Privacy Notice for End Users

Last update: June 30, 2024

Contents

  1. Introduction
  2. Name and address of the controller
  3. Name and address of the data protection officer
  4. General information on data processing
  5. Provision of our websites, mobile apps and forums; creation of log files
  6. Inquiries via contact form, email, support tool; legal matters
  7. Submission of newsletters
  8. Submission of push notifications
  9. Use of cookies
  10. Use of third-party analysis services
  11. Use of third-party customer support services
  12. Use of third-party email services
  13. Use of third-party login services
  14. Use of third-party market research services
  15. Use of third-party payment services
  16. Use of third-party social networks
  17. Use of third-party user acquisition services
  18. Use of third-party video advertising services
  19. Use of other third-party services
  20. Group Cooperations
  21. Rights of the data subject
  22. Privacy information for California residents
  23. Final provisions

1. Introduction

InnoGames GmbH (“InnoGames”, “We”, “Us”) is the data controller in respect of your personal data and is committed to protecting the privacy of your personal data when you visit one of our websites, install one of our mobile apps and interact with our social media presences (together the “Services”). This Privacy Notice will help you understand what personal data we collect about you, why we collect it, how we process it and when we delete it. This Notice will also clarify how you can exercise your rights when you trust us to handle your personal data. We ask that you take a moment to read this Notice carefully and familiarize yourself with its content. If you have any questions, you are welcome to contact us by using the contact information provided at the end of this Notice.

This Privacy Notice is based on the rules of the General Data Protection Regulation (“GDPR”), a law created by the European Union. As a company based in the European Union, we apply the standards set by the GDPR to everyone who uses our Services worldwide, regardless of their place of residence. However, if you do reside outside the European Union and use our Services, we may apply additional standards to you as required by local law.

To the extent that the California Consumer Privacy Act (“CCPA”) applies to you, the definitions in this Privacy Notice are to be read as follows: “personal data” includes “personal information”; “data subject” includes “consumer”; “controller” includes “business”; “processor” includes “service provider”, all as defined under the CCPA. For more information about our commitment to the CCPA, please read Section 22 below.

We are part of a group of gaming studios that are owned by our parent company Modern Times Group MTG AB (“MTG”), a Swedish gaming company. We cooperate with MTG, and the other gaming studios of the group (each a “Group Company”) to learn from one another, help each other and improve how we all make games. We like to see ourselves as a small gaming village in which we strive together to make great games. You will find more information about the ways we process data as a group on Title 20 "Group Cooperations."

Please note that our Services may contain links to external websites of other companies. If you follow a link to any of these websites, you should be aware that they have their own privacy notice and that we do not assume any liability for their processing of your personal data. Therefore, please make sure to read their privacy notices.

We offer our Services only to players who are at least 16 years old. Hence, we do not market to or solicit personal data from persons under the age of 16. If you are below the age of 16, please obtain the consent of your legal guardian before using our Services.

2. Name and address of the controller

The controller in line with the General Data Protection Regulation and other national data protection laws of the member states, as well as other legal data protection provisions, is:

InnoGames GmbH
Friesenstraße 13
20097 Hamburg
Germany
Email: privacy@innogames.com
Website: https://innogames.com

3. Name and address of the data protection officer

The data protection officer of the controller is:

Prof. Dr. Christian Rauda
ARTANA Digital GmbH
Alstertwiete 3
20099 Hamburg
Germany
Email: dpo@innogames.com
Website: https://artana.law

4. General information on data processing

1. Description and scope of data processing

In general, we process only the personal data which you disclose to us when using one of our Services. Personal data means any information relating to an identified or identifiable natural person. When you register as a user on one of our websites or in one of our apps, you only have to provide a username, email address and, if applicable, a password. When registering for certain Services such as mobile apps, usernames and email addresses are not collected during registration but only later during the use of the Service. We always store the password you have chosen in hashed form, which never allows for an inference of the actual password.

In the context of implementing a contract you have concluded with us, particularly in the context of fee-based Services you have chosen, the disclosure of further data, such as your full name, physical address, payment information may be required. It is sometimes also necessary to request further personal data for the purposes of processing your inquiries or providing you with support. InnoGames will handle this data confidentially and in compliance with the applicable data privacy provisions. As a matter of principle, InnoGames will not disclose personal data to third parties without your consent, unless there is a specific legal basis of doing so.

2. Legal basis for personal data processing

Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6(1)(a) of the EU General Data Protection Regulation (“GDPR”) serves as the legal basis for personal data processing.

In personal data processing required for the fulfilment of a contract of which the data subject is a party, Art. 6(1)(b) GDPR serves as the legal basis. This also applies to the processing required in order to carry out pre-contractual actions.

Insofar as personal data processing is required for the fulfilment of a legal obligation which our company is subject to, Art. 6(1)(c) GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require personal data processing, Art. 6(1)(d) GDPR serves as the legal basis.

If processing is required to protect the legitimate interests of our company or of a third party, and if the interests, fundamental rights, and freedoms of the data subject do not prevail over the interests mentioned first, Art. 6(1)(f) GDPR serves as the legal basis for processing.

3. Deletion of data and duration of storage

The personal data of the data subject are deleted or anonymized as soon as the purpose of storage no longer exists. In addition, such storage may occur if this is provided for by the EU law or Member State laws to which we are subject. The deletion or anonymization of data also occurs when the storage period prescribed in the abovementioned laws lapses, unless further storage of the data is required for conclusion or fulfilment of a contract.

4. Data security

InnoGames makes reasonable efforts to prevent unauthorized access to your personal data as well as unauthorized use or falsification of these data and to minimize the corresponding risks. However, the provision of personal data, whether it be in person, over the phone or over the Internet, always involves risks and no technological system is completely free of the possibility of being manipulated or sabotaged.

InnoGames processes the information collected from you in accordance with German and European data protection law. All employees are obliged to comply with data secrecy and data protection provisions and are instructed in this regard. Your data are transmitted in an encrypted form using the SSL method.

5. Provision of our websites, mobile apps and forums; creation of log files

A) Games

1. Description and scope of data processing

You can play our games via the website, mobile app, or both. Each time one of our websites or mobile apps is accessed, our system automatically collects data from the system of the accessing device.

