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Privacy Policy - Website

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1. AN OVERVIEW ON DATA PROTECTION

1.1 General information about this privacy policy

We take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy.

The term „personal data” (or “Data”) comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as cookie identifier or technical data).

The following information will provide you with an overview of which personal data, how it is collected as well as the purposes we use this Data for when you visit this website.

1.2 Data recording on this Website

How do we record your Data?

We collect your Data as a result of your sharing of your Data with us. This may, for instance, be information you enter into our contact form or information you provide in connection with job applications.

If you opt-in to cookies and tracking, our IT systems automatically record other Data upon visiting our website. This Data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed).

For more information regarding cookies and opt-out options, please consult section 4.2 of this Privacy Policy.

 

What are the purposes we use your Data for?

We can use your Data for the following purposes:

  • The existence of a contract between you and Kolibri Games to provide you with Services. You enter into this contract with Kolibri Games by accepting the Terms and Conditions of our Services.
  • Kolibri Games’ legitimate interest (or reasonable expectations of users), to offer you the best possible user experience, such as to ensure the security of the Services, moderate the community, respond to your requests and questions or to send you newsletters.
  • Your consent to offer you advertisements, products, services or personalized content depending on your user profile.

Kolibri Games is entitled to change this policy at any time. We will inform you of the material updates and recommend that you consult this policy on a regular basis or contact us if you have any questions. Using our Services following such a change means that you accept any changes.

How long do we keep your Data?

Unless the law specifies a different retention period, we will only keep your Data for the time necessary to carry out the operations for which the corresponding Data has been collected.

For example, we will keep the Data associated with your Account until the closure of the Account. In some cases, the Data may be kept for a longer period such as when we have a legal obligation to keep the Data.

 

2. GENERAL INFORMATION

The responsible party (referred to as the „controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others determines purposes of and resources for the processing of personal data.

 

The controller according to data protection laws is:

Kolibri Games GmbH
Hallesches Ufer 60
10963 Berlin

If you have any questions or suggestions about data protection, you can send us an email to privacypolicy@kolibrigames.com

Our data protection officer can be reached here.

 

3. HOSTING

External Hosting

This website is hosted by an external service provider: https://www.mittwald.de/. Personal data collected on this website are stored on the servers of Mittwald. These may include, but are not limited to, IP addresses, metadata and communications, contact information, names, web page access, and other Data generated through a website.

Mittwald is used for the purpose of fulfilling the contract with our potential and existing customers and in the legitimate interest of secure, fast and efficient provision of our online services by a professional provider.

Our host will only process your Data to the extent necessary to fulfil its performance obligations, in compliance with our instructions with respect to such Data.

4. COLLECTION AND USE OF YOUR DATA

4.1 Server log files

When you visit our website, we collect and store information in server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This Data is not merged with other Data sources.

This Data is recorded on the basis of a legitimate interest in the technically error free depiction and the optimization of the operator’s website.

4.2. Cookies 

If you opt-in to cookies and tracking, we use cookies to offer you a range of features and to make our websites more convenient to use. Cookies are small files that your web browser stores on your computer when you visit our website. You can opt-in and -out of cookies at any times by clicking on the corresponding on- and off icons in the overview below:

 

Essentials

  • Borlabs Cookie (own cookie)

Statistics

  • Google Tag Manager
  • Hotjar
  • Google Analytics

External Media

  • Facebook & Facebook Feed
  • YouTube

 

Alternatively, you can always opt-out of non-essential cookies by clicking on "Your Cookie Settings" in the footer of our website.

Please note that these settings may reduce the functionality of our site.

4.3. Support Requests

If you contact us by e-mail or telephone, we collect Data such as your name and the contents of your request.

If you contact us via social media, we collect some of the Data included on your profile.

When you send support requests directly via the chat system integrated into our websites, your Data is transmitted to our help desk provider HelpShift. Helpshift Inc. is located in 1 Embarcadero Ctr Ste SL12 #2048, San Francisco, CA 94111, USA.
By using our chat system, you understand and agree with the transmission of the personal data required to process your support request in accordance with Helpshift’s Privacy Policy.

