We, the Mediaworker UG (haftungsbeschränkt) (“Mediaworker” or “we“), are pleased about the visit of our website under https://gameforge.com/ja-JP/littlegames/ (“Casual Games Portal“).
The visit of our casual games portal should be as pleasant, fair and trouble-free as possible for all users. In order to guarantee this and to ensure the long-term success of our offers, our website is continuously optimized.
It is not possible to avoid that information about the individual user and the hardware used by him/her is collected, stored and finally used for different purposes.
We follow the guiding principle that when handling your data, we give your rights and our obligations a particularly high priority. All processing is therefore carried out within a secure framework, limited to the necessary extent, responsibly and with great care in accordance with the statutory provisions.
1. Details of the body responsible for the processing
We want to live up to your trust. For questions, suggestions and complaints regarding our handling of your data in general and about this PP in particular, please do not hesitate to contact us.
The company responsible for processing personal data is Mediaworker UG (haftungsbeschränkt), Sudetenstr. 8, 71570 Oppenweiler, Germany. For general questions regarding data protection, we can be contacted by post at the address given, by e-mail to [email protected], and by fax to +49 (0)321 21327641.
2. General information on the data we process and its origin
In this section we inform you about how we receive your data.
2.1 Lawfulness of processing
Already when collecting your data, we first make sure that the processing is carried out in a permissible, transparent and appropriate manner. In assessing whether permission has been granted and how the processing is to be structured in detail, we are guided by the requirements of the law applicable to us and in particular by the provisions of the EU Data Protection Basic Regulation (“DSGVO“), the Federal Data Protection Act of the Federal Republic of Germany and the other legal provisions governing the handling of personal data.
2.2 Data automatically collected by us
When using our casual games portal, system and user-related data is collected automatically and without further action by the user. For example, when you access a Casual Games Portal page, general specifications of your Internet browser (e.g. the type and version of the browser), the time of the page access and the IP address assigned to it (an individual identifier that was assigned to your Internet connection at that time) as well as system settings (e.g. the selected screen resolution and the version of the operating system) may be collected and logged in server logs. A further assignment to a specific Internet user is not made on principle.
Such processing is carried out in order to safeguard our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the secure and smooth operation of our casual games portal and the optimisation as well as to establish, implement or terminate the user contract concluded with you (Art. 6 Para. 1 lit. b) DSGVO).
3. Specific information on the purpose and scope of processing
In this section we explain in detail in which specific cases we process your data.
In principle, the processing takes place on the territory of the Federal Republic of Germany and directly by Mediaworker. If in individual cases we have personal data processed by another entity such as a company affiliated with us or a service provider and, if applicable, in a third country (a country outside the European Union or the European Economic Area), this is always done within the legally permissible framework and on the basis of a contract with the respective third party, which ensures compliance with the legal data protection requirements.
3.1 Server logs
In order to detect and defend against cyber attacks and manipulation attempts as well as for statistical reasons and to improve our Casual Games Portal, in addition to the Internet pages called up, for example, the times of the page call or the login to a user account as well as the IP address assigned to the user’s connection are collected. As far as necessary, comparable technical information such as the MAC address (the network address of the network adapter used) or similar identification features may also be collected.
Through these processing operations, we safeguard our legitimate interests (Art. 6 para. 1 lit. f) DSGVO) in the secure and smooth operation of our casual games portal and its optimisation, as well as in the execution or termination of the user contract concluded with you (Art. 6 para. 1 lit. b) DSGVO).
3.2 Communication with Mediaworker
We are happy to be in contact with our users for general questions about Mediaworker and our Casual Games Portal and answer questions about this PP and data protection at Mediaworker. For this purpose we offer different contact possibilities. Certain personal data is also processed when using such a channel.
Through the processing operations connected with the respective contact, we safeguard our legitimate interests (Art. 6 para. 1 lit. f) DSGVO) in the exchange with our users, potential contractual partners and other entities that wish to contact us. Insofar as a message is aimed at the conclusion of a contract between us and the requesting person or at clarifying contractual issues, the processing may also serve to initiate, implement or terminate a corresponding contract (Art. 6 para. 1 lit. b) DSGVO). In individual cases, the processing may ultimately be necessary to fulfil a legal obligation to which we are subject (Art. 6 para. 1 lit. c) DSGVO).