When accessing a website, the following data is collected:

When accessing a mobile app, the following data is collected:

The date, time, and IP address are also stored in the log files. If an error occurs during the use of our websites or mobile apps and we want to rectify this, we may also collect other data, e.g., Player ID and username.

2. Purpose of data processing

To allow delivery of the website or mobile app to the user's computer, your IP address must be stored for the duration of the session. In addition, we store your IP address and log files to ensure the functionality of the website or mobile app, to optimize the website/app, and to ensure the security of our information technology systems.

Moreover, InnoGames reserves the right to store IP addresses and log files and to monitor compliance with our Terms of Service and Game Rules ("Breach of the Terms”). Particularly in this case, the data is used to prevent any cases of abuse or to resolve them in or outside of a court of law (“Legal Dispute”), and, on a case-by-case basis, to pass on the data for this purpose to investigative authorities. Apart from that, any other analysis of data is done in anonymous form as much as possible. After the end of this period, the IP address and log files are deleted, unless there are mandatory statutory storage requirements or specific prosecution- and abuse investigation proceedings pending.

3. Legal basis for data processing

The legal basis for this processing is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data are deleted as soon as they are no longer necessary to fulfill the purpose of their collection. In the case when data are collected for the purpose of making the website or mobile app available, this is the case when the respective session is over.

Log files which contain personal data are generally deleted after seven days at the latest, unless

After the end of this period, the IP address and log files are deleted, unless there are mandatory statutory storage requirements or specific prosecution is pending.

5. Possibility of objection and removal

The collection of data for the purpose of making the website or mobile app available and the storage of the data in log files are essential for the operation of the website. As a consequence, there is no objection possibility on the part of the user. Likewise, in case of error logs and breach of terms of service, there is no possibility of requesting the objection or the deletion of the log files. This decision is based on Art. 21(1) and 17(3)(e) GDPR.

6. Existence of automated decision making

InnoGames uses an automated tool to determine whether you are breaching our Terms of Services or Game Rules in regards to the usage of prohibited bots and scripts (“Bot Detection Tool”). The Bot Detection Tool serves us by analyzing the data produced by your hardware when playing our games. In case the Bot Detection Tool determines that your actions in the game are incompatible with the action produced by a human, you might be subject to receiving an automatic ban.

B) Forums

1. Description and scope of data processing

Apart from the games themselves, InnoGames offers you the opportunity to participate in the game forums. To use the forums, it is necessary to create an account using your game account and provide a username and password. The following data is processed within the context of the forums:

Note that the alias email address is automatically created by InnoGames and is not visible to others.

2. Purpose of data processing

The collection of these data serves the purpose of providing you with the service, identification towards other users, and identification of the player for the purpose of moderation, account personalization, and management.

In addition, your personal information will be shared if it is necessary to protect other users or to counter threats to state or public security or to prosecute criminal offences and if is permitted by statutory data protection provisions. Your protectable interests will be considered in accordance with the statutory provisions. Please note that InnoGames may be obliged to disclose data due to statutory provisions or, for instance, a judicial order (e.g., disclosure to investigative authorities). Disclosure always occurs only insofar as it is necessary and legally permitted or prescribed.

3. Legal basis for data processing

The legal basis for the processing of user generated content is our legitimate interests in accordance with Art. 6(1)(f) GDPR. InnoGames has a legitimate interest in preserving all individual player contributions in the forums. Each contribution offers valuable insights about the game and the community. Deleting parts of these comments not only renders the forums unreadable but also erases historical information that can assist other players in reaching their game goals.

In cases where InnoGames is legally obliged to disclose data, the legal basis for the processing is substantiated in Art. 6(1)(c) GDPR.

4. Storage duration of data

The deletion of your game account automatically leads to the deletion of your forum account. However, the deletion of your forum account does not lead to the deletion of user-generated content in the forum.

6. Inquiries via contact form, email, support tool; legal matters

1. Description and scope of data processing

In case we receive a direct inquiry from you either via contact from, e-mail or the Support tool, we need to process your data to respond to your request. In case your request requires the involvement of the legal department your data will be processed by them as well. In the same way. the legal department might need to process your data in case you are involved in a legal matter, or dispute.

a) Contact form

On our company website, a contact form is available which can be used to contact us electronically. If you choose this option, the data entered in the input mask will be transmitted to us and stored. These data are:

Additionally, at the point of sending the message, the following data are stored:

For the processing of the data, reference is made to this Privacy Notice in the context of the submission process.

b) Email

Alternatively, it is possible to contact us via our provided email addresses. In this case, the personal data of the user transmitted with the email is stored.

c) Support tool

Alternatively, you can contact us via our support tool integrated into our Service. It will then store your user data and the content of the support inquiry as well as the time of the inquiry.

The data are used exclusively for the processing of the conversation.

d) Legal matters

The legal department supports other departments of InnoGames. They either work independently or with the help of other third-party consultants. In case the legal department is involved in your case, the data processed includes, but is not limited to:

The exact types of personal data processed by the legal department depend on the matter or dispute you are involved in.

2. Purpose of data processing

The processing of personal data serves us to process the contact and the support request by the responsible departments.

In case your contact relates to a legal matter, or a dispute between you and InnoGames, and this matter or dispute requires the attention of the legal department, the processing of your data will serve the purpose of handling legal matters or disputes, fulfilling legal obligations, complying with regulatory requirements, and to support the business units in obtaining and interpreting court orders and judgments, including accompanying and negotiating disputes.

The other personal data processed during the submission process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for this data processing is legitimate interest, Art. 6(1)(f) GDPR.

The legal basis for the processing with the purpose of concluding a contract or serving the contract execution is performance of a contract, Art. 6(1)(b) GDPR.

The legal basis for the processing with the purpose of fulfilling legal obligations and/or complying with regulatory requirements, is performance of a legal obligation Art. 6(1)(c) GDPR.

The legal basis for the processing with the purpose of establishing, defending, or exercising legal claims is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data are deleted as soon as they are no longer necessary to fulfil the purpose of their collection.

