Privacy Policy

I. General information
1. Responsible body, introduction
We are gameXcite GmbH, located at Bernstorffstraße 120, 22767 Hamburg, and you can contact us by mail or email at [e-mail].

The protection of your privacy is very important to us. Therefore, we explain below which personal data we collect and process when using our services or taking advantage of our offers. Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. These include, for example, their name, email address or phone number.

The collection, processing (including storage, modification, transmission, blocking and deletion) and use of your data takes place in compliance with the provisions of the Data Protection Act. Personal data are only collected, used and passed on if this is permitted by law or if the users give their consent to the collection of data and if this is technically or legally necessary for the provision of the service. In no case will the data collected be sold or otherwise transferred to third parties without your consent.

You can visit our website without giving any explicit information about yourself. Although we will process your IP address, the name of your internet service provider, the page from which you visit us or the name of the requested file, we will store it in log files without any further personal data. This evaluation is carried out solely for analytical and statistical purposes, to improve our services, or to counteract misuse. All personal information is anonymized and no connection can be made between the information provided and the submitting user.

However, if you wish to use our services and offers (e.g., games) or subscribe to our newsletter, personal information must be collected, processed and stored. This includes your email address, your IP address and, if applicable, an individual password (for logging into our website and games) or payment data (for ordering paid services). In addition, in order to ensure the proper operation of the game services and sanction violations of the Terms of Use, it is necessary to record certain actions within our website and games, including the time and place of logins, use or trading of virtual items or messages to other players or in the public chat of each game.

Further details on the data collected and their use can be found in Section II.

2. Legal basis
We collect and process personal data based on the following legal bases:
– Consent pursuant to Article 6 (1) (a) of the General Data Protection Regulation (GDPR). Consent shall be any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, in which the data subject indicates that he agrees with the processing of the personal data concerning him or her
– Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 (1) lit. b GDPR, i. the data is required so that we can fulfill our contractual obligations to you or we need the data to prepare a contract with you.
– Processing to fulfill legal obligations under Article 6 (1) (c) GDPR, i. that, for example, are required by law or regulation to process the data.
– Processing in order to safeguard legitimate interests in accordance with Article 6 paragraph 1 lit. f GDPR, i. that the processing is necessary to protect the legitimate interests of us or third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail.

3. Affected rights
You are entitled to the following rights with regard to the processing of data by us in the scope according to the respectively listed articles of the General Data Protection Regulation:

– Right to information pursuant to Art. 15 GDPR
– Right to correction in accordance with Art. 16 GDPR
– Right to be erased (“right to be forgotten”) in accordance with Art. 17 GDPR
– Right to restriction of processing according to Art. 18 GDPR
– Right to data portability in accordance with Art. 20 GDPR
– the right of objection according to Art. 21 GDPR

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of its residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the GDPR.

4. Data deletion and storage duration
The user’s personal data will be immediately deleted from our system once it is no longer needed. In addition, such storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. A blocking or deletion of the data takes place even if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for a contract or fulfillment of the contract or you have explicitly agreed to the further use of your data.

5. Integration of third party providers
It is possible that third party content (hereinafter referred to as “third party”), such as videos from Youtube.com, will be included in our website and games. This always presupposes that the third party providers use the IP address of the user, since they could not send the content to the browser of the respective user without this. Therefore, the IP address is required to display this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. However, we have no control over a third party’s IP address, for example, if they store it for statistical purposes. As far as we know such a circumstance exists, we will inform users about it.

Our websites and products may further contain advertising or third party services (such as the Facebook Like button or links to third party websites). If you click on those links, including an advertisement, you will leave our website and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site’s or service’s privacy policy. gameXcite GmbH does not verify the data protection conditions of third parties.