3.2.1 Contact us by e-mail
The e-mail is a convenient way to contact us. By sending an e-mail to us, we receive the sender’s e-mail address and the content of the message. In addition, the IP address of the sender is transmitted.
3.2.2 Contact us by fax
If we are contacted via fax, we receive the fax number of the sender in addition to the content of the message in question. If a fax is sent in the same way as an e-mail, what is described for receiving e-mails also applies accordingly.
3.2.3 Contact us by letter post
Contact by mail is of course also possible. In this case, we will exceptionally receive the address given by the sender in addition to the content of the message.
3.3 Demand-optimised design of the casual games portal
To provide you with a comfortable user experience, we can tailor our Casual Games Portal to your needs. This includes providing you with individual offers and placing associated ads or configuring the arrangement and graphic design of controls in a form optimized for you.
Through the processing operations involved, we safeguard our legitimate interests (Art. 6 para. 1 letter f) DSGVO) in providing our services in the most convenient way for you.
3.4 Range analysis, tracking, analyses and cookies
We have no interest in observing the external surfing behaviour of our users and do not track how you continue to move around the net after using our casual games portal.
On the other hand, we have a legitimate interest in the optimisation, further development and needs-based design of our offers and in being able to better assess the benefits of our advertising measures and to remunerate them in accordance with the contract. This includes information about how our casual games portal is used and which external sites users have found their way to us through. In order to detect errors and to improve the Casual Games Portal, we would also like to know which pages are visited how often, how long it takes to build a page until it is displayed in the browser and how much time is spent on the page in question.
Through these processing operations we protect our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the optimization and smooth operation of our casual games portal as well as in the fulfillment of contracts with our partners.
We use the open source software tool Matomo on our website to analyze the surfing behavior of our users. If individual pages of our website are called up, the following data is stored:
- Two bytes of the IP address of the calling system of the user
- The accessed website
- The website from which the user has reached the accessed website (referrer)
- The subpages that are called from the called web page
- The time spent on the website
- The frequency of the website visit
- The software runs exclusively on the servers of our website. A storage of the personal data of the users takes place only there. The data will not be passed on to third parties.
The software is set up in such a way that the IP addresses are not stored completely, but 2 bytes of the IP address are masked (e.g.: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.
The legal basis for the processing of the users’ personal data is Art. 6 para. 1 lit. f DSGVO.
The processing of the personal data of users enables us to analyze the surfing behavior of our users. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. For these purposes, we have a legitimate interest in processing the data in accordance with Art. 6 Para. 1 lit. f DSGVO. By anonymizing the IP address, the interest of the users in their protection of personal data is sufficiently taken into account.
The data is deleted as soon as it is no longer required for our recording purposes. In our case this is after 180 days.
On our website, we offer our users the option of opting out of the analysis process. To do so, you must follow the corresponding link. In this way, another cookie is set on your system, which signals our system not to store the user’s data. If the user deletes the corresponding cookie from his own system in the meantime, he must set the opt-out cookie again.
You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.
3.4.2 Tracking and analysis
To optimize our casual games portal for a better user experience, we would like to track how our offers are used and whether optimizations and new features are successfully accepted.
We can, for example, determine whether the website in question is necessary or needs to be improved by counting the number of clicks on a link to an information page and the length of time spent on that page.
The corresponding information is usually aggregated. This means that we gain summarized knowledge from initially individual information, which in most cases we can no longer trace back to individual users.
Insofar as such aggregation does not take place, your data is usually processed in pseudonymised form.
Cookies are stored by your browser on your system for their respective lifetime when you call up the Casual Games Portal. They are not executable applications and do not contain any harmful elements, but a string of characters corresponding to their function. In simple terms, cookies are small text files in which information is stored in connection with the Internet pages called up.