The retention duration of data used for managing legal matters or disputes is determined either by the applicable limitation period, or by the relevant legal obligations to preserve records, such as Section 147 German Fiscal Code (Abgabenordnung) and Section 257 German Commercial Code (Handelsgesetzbuch). In cases where the same data is also used for another purpose outlined in this Privacy Notice, the retention period related to that purpose also applies.

5. Possibility of objection and removal

At any time after contacting us, you have the option to object to personal data processing, regardless of whether this was done via a contact form, email or support tool. In such a case, the conversation cannot continue, and your concern may not be conclusively handled. If you wish to delete all personal data stored in the course of contacting us, you have the possibility to delete your account yourself at: https://goodbye.innogames.com/login . Moreover, we will automatically delete your account if you have not logged in to a game or game forum in three years. This shall not apply if mandatory statutory retention requirements are applicable.

Note, however, that there may be certain situations in which the continuous processing of your data is necessary for the establishment, exercise or defense of legal claims, and so your right to object and request erasure will preclude, as per the Art. 17(3)(e), and Art. 21(1) GDPR.

7. Submission of newsletters

1. Description and scope of data processing

Our newsletter is to inform you about product changes and new releases, to promote our products, to create call-to-action messages and generate more interest in our games, and to hand out gifts to players’ subscribers.

With your consent, we collect your e-mail to provide you with newsletters, and manage and analyze their delivery. Note, furthermore that the so called “Bounce list” is a part of the newsletter management. Bouncing lists are made up of email addresses that have previously bounced back or failed to receive our newsletters. By removing these addresses from our mailing list, we can improve the deliverability of our newsletters and maintain a positive reputation as a sender.

Our newsletters contain a pixel-size image (tracking pixels), which is retrieved by a server of the newsletter sender when the newsletter is opened. As part of this retrieval, technical information, such as information about your browser or operating system, as well as your IP address, location, and time of retrieval, is collected. This information is anonymized and evaluated independently of the individual.

2. Purpose of data processing

The purpose of this data processing is to provide you with our newsletters and to manage their delivery. This includes information regarding the newsletter delivery success rate, which includes a list of the e-mails to which the newsletter was not able to be delivered, called “Bouncing list”.

3. Legal basis for data processing

The legal basis for this data processing is consent, Art. 6(1)(a) GDPR.

4. Storage duration of data

We store your e-mail for the purpose of sending you newsletters for as long as you are a newsletter subscriber. Your e-mail will no longer be used for sending you newsletters once you revoke your consent.

5. Possibility of objection and removal

Since the submission and receipt of the newsletter depend on your consent, you can revoke this consent for collection and storage of your data at any time without providing the reasons for it. For this purpose, you can also use the unsubscribe link which can be found at the end of each of our newsletters.

Additionally, you have the option to opt-out of receiving newsletters in the Data Usage Window inside any of our games under “Settings”.

8. Submission of push notifications

1. Description and scope of data processing

If you have selected the appropriate settings on your device, InnoGames can send push notifications to your mobile device to give you updates for games and other relevant news.

2. Purpose of data processing

Push notifications are special notifications which are displayed directly on your mobile device. The notifications contain, for instance, the information that one of your buildings in the game has been completed. As a rule, push notifications contain short messages which focus on the essential.

3. Legal basis for data processing

The legal basis for this data processing is performance of contract, Art. 6(1)(b) GDPR.

4. Storage duration of data

The messages are stored within our push gateway for up to 21 days. The messages are also stored in anonymized form in our event tracking system for an indefinite amount of time. To our knowledge, messages may be stored by the supplier of your mobile device.

5. Possibility of objection and removal

You can switch off the push notifications as follows:

a) Android

Open “Settings” > “Apps & notifications” > “Notifications” > “App notifications” > “name of the app”. On this screen you can control if and how Push Notifications are shown to you.

b) iOS

Open “Settings” > “Notifications” > “name of the app”. On this screen you can control if and how Push Notifications are shown to you.

c) Data Usage Window

Additionally, you have the option to opt-out of receiving push notifications in the Data Usage Window inside any of our games under “Settings”.

9. Use of cookies

1. Description and scope of data processing

In order to ensure that you receive the most relevant information and the best service when you visit one of our websites, data will be collected through the use of cookies. It helps us (and other authorized third parties) to provide you with a personalized experience when you visit our website, and it also allows us to improve our service and ensure that you will easily find what you want.

Cookies are small pieces of data (text files) that are sent to your browser from a web server and stored on your device so that the website can recognize your device. There are two types of cookies, permanent (or “persistent”) and temporary (or “session”) cookies. Permanent cookies are stored as a file on your computer or mobile device for a longer period of time. Session cookies are temporarily placed on your computer when you visit our website but are erased when you close the browser. If you do not want to accept cookies, you can adjust the settings in your web browsers security preferences, see more information on this below.

We and our service providers may use the following categories of cookies:

a) Essential Cookies

These cookies are strictly necessary for us to provide our Services. For example, we may use these cookies to authenticate and identify our members when they use our Site so we can provide our Services. Without these cookies we would not be able to recognize you and you would not be able to access our Services. They also help us to enforce our Terms and Conditions and maintain the security of our Services.

b) Functionality Cookies

These cookies are not strictly necessary but allow us to personalize your online experience of our website. For example, they allow us to remember your preferences and mean that you do not need to re-enter information you have already provided e.g., when signing-up to our Services. We also use these cookies to collect information (e.g., popular pages, viewing patterns, click-throughs) about our visitors' usage of our Services so that we can improve our services and conduct market research. If you choose to delete these cookies, you will have limited functionality of our Services.

c) Advertising Cookies

These cookies use information about your usage of our websites, e.g., the pages you visit or your response to ads, to deliver ads that are more tailored to you, both on and off our website. These types of ads are called “interest-based advertising.” Many of these types of cookies belong to our service providers. For third party advertisers, see more below.

2. Purpose of data processing

We use the information from cookies to make our website user-friendly and enable us to provide you with personalization features (first-party cookies). We may also pass on information from cookies to several authorized third parties to deliver services they provide on their website (third-party cookies).