4.4 Analysis Tool and Advertising

4.4.1. Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses cookies, are stored on your device and allow us to analyze how you use our website. The information that the cookie generates about your use of this website (including your abbreviated IP address) is transmitted to a Google server in the United States and stored there.
Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to the use of our website and internet usage. Google might also transfer this information to third parties if required by law or insofar as third parties process this data on Google’s behalf.
We use Google Analytics is based on our legitimate interest in a needs-based design, statistical analysis and the efficient promotion of our website.

 

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

 

Browser plug-in

You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option to prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout.

 

Objection to the recording of data

You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation: (https://tools.google.com/dlpage/gaoptout)

For more information about how Google uses your information, see Google’s Privacy Declaration: https://support.google.com/analytics/answer/6004245?hl=en.

 

Demographic parameters provided by Google Analytics

This website uses the function „demographic parameters” provided by Google Analytics. It makes it possible to generate reports providing information on the age, gender and interests of website visitors. The sources of this information are interest related advertising by Google as well as visitor data obtained from third party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section „Objection to the recording of data.”

 

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

4.4.2. Hotjar

This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe (Website: https://www.hotjar.com).

Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.

We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so called conversion funnels).

Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.

Hotjar uses cookies. Cookies are small text files that are placed on your computer and stored by your browser. Their purpose is to make our website presentation more user friendly, more effective and more secure. These cookies allow us to in particular determine if this website was used with a certain device or if the functions of Hotjar have been deactivated for the respective browser. Hotjar cookies will remain on your device until you delete them.

You can set up your browser in such a manner that you will be notified anytime cookies are placed and you can permit cookies only in certain cases or exclude the acceptance of cookies in certain instances or in general and you can also activate the automatic deletion of cookies upon closing of the browser. If you deactivate cookies, the functions of this website may be limited.

The use of Hotjar and the storage of the Hotjar cookies are based on Article 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Article 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

 

Deactivation of Hotjar

If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/opt-out.

Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.

For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy.

4.5 Plug-ins and Tools

4.5.1. YouTube

This website embeds videos of the website YouTube. The website operator is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

If you visit a page on this website into which a YouTube has been embedded, a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified about which of our pages you have visited.

Furthermore, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about this website's visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud. These cookies will stay on your device until you delete them.

If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

The use of YouTube is based on our legitimate interest in presenting our online content in an appealing manner. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on this basis; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under:
https://policies.google.com/privacy?hl=en.

4.5.2. Google Web Fonts

To ensure that fonts used on this website are uniform, this website uses so called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts.

To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. The use of Google Web Fonts is based on our legitimate interest in presenting our online content in a uniform and appealing way.

If your browser should not support Web Fonts, a standard font installed on your computer will be used. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.

4.5.3. Google Maps

Via an API, this website uses the mapping service Google Maps. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.

We use Google Maps on the basis of our legitimate interest to present our online content in an appealing manner and to make the locations disclosed on our website easy to find.

4.5.4. Google reCAPTCHA

We use „Google reCAPTCHA” (hereinafter referred to as „reCAPTCHA“) on this website. The provider is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g. information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g. IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

The data is processed on the basis of the website operator’s legitimate interest, to protect the web content against misuse by automated industrial espionage systems and against spam.

For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms of Use under the following links:
https://policies.google.com/privacy?hl=en and
https://policies.google.com/terms?hl=en.

4.6. Newsletter

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis.
This website uses CleverReach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, Germany.
CleverReach is a service that can be used to organize and analyze the sending of newsletters. The data you have entered for the purpose of subscribing to our newsletter (e.g. e-mail address) are stored on servers of CleverReach in Germany or in Ireland.
Newsletters we send out via CleverReach allow us to analyze the user patterns of our newsletter recipients. Among other things, in conjunction with this, it is possible how many recipients actually opened the newsletter e-mail and how often which link inside the newsletter has been clicked. With the assistance of a tool called Conversion Tracking, we can also determine whether an action that has been predefined in the newsletter actually occurred after the link was clicked (e.g. purchase of a product on this website). For more information on the data analysis services by CleverReach newsletters, please go to: https://www.cleverreach.com/en/features/reporting-tracking/.

For more details, please consult CleverReach’s Data Protection Provisions.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent. You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the „Unsubscribe” link in the newsletter.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our legitimate interest in complying with the legal requirements when sending newsletters. The storage in the blacklist is indefinite. You may object to the storage by sending an email to privacypolicy@kolibrigames.com.

