
- Advertising ID (IDFA/AAID)
- Device type and model
- Operating system
- IP address (anonymized)
- Interactions with advertisements
- App usage data
- Approximate location (country/city)
Opt-Out Instructions:
- iOS: Disable Tracking in Privacy Settings
- Android: Disable personalized Advertisements at Google
The processing of personal data is based on the following legal bases:: Art. 6(1)(f) GDPR (legitimate interest)
More information: https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy
5. Data Sharing and Recipients
Your data is only shared with the following recipients:
- Unity Technologies (USA) - with EU Standard Contractual Clauses
- Google LLC (USA) - EU-US Data Privacy Framework certified / Standard Contractual Clauses
- Apple Inc. (USA) - with appropriate safeguards
- Vercel Inc. (USA) - with EU Standard Contractual Clauses
- ironSource Mobile Ltd. (Israel)
Data is not shared with third parties for other purposes.
6. Storage Period
We only store personal data for as long as necessary for the respective purposes. Analytics data is usually automatically deleted after latest 26 months. Data required to fulfill contractual or legal obligations is stored until the expiry of the respective retention period.
7. Your Rights as Data Subject
You have the following rights:
- Right of access (Art. 15 GDPR)
- Right to rectification (Art. 16 GDPR)
- Right to erasure (Art. 17 GDPR)
- Right to restriction of processing (Art. 18 GDPR)
- Right to data portability (Art. 20 GDPR)
- Right to object (Art. 21 GDPR)
- Right to withdraw consent (Art. 7(3) GDPR)
- Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)
To exercise your rights, please contact: privacy@valorbyte.de
8. Data Security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security measures are continuously improved in line with technological developments.
9. Changes to the Privacy Policy
We reserve the right to amend this privacy policy to ensure it always complies with current legal requirements or to implement changes to our services in the privacy policy. The new privacy policy will apply to your next visit.
10. Contact the Data Protection Officer
If you have any questions about data protection, you can contact us::
Valorbyte UG (haftungsbeschränkt)
Haid-und-Neu-Str. 18
76131 Karlsruhe
Germany