We may use session cookies to allow you to move between pages on our website without having to re-enter information.

Permanent cookies are used in several ways, including:

We (and our authorized third parties) may use non-personal information from both permanent cookies and session cookies for statistical purposes as follows:

We set and read our own cookies to provide the following functions (first-party cookies):

a) Remember Me Cookie

To provide you with ‘remember me’ functionality: We allow users to log into the game via this cookie. This can be disabled by deselecting “Remember Me” on manual login. If you select the "Remember Me" function, a permanent cookie will be installed in the device you are using, so that you do not need to log in again when browsing the Services. If you log out of a Service, the cookie will be deleted again.

b) Language Version Cookie

To ensure the right language version of the game is shown to you.

c) Portal Cookie

To allow us to optimize our landing pages and improve our marketing: we store details of the landing page you visited as well as an identifier in a cookie.

d) 3rd Party Snippet Cookie

We set a cookie to record your decision about 3rd party tracking snippets and cookies.

We also use several third-party cookies as part of our Services. These cookies are governed by the respective sites and are not controlled by us. You can switch off the installation of some of these cookies in your general browser settings, for others you will need to go to the respective websites and follow the instructions provided.

For instance, it is checked which language version you use to access our Services. If you became aware of our Services through one of our partners, we store the information on who the partner is.

Third party advertisers: We may use advertisers, third party ad networks, and other advertising companies to serve advertisements on our Services. Please be advised that such advertising companies may gather information about your visit to our Services or other sites to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. Please note that the collection and use of information by third party advertisers is not covered by this Privacy Notice.

3. Legal basis for the data processing

The legal basis for this data processing legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data is deleted as soon as it is no longer necessary to fulfil the purpose of its collection.

5. Possibility of objection and removal

If you do not want these cookies to be stored on your computer or wish to be informed of their storage, you can prevent the installation of cookies by a corresponding adjustment to your browser software by selecting the option "do not accept cookies" in your browser settings or declining the use of third-party tracking on the first visit to the website. Your browser manufacturer's instructions will give you more details on how this works. However, we would like to point out that by preventing cookies, you may find that you cannot use all the website's functions to the full extent.

a) Android

Open “Settings” > “Privacy” > “Ads”. On this screen you can control if and how ad personalization on this device occurs.

b) iOS

Open “Settings” > “Privacy & Security” > “Tracking”. On this screen you can control if and how apps can track you across other companies’ apps and websites. Additionally, open “Settings” > “Privacy” Security” > “Apple Advertising”. On this screen you can control if and how Apple shows you personalized ads.

c) Data Usage Window

Additionally, you have the option to opt-out of using third-party tracking in the Data Usage Window inside any of our games under “Settings”.

10. Use of third-party analysis services

1. Description and scope of data processing

a) Game analysis services

When you use our Services, InnoGames and our third-party analysis service partners collect personal data. This is either done by placing a cookie in the cache of your browser, via an SDK embedded in our apps, or via a link in an email, which sends information to our Partners. The data generally includes your IP address and in-game events.

b) Other analysis services

When you visit the “Career” section of our company website and our LinkedIn company page, InnoGames and our third-party analysis service partners collect personal data. This is done by placing a cookie in the cache of your browser which communicates with the LinkedIn servers. If you are a LinkedIn user, LinkedIn will transmit an anonymized summary of your personal data to us for statistical purposes.

2. Purpose of data processing

a) Game analysis services

InnoGames makes use of these third-party analysis services to detect and prevent breaches of InnoGames’ Terms of Service, to detect and prevent fraud, to measure the success of marketing and newsletter campaigns, to track in-game-events to create user-related activity statistics, to measure the player’s reaction to version changes, to measure the performance on different devices, as well as to measure the compatibility, performance and stability of the current game version.

b) Other analysis services

InnoGames makes use of these third-party analysis services to manage and analyze the effectiveness of job postings and improve the user experience of the Career section of our company website. In addition, the data collected is used to analyze the performance of marketing campaigns and generate performance reports.

3. Legal basis for data processing

a) The legal basis for the data processing for game analysis services is performance of contract, Art. 6(1)(b) GDPR.
b) The legal basis for the data processing for other analysis services is legitimate interests, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data will be retained by us for the duration of use of the Service. Our partners will retain inquiry information, analytics Information and contact information for as long as necessary for business purposes, and thereafter as needed for record-keeping matters.

5. Data recipients

11. Use of third-party customer support services

1. Description and scope of processing

Apart from InnoGames’ game support channels, InnoGames maintains an active profile in various social media networks, which we use to communicate and engage with our players, as well as to promote our products and services. InnoGames makes use of third-party customer support services to manage these interactions and make sure that all your contact with us is attended to. InnoGames also uses such customer support services to facilitate the communication of important notices by incorporating shortened versions of links in our social networks’ publications.

Moreover, InnoGames uses machine translation tools to translate the content of messages sent to us in foreign languages. The data transferred to the service providers will be limited to the content of your message and will only be stored as long as necessary for achieving the purpose of translating.

2. Purpose of data processing

InnoGames makes use of these third-party customer services tools to facilitate information sharing and manage our communication with you.

3. Legal basis for data processing

The legal basis for this data processing is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data will be retained as long as it is necessary to fulfil the purpose of its collection, unless you request earlier deletion.

5. Data recipients

12. Use of third-party email services

1. Description and scope of processing

In case you registered to receive newsletters from us, or in case we need to communicate with you via e-mail about your account, including but not limited to your progress in the game, or reset of your password, this will occur via third-party service providers. In order to manage the sending of newsletters, the emails contain a pixel-sized image (pixel code) that is retrieved by the service providers server when the newsletter is opened. For the processing the email communication InnoGames shares your account name and email with the third-party email services.

2. Purpose of data processing

InnoGames makes use of these third-party services to provide you with newsletters and communicate with you via email.

3. Legal basis for data processing

The legal basis for the processing with the purpose of sending newsletters is consent, Art. 6(1)(a) GDPR. The legal basis for the processing of data with the purpose of communication about the account is the performance of a contract, Art. 6(1)(b) GDPR.