This is what makes some basic functions of the Casual Games Portal possible at all. Cookies allow for example a recognition of your browser. This allows you to load previously defined settings such as the language displayed and the orientation or size of a window in a browser game. Cookies thus help us to offer our Casual Games Portal in a functional and user-friendly form and according to your needs.
In addition to these technically necessary and useful functions (necessary cookies and function cookies), cookies also enable us to record and analyse the use of our Casual Games Portal (analysis cookies). Thus, for example, we can determine how often a page has been called up, how regularly certain page functions are used, or whether and where errors occurred (performance cookies).
Cookies can also be used to deliver advertisements in line with your interests (advertising cookies). However, the information associated with the Casual Games portal cookies is usually stored in a pseudonymized form, which means that we are unable to assign it directly to an individual user without consulting further information.
As a rule, cookies are automatically removed from your system as soon as you leave our Casual Games Portal or end the usage process by logging out (session cookies). However, some cookies can also be stored on your system beyond that. To prevent this, you can set your Internet browser to block all cookies, to allow only certain cookies or to delete all cookies after closing the browser. If you wish to use this option, please follow the instructions of your browser provider. Please note, however, that in this case the use of our Casual Games Portal may be completely or partially impossible or only possible to a limited extent for technical reasons.
3.5 Advertising on our Casual Games Portal and Google Adsense
To finance our casual games portal, we can integrate advertisements of third parties at different places on the portal. By clicking on such a page, you will be redirected to the website of the respective advertiser. The respective site operator will inform you about the processing of personal data in a separate data protection declaration. In addition, cookies (see above under 3.4.3) of the advertiser and/or the respective advertising network can be saved by the display of an advertisement.
3.5.1 Advertising on the Casual Games Portal
On the one hand, we can place advertisements at selected locations of our casual games portal. On the other hand, advertisements of the respective third-party providers may be displayed within the games of these providers that we integrate.
3.5.2 Google Adsense
The information obtained via cookies and web beacons, your IP address and the delivery of advertising formats are transmitted to a Google server located in the USA and stored there. Google may pass on this collected information to third parties if required by law or if Google commissions third parties to process the data. However, Google will merge your IP address with the other stored data.
You can prevent the above-mentioned cookies from being stored on your PC by adjusting your browser settings accordingly. However, this may mean that the contents of this website can no longer be used to the same extent. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
AdSense allows personalized advertising to be targeted to you. You can easily disable personalized advertising in your private Google account: https://adssettings.google.com/authenticated.
Further information about the data transmitted to Google Adsense and how it is stored and used can be found here: https://policies.google.com/technologies/ads
3.6 Integration of third party content
In our website, after your active consent, third party content can be included. The content of these third-party providers can collect data such as your IP address or pages you visit on our website and, if necessary, set a cookie in order to guarantee their full functionality. Your interactions with third party offers are subject to their policies and not ours.
Please note that by deciding to share or interact with your personal data via such frames, you are making this data available to said third party and not to us, so that such interaction and sharing of information also comply with the guidelines said third party and not ours.
You can define your settings via the integration of third-party content here:
3.7 IT security measures
It is a particularly important concern for us to be able to guarantee the security of our casual games portal at all times. To this end, we use technical measures such as common hardware and software solutions to monitor the security status of our systems, which, for example, detect and ward off cyber attacks such as so-called DDoS attacks, malware or unauthorized login attempts and other attempts at manipulation. In addition to the use of such measures, server and system logs are also sifted.
The implementation of the IT security measures described serves to protect our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the availability of our services as well as the security of our casual games portal and the associated protective measures.
3.8 Processing for statistical purposes
Within the scope of statistical evaluations, we collect data in sub-areas of our casual games portal such as the operating system and its version, the browser and its version, IP address and other system data. We use this information for statistical evaluations, especially for the purpose of better adapting our Casual Games Portal to the needs of the users. If possible, the data is anonymized and aggregated. If this is not possible, a pseudonymisation is used. This information will not be passed on to third parties.
By processing for statistical purposes we safeguard our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the optimisation of our services.