6. Data provided to us by third parties (usage via third parties)
By signing up to play our games not directly on our website but via third parties such as Apple AppStore, google Play Store or Facebook Gameroom you are agreeing that these third parties share your User ID with us so that we can properly identify your game account on our servers, save your progress and deliver virtual currency purchases. We will further receive your Facebook ID if you choose to connect the game with your Facebook Account on mobile devices to independently identify you and restore your game progress.

?Please note that we are not receiving any personal data or payment details from these third parties but only pseudonymized customer data such as your User ID, country and language. Additional data that we will process in these cases is listed in chapter II. Please consult the Privacy Policies of the respective third party that you have registered with for further information on how they handle your data.
– Facebook: https://www.facebook.com/policy.php
– Apple: https://www.apple.com/de/privacy/
– google: https://policies.google.com/privacy
– gamigo: https://en.gamigo.com/pages/privacy
– Spil Games: https://www.agame.com/privacy-policy
– Kongregate: https://www.kongregate.com/privacy

II. Concrete data processing
1. Data collection when visiting the website
a) Scope of data processing
When visiting our website, the following data is collected and stored by us or our web server:
Information about the browser type and version used
The user’s operating system
The user’s Internet service provider
The user’s IP address
Date and time of access
The transferred data volume
Websites from which the user’s system comes to our website
Websites accessed by the user’s system through our website
The data is stored in the log files of our system (so-called server log files). Retention of this data together with other personal data does not occur. The website itself is hosted by and thus the this data is accessible to the external service provider Conversis GmbH, Erftstraße 11, 47051 Duisburg, Germany (“Conversis”), who will be responsible for server maintenance on our behalf. Any further use is not made by the service provider.

Our website uses at several locations so-called cookies. They serve to make our offerings more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and function through your browser. Cookies as such can not be used to identify the user. The majority of the cookies we use are called “session cookies”. They are automatically deleted at the end of your visit. Cookies do not harm your computer and do not contain viruses.

We use Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland.
Google Analytics uses is gathering information how you are using the website and is creating various statistics. Among the information gathered are the selection of links, the time spend on the individual pages and the frequency of visits together with your IP address. The IP address transmitted by your browser within the scope of Google Analytics will not be associated with other data held by Google.
Google Analytics is using what is referred to as “cookies”. These are text files which are saved on the user’s computer and allow for an analysis of the use of the website by you. As a rule, the information generated by the cookie regarding the use of this website by the users is transmitted to and saved by Google on a server in the United States. In case of activation of the IP anonymisation on this website, however, Google will previously shorten the user’s IP address within member countries of the European Union or in other contracting states of the Treaty in the European Economic Area. Only in exceptional cases, the full IP address is transmitted to a Google server in the USA and shortened there. The IP anonymisation is activated on this website. Google will use this information on our behalf in order to evaluate the use of this website by you, to compile reports on website activities and to provide further services relating to the usage of the website and the Internet usage to the website provider.

b) Legal basis
The legal basis for the processing of data is Article 6 (1) lit. f GDPR.
The legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR therefore lies in the functionality of our website and its availability.
The legal basis for the transfer of the data to the hosting service provider are Articles 28 (3), 6 and 7, Article 45 (3), Article 46 (2) (c) GDPR. The service provider is based in the European Union and is bound by the provisions of the GDPR.

c) Purpose of the data processing
The temporary storage of the IP address by the system is necessary to allow delivery of the website to the user’s computer. To do this, the user’s IP address must be kept for the duration of the session.
The data is stored in order to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. We reserve the right to retrospectively review the log files if there are specific indications of unlawful use. An evaluation of the data for marketing purposes does not take place in this context.

d) Duration of storage
The log files will be deleted after a maximum of seven days, unless there is a need to retain the data for the aforementioned purpose due to specific events.
Additional storage is possible. In this case, users’ IP addresses are deleted or obfuscated, so that an assignment to a specific user is no longer possible.

e) Opposition and removal option
The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no contradiction on the part of the user.