4. Storage duration of data

The data will be retained as long as you register for receiving our newsletter or maintain an account with us and will be deleted as soon as you withdraw your consent or request the deletion of your data.

5. Data recipients

13. Use of third-party login services

1. Description and scope of the data processing

Our games offer the possibility to log in to our Services via third-party login services. If you use them, an additional registration for our Services is not necessary. You will be redirected to an external service where you can log in with your account. This links your account on the external service with a guest account on our Services. Through the link, we automatically receive personal data from the external service. The following data is transferred to us: Your email address used to register with the external service and any additional information you select to share during authentication. When using Sign-in with Apple you can additionally choose whether we receive your actual email address or a randomly generated email address that links to your account.

2. Purpose of the data processing

The third-party login services help us to simplify login for new users who do not wish to create a new account on our Services.

3. Legal basis for the data processing

The legal basis for this processing is performance of contract, Art. 6(1)(b) GDPR.

4. Storage duration of data

The data is retained for as long as your account with our Services exists.

5. Objection and deletion

You can object to this processing by unlinking your account on the third-party login service from your guest account on our Services. You can delete any data stored during processing on our Services by deleting your account as described below at Section 21.

6. Data recipients

14. Use of third-party market research services

1. Description and scope of data processing

InnoGames makes use of market research tools offered by third parties to understand your preferences better. The better we understand what your preferences are when playing our games, the more attractive to you will be services we offer. Our market research can take a form of an app store optimization test, in which your choices will registered, and you will be asked to provide insights of which app characteristics are more appealing to you, or we might simply ask you to participate in a survey and share your experience in our games with us. When you participate in our market research, we and our Partners collect your technical, device, usage data, and the answers you gave us. This helps us to determine how we can improve the services we offer.

2. Purpose of data processing

InnoGames makes use of these services in order to carry market research to improve existing and/or future products.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of market research is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data will be retained as long as it is necessary to fulfil the purpose of its collection, unless you request earlier deletion.

5. Data recipients

15. Use of third-party payment services

1. Description and scope of processing

Additional to our free-to-play game services, InnoGames offers premium services to our players. In case you decide to purchase one of InnoGames’ premium service. InnoGames will transfer your personal and/or billing related data to these payment partners. This is required for the fulfilment of the contract, for payment processing as well as for the protection of other users and is legally permitted or prescribed.

In addition, your personal information will be shared if it is necessary to protect other users or to counter threats to state or public security or to prosecute criminal offences and if is permitted by statutory data protection provisions. Your protectable interests will be considered in accordance with the statutory provisions. Please note that InnoGames may be obliged to disclose data due to statutory provisions or, for instance, a judicial order (e.g., disclosure to investigative authorities). Disclosure always occurs only insofar as it is necessary and legally permitted or prescribed.

2. Purpose of data processing

InnoGames makes use of third-party payment services to carry out payment transactions. In the event of payment delay, we may commission a debt collection agency or a lawyer to collect the outstanding debt.

3. Legal basis for data processing

The legal basis for this data processing is performance of contract, Art. 6(1)(b) GDPR.

4. Storage duration of data

Your personal and/or billing related data will be retained by InnoGames for maximum of 3 years from the purchase date before it undergoes an anonymization process. After your data has been anonymized, your data will be retained for legal and statutory purposes for up to 10 years.

5. Data recipients

16. Use of third-party social networks

1. Description and scope of data processing

InnoGames is present in various social networks. We use social media for different purposes: from promoting our company to acquire good talents to become part of our team, for building and managing our communities, as well as, marketing our games to you. Social networks can comprehensively analyze your user behavior when you visit their websites or sites with integrated social media content, including but not limited to like buttons, banner advertisements, etc., so visiting our social media presences will trigger several processes which are relevant to data privacy. For details, please refer to the terms of use and data privacy policies of the respective social media portals.

2. Purpose of data processing

InnoGames makes use of third-party social networks for product and HR marketing, customer relationship management, as well as to build and grow our community.

3. Legal basis for data processing

The legal basis for this data processing is legitimate interest, Art. 6(1) (f) GDPR.

4. Storage duration of data

The data will be retained as long as it is necessary to fulfil the purpose of its collection, unless you request earlier deletion.

5. Data recipients

17. Use of third-party user acquisition services

1. Description and scope of processing

InnoGames relies on digital advertising to promote our Services. We use various advertising networks to show our banner, interstitial or video ads. Our partners are compensated when you install our game, therefore when you click on our ad and install our app both InnoGames and the partners collect your data to later compare it with against each other to determine the amount of compensation is due. Your data is collected by the advertising network’s cookie or SDK that is placed on our Services.

2. Purpose of data processing

InnoGames makes use of these services in order to grow our player base, as well as to enable cross-selling between InnoGames’ products.

3. Legal basis for data processing

The legal basis for this data processing is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data will be retained as long as it is necessary to fulfil the purpose of its collection, unless you request earlier deletion.

5. Data recipients

18. Use of third-party video advertising services

1. Description and scope of processing

Since our games are generally free to download and play, to be able to maintain and continuously develop our games we monetize them by displaying ads in them. When displaying ads, we use third-party advertising companies to serve the ads in our games. The advertising companies pay us for displaying their ads and this what makes it possible for us to offer you the game free of charge. Apart from this, we might also give you the possibility to watch an ad instead of paying for a feature that you otherwise would have to pay. The third-party advertising companies may collect and use some of your personal information, including but not limited to IP address, geo location, and language settings to offer you personalized ads, but also to know if you clicked on and watched the video ad. Non-personally identifiable information to manage and measure the delivery of advertising within that game can be collected, including the number of times the same advertisement is served and viewed.

2. Purpose of data processing

The data is processed by us to provide advertisements about goods and services of interest to you. We offer our mobile games for free, so these ads allow us to continue making and updating top quality free games which is a legitimate interest of ours but also of yours if you want to play games for free. Without displaying ads, we would not make sufficient money to keep offering the games for free to you. Please do not play our games if you do not wish to have your personal data processed for advertising purposes.