3.9 Improvement of our Casual Games Portal
In many cases, the processing of personal data serves to improve our casual games portal and, in connection with this, to detect and correct errors, increase security and optimize the user experience.
This is how we protect our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the provision and optimisation of our services and the security of our casual games portal.
3.10 Protection of other legal interests
In individual cases, the processing of personal data may also be necessary to safeguard other legal interests, in particular cooperation with the competent authorities or the assertion, enforcement or defence of legal claims.
The corresponding processing serves to fulfil our legal obligations (Art. 6 Para. 1 lit. c) DSGVO) or to safeguard our legitimate interests (Art. 6 Para. 1 lit. f) DSGVO) in the assertion, enforcement or defence of legal claims.
3.11 No change of purpose
In order to be able to achieve the purposes set out in this PP on a permanent basis, we reserve the right to adapt the manner of data processing to legal or business requirements. For example, we optimise data processing procedures or implement new processes and procedures. However, this is always done with careful attention and strict compliance with the legal requirements. Without your express consent, we do not intend to change these purposes in a way that is incompatible with the purposes for which they were established. In order to maintain the maximum transparency that we strive for, we will reflect relevant adjustments in this PP and provide information about them.
3.12 Balancing of interests
In so far as we process personal data on the legal basis of Art. 6 para. 1 lit. f) DSGVO and thus to safeguard our legitimate interests, we first establish our interest in the processing in question. We then compare this with the expected interests of the persons concerned. In doing so, we consider in particular the intended purpose, the type of data processed and the associated risks to the rights and freedoms of the data subjects. We also check whether the technical and organizational measures we have taken are sufficient to maintain the required level of protection. Only if all this is the case and the processed data are also limited to the necessary extent, will we carry out processing on this basis.
4. disclosure and transmission of personal data
The processing of your data is basically only carried out by us, on the territory of the Federal Republic of Germany and always for the purposes specified in this PP. This section provides information as to whether and why, in certain cases, personal data is passed on or transferred.
4.1 Reasons for disclosure and transmission
We will only pass on your data internally or externally if this is necessary to achieve one of the purposes defined in this PP. Any forwarding or transmission is also limited to the extent actually required for this purpose.
4.2 Internal and external recipients of data
As a rule, your data is transferred within the company to the department responsible for the respective processing, which in turn is only carried out by the responsible employee(s). For example, we can forward a complaint received by post to the responsible support employee.
Furthermore, carefully selected external service providers provide us with their data centers. Insofar as we are legally obliged to do so, we also pass on data to the relevant authorities to the extent necessary. If we engage external consultants, such as lawyers in particular, to defend against or assert legal claims, we may also transfer the necessary data to these recipients.
All transmissions are equally carried out exclusively for the purposes set out in this PP and in strict respect and compliance with the legal requirements, in particular the conclusion of an agreement on the processing of data on behalf of a third party in accordance with Art. 28 para. 3, sentence 1 DSGVO.
4.3 Recipients in third countries
Before each transmission of personal data, we first check whether the legal requirements for the specific transmission are met. This includes that we only pass on personal data to recipients who can guarantee an appropriately high level of data protection. For this reason, we only transfer data to a recipient in a third country (see 3.) if an adequate level of data protection exists in the third country in question. This is the case if an adequacy decision has been issued by the EU Commission. Such a level of data protection may exceptionally also exist if a service provider from the United States of America is certified according to the EU-US Privacy Shield or if the transfer is made on the basis of the standard contractual clauses of the EU Commission.
5. Duration of storage
In this section we explain for which period of time the personal data collected by us will be stored.
We do not store personal data for no reason. Each storage serves a specific purpose and is bound to this purpose. The storage period is essentially determined by the purpose underlying the respective processing and the necessity associated with it. We therefore only store personal data for as long as the data is required to achieve the specified purpose.
First of all, when determining the storage period, we check whether it is necessary to store the data concerned for the entire duration of a contract with the persons concerned.