4.7 Job Applications

We offer website visitors the opportunity to submit job applications to us. We assure you that the collection, processing and use of your Data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

If you click the “Apply Now”-button in the “CAREERS”-section of our website, you will be directed to our external recruiting provider Lever. Lever is located in 1125 Mission Street San Francisco, CA 94103. By submitting your application via our careers page, you understand and agree with the transmission of the personal data required to process your job application.

When processing Data through Lever, we ensure that your personal information is only used in accordance with Lever’s Privacy Policy and our instructions. In particular, you understand that data may be transferred outside of the EU, to a country that is not offering the same level of protection of your personal data. In this context, the protection of your Data is especially ensured by an agreement with our partners under the Standard Contractual Clauses, approved by the European Commission.

Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

 

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.) required to make a decision concerning an employment relationship.

The legal grounds for the corresponding data processing are Negotiation of an Employment Relationship (§ 26 BDSDG-neu), General Contract Negotiations (Article 6 Sect. 1 lit. b GDPR) or your consent. You may revoke your consent at any time.

If your job application should result in a recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG-neu and Article 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our IT-systems.

 

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the Data you have submitted on the basis of our legitimate interests for up to 2 years from the end of the application procedure. Afterwards the data will be deleted, and any physical application documents will be destroyed.

Longer storage may also take place if you have given your consent or if statutory data retention requirements preclude the deletion.

 

Admission to the applicant pool

If you apply to us via our website, you can consent to be included in our applicant pool. All documents and information from the application will then be transferred to the applicant pool in order to contact you about further suitable vacancies.

The data from the applicant pool will be irrevocably deleted after 2 years in case you consent to an extended archiving period.

Admission to the applicant pool is based exclusively on your express consent which you grant us at the time of application.

You can revoke your agreement at any time. For that, please contact us under jobs@kolibrigames.com. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

 

5. DISCLOSURE OF DATA

We may share your Data with:

 

  • The technical service providers involved in the supply of the services. As subcontractors, these service providers are under the same obligations as ourselves to comply with applicable personal data protection laws.
  • The partners who use your Data to provide you with personalized advertisements or Personalized Content. For more information about these partners and your opt-out options, please click on "Your Cookie Settings" in the footer of our website
  • Other companies, only in the event of a transfer of our activities.
  • Administrative or judicial authorities to verify the proper use of our services or for the purposes of an investigation, in compliance with applicable law. We always verifiy the legitimacy of the request.

 

In such cases, your Data may be transferred to countries located outside of the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of your Data is especially ensured by agreements with our partners under the Standard Contractual Clauses, approved by the European Commission.

6. YOUR RIGHTS

Please contact us via e-mail at privacypolicy@kolibrigames.com to exercise your rights as set out below:

6.1 Obtain a copy of your Data – “Right of access and data portability”:

At any time, you can request a copy of your Data. You may also consult the Data, use it yourself or transfer it to another service provider.

6.2 Correct your Data – “Right to rectification”

You have the right to correct your Data when it is inaccurate or incomplete (for example, change your address).

6.3 Delete your Account – “Right to erasure (right to be forgotten)”

You can request the closure of your Account and the deletion of the associated Data.

6.4 Limit the use of your Data – “Right to restriction of processing”

You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request.

6.5 Give and withdraw your consent – “Right to object and withdraw your consent”:

At any time, you may withdraw your consent or object to the receipt of newsletters and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers):

  • For email advertising directly by following the information provided in our newsletters
  • On our “Your Cookies Settings” page in the footer of our website to manage your Cookies preferences.
  • Or by email request to privacypolicy@kolibrigames.com.

We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights

If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority.For the state of Berlin, the competent authority is:
Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstraße 219
10969 Berlin

mailbox@datenschutz-berlin.de

6.6 Right to non-discrimation

We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights.

12    SSL AND/OR TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from „http://“ to „https://“ and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, Data you transmit to us cannot be read by third parties.

13. CHANGES TO THIS DATA PROTECTION POLICY

We reserve the right to update this Privacy Policy, if necessary, in compliance with the applicable Data protection regulations. This way, we can adapt it to the current legal requirements and take changes in our services into account, e.g. when introducing new services. The most current version always applies to your visit.

The current version of this Privacy Policy is always available at HTTPS://KOLIBRIGAMES.COM/WEBSITE-PRIVACY-POLICY/.

 

Last update: April 6, 2021

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