3. Legal basis for data processing

a) iOS and browser

Personalized Ads: The legal basis for processing your personal data (especially your IDFA) for personalized ads on iOS is your consent, Art. 6(1)(a)GDPR, which you grant us by allowing tracking through the pop-up at the start of the game.

You can revoke your consent with effect for the future as follows:

iOS: Select “Ask App Not to Track” in the consent pop-up at the start of the game (if you haven’t already disabled tracking in your system settings). If you want to withdraw your consent later: Open “Settings” > “Privacy & Security” > “Tracking”. On this screen you can control if and how apps can track you across other companies’ apps and websites. Additionally, open “Settings” > “Privacy” Security” > “Apple Advertising”. On this screen you can control if and how Apple shows you personalized ads.

Browser: Deselect “Allow third party browser cookies and pixels” in the Data Usage Window of the game.

Non-Personalized Ads: The legal basis for processing your personal data to display ads that are not personalized is a legitimate interest of ours, Art. 6(1)(f) GDPR. We offer our games for free. To be able to keep doing this we show advertisements in our games for which the advertising companies pay us. Without this, we would have to charge a fee for you to play our games. It is a legitimate interest of ours to process your data to display ads that are not personalized to be able to keep providing you our games free of charge and so we remain able to compete with other companies on the market and create great and entertaining games that a large audience can enjoy, no matter how much money one is able to spend. This interest outweighs a potential contrary interest of yours if you do not want your data to be processed to display ads. Unfortunately, it is technically not possible to efficiently display ads without processing some of your personal data for this purpose. Please do not play our games if you do not wish to have your personal data processed for us to display non-personalized ads.

b) Android and Fire OS

Personalized and Non-Personalized Ads: The legal basis for processing your personal data to display personalized ads as well as ads that are not personalized is a legitimate interest of ours, Art. 6(1)(f) GDPR). We offer our games for free. To be able to keep doing this we show advertisements in our games for which the advertising companies pay us. Without this, we would have to charge a fee for you to play our games. It is a legitimate interest of ours to process your data to display ads that are not personalized to be able to keep providing you our games free of charge and so we remain able to compete with other companies on the market and create great and entertaining games that a large audience can enjoy, no matter how much money one is able to spend.

You can opt-out of having your personal data processed for personalized ads as follows:

Android: Open “Settings” > “Privacy” > “Ads”. On this screen you can control if and how ad personalization on the device occurs.

Fire OS: Open “Settings” > “Security & Privacy” > “Advertising ID” > “Interest-Based Ads”. On this screen you can control if and how ad personalization on the device occurs.

Opting out of having your personal data processed when we display non-personalized ads is unfortunately not possible. In case of non-personalized ads, our legitimate interest to process data to display such ads (see above) outweighs a potential contrary interest of yours. Unfortunately, it is technically not possible to efficiently display ads without processing some of your personal data for this purpose. Please do not play our games if you do not wish to have your personal data processed for us to display non-personalized ads.

4. Storage duration of data

The data will be retained as long as you maintain your account with us. Note that by playing as a guest, that is, even if you have not registered and confirmed your e-mail with us, you still maintain an account with us (“Guest Account”). Additionally, your account will be deleted after 3 years of inactivity, or earlier if you actively request its deletion as described in Section 20.

5. Data recipients

19. Use of other third-party services

1. Description and scope of data processing

InnoGames makes use of different third-party services for hosting our company website and to managing your interaction with our Services. In case you access one of our pages featuring a relevant map, map content is retrieved from Google's servers. If you are signed in with your Google account, Google can merge your browsing behavior with other information. When you access a Service featuring a form or other way to input information, a CAPTCHA is retrieved from Google’s servers. The CAPTCHA analyzes your input behavior based on various characteristics (e.g., IP address, length of stay, mouse movements) to discern if you are a human or a machine.

2. Purpose of data processing

InnoGames makes use of third-party service provider to host the company website, to provide end-users with contact form services, display open positions and manage applications, manage end-users’ interaction with our websites, as well as to secure our website from fraud and spam.

3. Legal basis for data processing

The legal basis for the data processing the purpose of interacting with us via our websites is legitimate interest, Art. 6(1)(f) GDPR.

The legal basis for the data processing for the purpose managing your application for a position with InnoGames is consent, Art. 6(1)(a) GDPR.

4. Storage duration of data

The data will be retained as long as it is necessary to fulfil the purpose of its collection, unless you request earlier deletion.

5. Data recipients

20. Group Cooperations

I - Joint Controllership

What does joint controllership mean?

In some cases when we cooperate with MTG and/or a Group Company we jointly determine if and how certain personal data of yours is processed. In such a case the companies involved are each controllers of your data when doing so and the working relationship is called a joint controllership. We have concluded an agreement with MTG and all Group Companies in which the rules for our joint controllership are set out and which also includes so called standard contractual clauses that ensure that personal data of European players is adequately safeguarded when transferred between us and Group Company that is not established in the European Union or a country considered to have the same level of data protection as the European Union.

A) Mergers & Acquisitions

1. Description and scope of processing

MTG, the Group Companies and we can support each other when buying or selling a company. In such cases a strictly limited number of personnel involved in such a transaction can receive access to personal data (e.g., names, email addresses, unique identifiers) included in relevant documentation shared by a potential seller or determine which personal data is shared with a potential buyer and how this shall be done. Principally, personal data is anonymized before it is disclosed and, should it be necessary to disclose personal data, such disclosure of personal data will be kept to a minimum.

2. Purpose of data processing

The purpose of such a cooperation is to review relevant material shared with us by a potential seller, so we and/or MTG, and/or the involved Group Companies can make good business decisions, or to enable a potential buyer to do so when sharing such data with it. This is a legitimate interest of ours, MTG, the involved Group Companies, and the potential sellers or buyers.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of Mergers and Acquisitions is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The storage period for data processed for the purpose of handling legal matters or disputes is governed by the relevant limitation period, so that we can sufficiently defend ourselves against claims, and by relevant legal obligations to retain documents. If a transaction has been successful, we might be obliged to store the respective personal data according to the applicable statutory provisions, in which case we will store the documents according to the retention periods stated in such provisions. Personal data that is no longer relevant if a transaction has not been successfully made, will be deleted if it is not relevant for another purpose under this privacy policy.