If such permanent storage is not necessary, we will examine the minimum storage period specifically required for the purposes defined in this PP. Thus, complaints and support requests as well as usage data from which a breach of the rules may result will be stored until there is no further need for storage for the assertion, enforcement or defence of legal claims or until further support cases can usually not be expected. As a benchmark we use the regular limitation period of three years according to § 195 BGB. If, for technical reasons, storage is only necessary for a short period of time (e.g. for the duration of a current session), the relevant data is generally only stored for the duration of the usage process and for a maximum of 30 days.
As soon as the corresponding processing purpose no longer applies or data is no longer required to achieve this purpose and there are no further statutory retention obligations to the contrary, we delete the data concerned.
6. Your rights
In this section we inform about the rights of data subjects in relation to the processing of their data and how these rights can be exercised in relation to us.
6.1 Right of access
You have the right to ask us to confirm whether we are processing your data. If this is the case, you also have the right to obtain from us comprehensive information on this, a copy of this data in principle free of charge, and further information..
6.2 Right of rectification
If the data concerning your person is incorrect or incomplete, you are entitled to ask us to correct or complete the data.
6.3 Right of deletion
You have the right to demand the immediate deletion of your data. However, such a deletion may be opposed by compelling legal reasons, such as in particular legal storage obligations. In individual cases, it may also be that we need your data to assert, exercise or defend legal claims. In such cases, however, we will process the data concerning you strictly for the intended purpose and delete it immediately as soon as the corresponding reasons for storage cease to apply. We will also inform you about any such obstacles.
6.4 Right to limit processing
As an alternative to the deletion of your data, you are basically entitled to demand that we restrict the processing of the data in question. If you exercise this right, we may only store the data covered by this. Any processing beyond this may then only be carried out with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
6.5 Right of objection
For reasons arising from your particular situation, you have the right to object to the processing of your data at any time, provided that we carry out the processing in question lawfully in accordance with Art. 6, Paragraph 1, Letter f) of the DPA, in order to safeguard our legitimate interests. If you have such a right of objection and exercise it vis-à-vis us, we will no longer process the data covered by it.
Your right of objection can only be exceptionally not be exercised if we can prove a compelling reason for the processing worthy of protection, which outweighs your interests, rights and freedoms, or if the processing serves the assertion, exercise or defence of legal claims. However, this exception does not apply if you object to the processing of your data for the purpose of direct marketing and related profiling. You may object to processing for these purposes at any time.
6.6 Revocation of consent
If we process your data on the basis of a consent given by you, you can revoke your consent at any time with effect for the future. We will immediately cease the processing in question from the time we receive your revocation and until a new consent has been given.
6.7 Right to data transferability
If we process your data on the basis of a consent given by you or to establish, implement or terminate a contract with you, you can demand that we surrender the data that you have actively made available to us. The surrender will be in a structured, common and machine-readable format. Should you wish to do so in such a case and provided that this is technically feasible, you can also demand that we transfer this data to another person responsible.
6.8 Right of appeal
You have the right to complain to a competent supervisory authority if you believe that the processing of your data by us is in breach of the law.
6.9 Exercising your rights
You are free to contact us by the method you prefer in order to exercise your rights set out here (see section 1 for details). In all cases, please state your request as precisely as possible for an uncomplicated allocation.
7. Notes on data security
When handling personal data, we have taken appropriate technical and organizational measures to ensure the security of the data and thus minimize the risks to the rights and freedoms of the persons concerned. This includes the fact that we do not collect any clear names or address data. In addition, we limit the collection and storage of personal data to the necessary minimum and encrypt data wherever possible.
8. Notes on the integrated games and on the forwarding to offers of third parties (hyperlinks)
In some places our Casual Games Portal contains links to external websites. If you click on such a hyperlink, you will be directed to offers that are beyond our control and influence. Since we integrate the various games predominantly via so-called framing, the previous explanations apply accordingly to these games. The respective provider is exclusively responsible for the respective offers. The data protection regulations of the respective provider apply in each case.
This PP is available in the version dated 22 July 2020. We reserve the right to adapt its content if this should become necessary to correct errors, improve comprehensibility, supplement information or for legal reasons. In the event of such an adaptation, we will always respect the principles and policies set out in this PP and maintain the protection of your personal data.