Of course, you can also use the websites and games operated by us without cookies by setting the browser so that you generally reject cookies or inform you about a cookie so that you can decide at any time whether you accept it or not , You can manually delete cookies that already exist on your computer from your hard drive at any time. Please note, however, that the use of the website and the games without cookies may be limited.

Furthermore, users can prevent Google from prospectively collecting, using and processing data generated by the cookie and related to the use of the website (including your IP address) by downloading and installing the browser plugin (referred to as deactivation add-on) available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser add-on or within browsers on mobile devices (e.g. tablets or smartphones) please click this link in order to prevent collection by Google Analytics on this website in future. This will result in the storage of an opt-out cookie on your device. If you delete your cookies in this browser, you must click this link again.

2. email and newsletter delivery
a) Scope of data processing
If you use our website and games and deposit your email address here, we can subsequently use it to send you emails. In such a case, your email will only receive information about important changes in our games and services.
It is also possible on our website or in our games to subscribe to a free newsletter containing direct mail for our products or products from our cooperation partners. When you sign up for the newsletter, the data from the input mask are transmitted to us or the previously stored email address is used. In this case, the date and time of registration for the newsletter and the IP address used are also stored. As part of the confirmation of the newsletter registration, the date and time at which you click on the confirmation link for the newsletter registration as well as the IP address used will also be saved.
To send the newsletter, your email address will be forwarded to our external service provider, The Rocket Science Group LLC, 675 Ponce de Leon Ave. NE, Suite 5000, Atlanta, GA 30308 USA, (“Mailchimp”), who will, on our behalf, ship the Newsletter. Any further use is not made by the service provider. The service provider is located outside the European Union in the United States of America. More information about Mailchimp and its privacy policy can be found here: https://mailchimp.com/legal/privacy/

b) Legal basis
The legal basis for the processing of the data when sending out the newsletter due to the prior acquisition of goods or services is Art. 6 § 1 lit. f GDPR in conjunction with § 7 (3) UWG. The legitimate interest within the meaning of Art. 6 § 1 lit. f GDPR is therefore in direct advertising and the increase in sales to existing customers.
The legal basis for processing the data when registering directly for the newsletter is Article 6 (1) (a) GDPR.
The legal basis for the transfer of the data to the newsletter service provider are Articles 28 (3), 6 and 7, Article 45 (3), Article 46 (2) (c) GDPR. The service provider is certified under the Privacy Shield Framework and is therefore subject to the EU Commission’s decision on adequacy (Implementing Decision 2016/1250), i. The data protection level of the service provider is recognized as being equivalent to the GDPR, although it is based in the USA. In addition, the standard data protection clauses of the EU Commission are used in contractual relation with the provider.

c) Purpose of data processing
The purpose of storing email address is to afford the possibility of electronic contact for advertising purposes. The date and IP address of the registration as well as the confirmation of the registration will be recorded in order to document the consent to the newsletter delivery and to prevent misuse. The transfer to the service provider is carried out for the purpose of sending the newsletter as a mass mailing.

d) Duration of storage
As far as we have received your email address in the context of the purchase of goods or services, this will be deleted for the delivery of advertising 18 months after the last purchase of goods or services or in the event of an objection or advertising block .
As far as you have expressly consented to the receipt of the newsletter, we will only delete or block the email address for the advertising mailout, if you revoke your consent. The data confirming the order of the newsletter will be stored for the same amount of time.

e) Opposition and removal option
You may object to the use of the email address for promotional purposes at any time, without incurring any costs beyond the charges of your communications tariff. You can object to the use of any advertising mail by clicking on a link provided there with effect for the future. You may also opt-out of advertising prospectively by emailing [e-mail]. In the case of opposition by email, the implementation of the cancellation or blocking can take up to 5 working days; In this period, advertising may still be delivered .