5. Recipients of data

Recipients of the processed personal data can be our providers of office tools, providers of data rooms as well as external financial and legal advisors, MTG, involved Group Companies, and the potential buyer. We can receive your personal data from a Group Company, or a potential seller in which case the same recipients can apply.

B) Business Intelligence

1. Description and scope of data processing

We share a limited amount of data with MTG to get a better understanding of how you play our games and what you like about them so we can improve them. This includes a group-internal unique identifier, game title, time of install, platform, country code per install, marketing channel/category and marketing campaign, browser information, engagement with the game (login sessions), amount of money spent in the game, and how effective a marketing campaign was.

2. Purpose of data processing

A better understanding of how you play our games and what you like about them helps us make them better and improve how we market them. As a gaming studio, it is essential for us that we can understand how games are played and how effective our marketing efforts are to ensure that enough players enjoy our games so we can keep making them. This interest is shared by MTG and the Group Companies.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of Business Intelligence is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The data is stored for as long as you are an active player of the game. Your data will be deleted or anonymized after 3 years of inactivity, which depends on the date of your last time you played a game of ours.

5. Recipients of data

The recipient of the processed personal data is our parent company, MTG. The information is not shared with Group Companies.

C) Data Protection Compliance Work

1. Description and scope of data processing

MTG supports us with our data protection compliance work. We can jointly process personal data of yours required to ensure compliance with data protection laws, e.g., names, email addresses, usernames, unique identifiers (e.g., game-ID players). E.g., this can be the case when you reach out to us with a data protection request, and we seek MTG’s support to respond adequately and in time.

2. Purpose of data processing

We want to be able to offer you a high level of data protection when you play our games. To ensure that we comply with relevant data protection laws we receive support from MTG. This is a legitimate interest of ours, MTG, the other Group Companies and you.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of data protection compliance work is legitimate interest, Art. 6(1)(f) GDPR and compliance with a legal obligation, Art. 6(1)(c) GDPR.

4. Storage duration of data

The data will be stored for duration that we need to be able to prove that we are complying with data protection laws. Due to this, data protection requests of yours will be stored for (…) years.

5. Recipients of data

Recipients of the processed personal data can be our providers of office tools and MTG.

II – Other Cooperations

Apart from cases in which we jointly process personal data, we cooperate within the group in the following cases:

A) Developing or distributing Games

1. Description and scope of data processing

MTG can support us when we are developing or distributing our games (e.g., consulting regarding game features or functionalities). In the process of this it is possible that certain personal data of players of our games might be disclosed to MTG, such as names, email addresses, usernames, or unique identifiers. Such personal data will not be actively stored or used by MTG for such support.

2. Purpose of data processing

Since we are part of the same group and MTG is our parent company, we both share the legitimate interest of developing and distributing great games. To be able to do this we work closely together.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of developing or distributing games is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

The personal data is stored by us according to the applicable retention periods of this privacy policy (e.g., the retention period for your account data).

5. Recipients of data

Recipients of the processed personal data can be our providers of office tools and MTG.

B) Legal Support

1. Description and scope of data processing

MTG supports us with legal guidance regarding legal complaints, claims, court proceedings or other legal matters we might be facing. In such cases MTG might receive personal data (e.g., names and contact details of plaintiffs or complainants) of persons involved in such legal matters from us.

2. Purpose of data processing

Since we are part of the same group and MTG is our parent company, we both share the legitimate interest of effectively handling legal complaints, claims, court proceedings or other legal matters we might be facing. To be able to do this, we work closely together.

3. Legal basis for data processing

The legal basis for processing your personal data for the purpose of legal support is legitimate interest, Art. 6(1)(f) GDPR.

4. Storage duration of data

Data will be retained according to legal obligations (e.g., employment laws) or our legitimate interest of defending ourselves against legal claims.

5. Recipients of data

Recipients of the processed personal data can be our providers of office tools and MTG.

21. Rights of the data subject

If we process personal data about, you have the following rights:

1. Right of access

You can request that we inform you about the personal data we process about you. If such processing exists, you can request that we provide you with the following information:

  1. The purposes of the processing.
  2. The categories of personal data which are processed.
  3. The recipients or the categories of recipients to whom the affected personal data has been or will be disclosed.
  4. Where possible, the planned storage duration of your personal data or, if not possible, the criteria for determining the storage duration.
  5. If there is a right to request the rectification or deletion of personal data, the restriction of processing or the objection to such processing.
  6. The right to lodge a complaint with a supervisory authority.
  7. Where the personal data is not collected from you directly, any available information as to its source.
  8. The existence of automated decision-making, including profiling, referred to in Art. 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
  9. If your personal data is transferred to a third country or to an international organization, the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer.

We will respond to your inquiry within a month upon receipt of the request.

2. Right to rectification

You can request that we rectify and/or complete your personal data, provided that the data is incorrect or incomplete. We will rectify or complete the data without undue delay.

3. Right to deletion (“right to be forgotten”)

We automatically delete all accounts after 3 years of inactivity. Additionally, you can request an earlier deletion of your account and associated personal data at any time at: https://goodbye.innogames.com/login.A deletion request is carried out within 7 days (“hard deletion”). Until then, you can still cancel the request by logging into the game (“soft deletion” grace period).

a) Obligation to delete

You can request that we delete your personal data without undue delay where one of the following applies:

  1. Your personal data is no longer necessary for the purposes for which it was collected.
  2. You have revoked your consent on which the data collection was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and no other legal basis exists for the processing.
  3. You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
  4. Your personal data has been unlawfully processed.
  5. Your personal data must be deleted to comply with a legal obligation pursuant to European Union or Member State law to which we are a subject.
  6. Your personal data has been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

b) Information for third parties

If we have made your personal data public third parties and are required pursuant to Art. 17(1) GDPR to delete the personal data, we, taking into account available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform the third parties processing your personal data that you have requested the deletion of any links to, or copy or replication, of this personal data.

c) Exceptions

The right to deletion does not apply to the extent that processing is necessary:

  1. For exercising the right of freedom of expression and information.
  2. For complying with a legal obligation which requires processing pursuant to European Union or Member State law, to which we are subject, or for performing a task in the public interest or in exercise of public authority vested in us.
  3. For reasons of public interest regarding public health in accordance with Art. 9(2)(h) and (i), as well as Art. 9(3) GDPR.
  4. For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Art. 89(1) GDPR, provided that the deletion right does not render impossible or seriously impair the achievement of the objectives of that processing.
  5. For the establishment, exercise, or defense of legal claims.