3. Registration for / use of Asterix & Friends
a) Scope of data processing (all versions)
If you register for our game, “Asterix & Friends” via our website or via a third party provider (e.g. google Play, Apple AppStore, Facebook Gameroom, Kongregate, gamigo, Spil Games), we will collect, process and store personal data or transmit collected data on other IT systems or external partners to allow you smooth access to the game. Specifically, this concerns:
– IP address
– Time of registration, login and logout
– User ID (automatically assigned or provided by third party provider, e.g. Kongregate Username)
– Village Name and Guild Name (by you freely selectable)
– Inventory of virtual items incl. time of purchase / receipt or sale in-game
– Virtual currencies incl. time of transactions
– Chat messages incl. time of communication
– In-game activity (e.g. Village level, XP, completed quests, achievements, rankings)
– Facebook ID and Profile Image (if connected to Facebook Account)

These data are accessible by the developers of the game, the service provider Drago Entertainment (Drago Sp. z o.o., ul. Alba?ska 3, 30-662 Kraków, POLAND), who are supporting us for the game’s further development and its maintenance. The service provider does not use the data for any other purpose.

These data are also shared with the Analytics Provider deltaDNA Ltd., Greenside House 25, Greenside Place, Edinburg who processes them on our behalf. The service provider does not use the data for any other purpose.

Furthermore, these data are accessible to the external service provider Conversis GmbH, Erftstraße 11, 47051 Duisburg, Germany (“Conversis”), who will be responsible for server maintenance on our behalf. The service provider does not use the data for any other purpose.

If you are using the iOS or Android version of the game, you will receive personalized ads from different advertising partners (see list below). The personalization of the ads is done by using an ad ID, the so called GAID (Google Advertising ID) for android systems and IDFA (Identifyer for Advertising) for Apple systems. The below mentioned advertisers are collecting the ad ID and display ads to the consumer, based on the user behaviour collected by Google and Apple and incorporated within the ad ID. The data is being processed in accordance to the corresponding data privacy statement of the dedicated advertiser as linked below:
ironSource Mobile Ltd.: http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
AdColony Inc.: https://www.adcolony.com/privacy-policy/
Applovin Corporation: https://www.applovin.com/privacy/
Chartboost Inc.: https://answers.chartboost.com/en-us/articles/200780269
Vungle Incl.: https://vungle.com/privacy/
Appsflyer Ltd.: https://www.appsflyer.com/privacy-policy/

Notice: Effective March 1st 2020, Sproing Publishing GmbH has transferred operation of “Asterix & Friends” to gameXcite GmbH. To ensure the trouble-free operation of the game from this point on, the existing, above-listed game data have been transferred to gameXcite GmbH. Insofar as personal data according to art.4 nr.1 GDPR is being transmitted, it is being done so based on art 6. para.1 lit.f) GDPR with the sole purpose of ensuring our legitimate interest in offering you the opportunity to continue playing via gameXcite.

Attention: When registering through one of our third party providers (e.g. google Play, Apple AppStore, Facebook Gameroom, Kongregate, gamigo, Spil Games), please note the privacy policy of the respective third party provider.

b) Scope of data processing (Web version)
When you register on our website (http://www.asterix-friends.com) for the game “Asterix & Friends”, we collect, process and save your email address as well as a password that you have defined in addition to the data listed under (a). This information will be used so that you may login to our website and games. In this case, the date and time of the login as well as the IP address used are also saved. As part of the confirmation of your registration (“Double Opt In”), the date and time at which you click on the confirmation link for the newsletter registration as well as the IP address used will also be saved. The same applies to any further login to our website or one of our games or to the publication of a post in our public forum, each of which is saved with the date and the IP address used.

Alternatively, we offer you the possibility of logging into our service using Facebook Connect. An additional registration is therefore not necessary. For login, you are redirected to a Facebook page where you can log in with your account data. In doing so, your Facebook profile and our service are linked. As a result of this linkage, we automatically receive information from Facebook Inc., which have been released by you in your Facebook privacy settings (further information can be found at: https://www.facebook.com/help/325807937506242/), specifically your email address. This information is mandatorily required for concluding the contract as it enables us to identify you. You can revoke the permission to use this data, which you granted us, at any time via your Facebook settings. Your account as such would not be affected by this; however, the account is linked to this information and can exclusively be used from the initially used Facebook account. For further information on Facebook Connect and their privacy settings, please find more information on data policy and terms of use of Facebook Inc.

Alternatively, we offer you the possibility of logging into our service using your google Account. An additional registration is therefore not necessary. For login, you are redirected to a google page where you can log in with your account data. In doing so, your google account and our service are linked. As a result of this linkage, we automatically receive your email address. This information is mandatorily required for concluding the contract as it enables us to identify you.

Any additional personal data, such as your name, address or telephone number, will not be retained, unless you provide this information voluntarily, for example in the customer self care module, chat or in the forum.

For the registration, your email address will be forwarded to the external service provider SURAWAY LTD, Arch. Makariou III, 155, Proteas House, 5th floor, 3026, Limassol, Cyprus, which will take over user data management on our behalf. Any further use is not made by the service provider.

Notice: Effective March 1st 2020, Sproing Publishing GmbH has transferred operation of “Asterix & Friends” to gameXcite GmbH. To ensure the trouble-free operation of the game the existing email addresses have been transferred to gameXcite GmbH. It is being done so based on art 6. para.1 lit.f) GDPR with the sole purpose of ensuring our legitimate interest in offering you the opportunity to continue playing via gameXcite.

c) Legal basis
The legal basis for processing the data when registering for the game directly on our website is Article 6 (1) (a) GDPR. The legal basis for the use for analysis purposes or to display advertising is Article 6 (1) (f) GDPR. The special interest is to enable the display of ads, control the delivery of ads, prevent fraud and for accounting.

The legal basis for the transfer of the data to the service provider Suraway Ltd., Conversis GmbH, deltaDNA and Drago Entertainment are Articles 28 (3) GDPR. The service providers are based in the European Union and are bound by the provisions of the GDPR.

d) Purpose of data processing
Purpose of storing the account-name/-ID or the email address is to facilitate the possibility of individual logins to the game and the assignment of the user’s account. IP address and time of login are recorded to prevent misuse (e.g., access by third parties). This also applies to the storage of the remaining log data for in-game activity (for example, in-game misconduct / rule infractions). The saving of the village name, virtual currency and inventory is necessary for the operation of the game. The analysis of user data serves the purpose of optimizing the game for the expectations of customers. The display of ads is used to finance the game operation.

The transfer to our service providers is for the purpose of maintaining the game’s standard operation including the login and user account management.

e) Duration of storage
Since the data collected is an elementary part of the online game and its operation, without the player’s data, standard use of the service will not be possible or will only be so to a limited extent. We delete or block the collected data only if you specifically request that we delete your information.

Insofar as you have confirmed your registration (“Double Opt In”), we will delete or block the email address and the password only if you specifically contact us to request its deletion – the data confirming the registration, the login and the publication of posts in the forum will be retained for the same amount of time as your personal data. User data from unconfirmed applications will be deleted within 14 days.

f) Opposition and removal option
At any time, you may request the deletion of your user data by post or email to [e-mail], without incurring additional costs. Attention: After deletion the use of our services and games incl. possibly acquired premium features is no longer possible. In the event of opposition by email, the implementation of the cancellation or blocking may take up to 5 working days, unless we are legally obliged (eg to settle payment disputes) to retain your data for a longer period of time.
You can disable the usage of the ad ID in the configurations of your mobile device anytime or delete or reset existing ad Ids. You can find a guideline for android devices here: https://support.google.com/android/?hl=de#topic=7313011 and for Apple devices here: https://support.apple.com/de-de
In case you are disabling the transmission of the ad ID, you will receive non-personalized ads and all collected data will be made anonymous.