4. Right to restriction of processing

You can request that we restrict the processing of your personal data where one of the following applies:

  1. The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
  2. The processing is unlawful and you oppose the erasure of the personal data, requesting that its use be restricted instead.
  3. We no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise, or defense of legal claims.
  4. You have objected to the processing pursuant to Art. 21(1) GDPR, and it has not yet been determined whether our legitimate grounds outweigh yours.

If processing has been restricted, such personal data will, except for storage, only be processed with your consent; for the purposes of establishing, exercising, or defending legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest of the European Union or of a Member State.

If the processing restriction was imposed pursuant any of the above circumstances, we will inform you before the restriction is lifted.

5. Right to briefing

If you assert the right to rectification, deletion, or restriction of processing, we will notify each recipient to whom your personal data was disclosed of this, unless this proves impossible or involves disproportionate effort. We will inform you about these recipients if you request it.

6. Right to data portability

You have the right to receive your personal data which you have provided to us in a structured, commonly used, and machine-readable format. Furthermore, you have the right to transmit this data to another controller without hindrance from the controller from us, provided that:

  1. The processing is based on consent pursuant to Art. 6(1)(a) GDPR, or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR, and
  2. the processing is carried out by automated means.

In exercising this right, you have the right to request that your personal data concerning is directly transmitted from one controller to another, where technically feasible.

The right of data portability shall not apply to processing personal data necessary for the performance of a task carried out in the public interest or in exercise of public authority vested in us.

This right to data portability shall not adversely affect the rights and freedoms liberties and rights of others.

7. Right to object

You have the right, on grounds relating to your particular situation, at any time to object to the processing of your personal data on the basis of Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions. We will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

If personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.

in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by using automated means using technical specifications.

8. Right of withdrawal of consent

You have the right to withdraw your declaration of consent pursuant to data protection law at any time. Withdrawal of consent shall not affect the lawfulness of data processing based on consent effective prior to its withdrawal.

How you withdraw your consent will depend on how you access our games. You can revoke your consent with effect for the future as follows:

9. Automated individual decision-making, 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 affects you in a significant manner.

The above shall not apply if the decision:

  1. Is necessary for entering into, or performance of, a contract between yourself and us,
  2. is authorized by European Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  3. is based on your express consent.

In the cases referred to in points (1) and (3), we will implement suitable measures to safeguard your rights and freedoms and legitimate interests, entailing, at least the right to obtainn human intervention on our part, to express your point of view and to contest the decision.

Decisions referred to above shall not be based on special categories of personal data referred to in Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

10. Right to lodge a complaint with 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 habitual residence, place of work or place of the alleged infringement if you consider that processing of your personal data infringes the GDPR.

22. Privacy Information for California residents

1. General information

If you are a consumer residing in California, the California Consumer Privacy Act (“CCPA”) applies when you use our Services. The CCPA defines personal information and sensitive personal information as follows:

All the information we provide throughout this Privacy Notice in regards which personal data we process, and for which purposes we process it, apply correspondingly to cases in which we process Personal Information of yours as resident of California.

2. Recipients of data

We may share personal information with third parties for certain purposes. For example, we share personal information with:

We value your trust and are committed to safeguarding your personal information. If you have any questions or concerns about the way we share your data with third parties, please don't hesitate to contact us.

3. Your rights under CCPA

If you are a resident of California, you have the following rights:

a. Right to Delete Personal Information: You have the right to request that we delete your Personal Information. Depending on the specific case, exceptions can apply to this right, e.g., if we have to keep your information to comply with legal obligations or to ensure the freedom of expression (Section 1798.105 CCPA).

b. Right to Correct Inaccurate Personal Information: You have the right to request the correction of Personal Information we maintain about you (Section 1798.106 CCPA).

c. Right to Know What Personal Information is Being Collected: You have the right to request the following information from us (Section 1798.110 and 1798.115 CCPA):

4. Right to opt-out of sale and sharing

We do not sell your Personal Information. We share your Personal Information with advertising partners to show you ads that might be more interesting to you. You have the right to opt out of any sale or sharing of your Personal Information (Section 1798.120 CCPA). Please see Section 21. 8 (“Rights of the data subject - Right of withdrawal of consent”) of this Privacy Notice on how to do this.

5. Right to limit the use and disclosure of sensitive personal information

We only process Sensitive Personal Information of yours (e.g your account log-in) with the purpose of providing you access to the games and process any purchase you might have done within the game, and do not disclose any of these data to third parties, unless we are under legal obligation to do so. You have, however, principally the right to limit the use or disclosure of your Sensitive Personal Information should we be using such data of yours beyond what is reasonable and proportionate to provide the requested services or other purposes permitted by the CCPA (Section 1798.121 CCPA)

6. Right of no retaliation following opt out or exercise of other rights

If you exercise your CCPA rights, you have the right that we do not unlawfully treat you in a detrimental way (Section 1798.152 CCPA). Please note though, that depending on your request, features within our game might not work the same way as they would have without your request (e.g., if you want to see ads that might interest you more).

23. Final provisions

We may modify, supplement, or replace this Privacy Notice from time to time, and may do so at our discretion, consistent with applicable data protection laws and rules. Any revisions to our Privacy Notice will be posted here at https://privacy.innogames.com , as well as a notice in a prominent location on the Services. You are required to acknowledge receipt of the Privacy Notice to continue to use our Services. Any revised policy will supersede and replace previous privacy notices, effective as of the date on which they are posted. Your use of the Services after any revised Privacy Notice has been posted confirms your acknowledgement to all such changes.

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