4. Purchase of premium features / payment processing
a) Scope of data processing (Web Version)
We have licensed the distribution rights regarding certain digital premium content in our games to Suraway Ltd. for the Web Version. Suraway Ltd. offers such digital premium content in íts own name. For this purpose and during the checkout process we have integrated Suraway Ltd.’s technology which allows Suraway Ltd. to directly collect data regarding any purchases from you and to process such data. We do not transfer such data, but such data is directly collected and processed by Suraway Ltd. as responsible body. Suraway only informs us if certain content has been purchased by a certain user, but we do not receive any payment data. For all further information please refer to the Privacy Policy of Suraway Ltd under: [LINK]

b) Scope of data processing (Mobile, Facebook and other versions)
When paying through third party providers (e.g. google Play, Apple AppStore, Facebook Gameroom, Kongregate, gamigo, Spil Games) we are not receiving any personal data but only the confirmation that a payment was made. In this case please please note the privacy policy of the respective third party provider.

c) Legal basis
The legal basis for allowing the payment provider or licensees to collect and process the data as detailed above is Article 6 (1) (b) and (c) GDPR.

d) Purpose of data processing
Purpose of the allowing third parties to collect the data is to enable a payment process where as few parties as possible have access to your payment data. Date and IP address during the payment process are collected to prevent fraud.

e) Duration of storage
We store any purchase data for as long as your account is active and thereafter for a term of the respective statute of limitation or as long as required under applicable tax law.

f) Opposition and removal option
You can not oppose this processing.

5. Contacting our customer Support / Use of contact form
a) Scope of data processing
By using our Contact Form (e.g. clicking the green “Support” Button) or sending an email to our customer support (e.g. [e-mail]), you agree to provide us with certain personal information including your email. By using the contact form your IP Address may also be processed as well as information filled in into the form’s various fields.
For the processing of this data we are using the service provider Zendesk Inc, 1019 Market Street, San Francisco, CA 94103, USA (“Zendesk”). Any further use is prohibited to the service provider. More information about Zendesk and its privacy policy can be found here: https://www.zendesk.com/company/customers-partners/eu-data-protection/

b) Legal basis
The legal basis for processing the data when contacting our customer support and/or using the contact form is Article 6 (1) (a) GDPR.
The legal basis for the transfer of the data to the service provider are Articles 28 (3), 6 and 7, Article 45 (3), Article 46 (2) (c) GDPR. The service provider is certified under the Privacy Shield Framework and is therefore subject to the EU Commission’s decision on adequacy (Implementing Decision 2016/1250), i. The data protection level of the service provider is recognized as being equivalent to the GDPR, although it is based in the USA. In addition, the standard data protection clauses of the EU Commission are used in contractual relation with the provider.

c) Purpose of data processing
The purpose of processing email addresses and other personal data is to facilitate customer support, e.g. helping the player by responding to his or her queries. Zendesk serves as a tool to manage the volume of messages and is therefore, processing the data on our behalf.

d) Duration of storage
Your data will be deleted 18 months after the last time that you have contacted our customer support or used our contact form.

e) Opposition and removal option
At any time, you may request the deletion of your user data by post or email to [e-mail], without incurring any additional costs.

f) Job Applications
By applying, you explicitly confirm that you are interested in being employed by gameXcite GmbH. You therefore voluntarily provide your personal data such as your name, email address, date of birth, telephone number, IP address, device ID, curriculum vitae, photograph, references, and certificates to be used for recruiting purposes, in particular for filing and matching your profile with any and all open positions at gameXcite GmbH, including those beyond which you specifically applied to. We may further collect and process information from third party public sources, such as LinkedIn or Xing or other career networking services.

If there is a job opportunity which matches your profile, gameXcite GmbH may forward your data to the responsible managers in order to contact you for interviews. Your personal data will be processed in the form of databases and will be collected in secured personal files. You have the option of withdrawing your application at any time.

Last update: 01.04.2020