Videogames Without Borders (“VGWB”), is committed to protecting the user’s privacy and personal data. Personal data is collected and used strictly within the legal limits of applicable data protection law. With this privacy policy, we inform the user of the personal data we collect when they use the app and what purpose we use it for.

We collect and use the user’s personal data strictly within the legal limits of the data protection laws of the Federal Republic of Germany. We inform the user below of type, extent and purpose of any collection and use of personal data.

1. Data controller/Contact

The data controller for the purpose of data protection law is:

Videojuegos Sin Fronteras (Video Games Without Borders)  
Please feel free to address any questions or concerns regarding data protection/privacy to ## 2. Scope of data protection Data protection concerns personal data. This is defined in Sec 3 para. 1 of the German Federal Data Protection Act (“Bundesdatenschutzgesetz”; “BDSG”) as any information concerning the personal and material circumstances of an identified or identifiable individual. This includes information like name, postal address, e-mail address or telephone number, but also usage date in some cases. Usage data are data required to use our app, for instance information about start, end and extent of use as well as login data. ## 3. Collection and use of the user’s data ### 3.1 Automatic data collection When the user accesses our app while connected to the internet, their device automatically transmits certain data for technical reasons. The following data are stored separately from any other data the user may transmit to us: - Date and time of access - Device type and version - Operating system - Section of the app being used - Unique anonymous user identity Such data is stored for purely technical reasons and are never associated with any particular individual. ### 3.2 Voluntary data sharing by the user In order to fully enjoy our services, the user is asked to enter their age and gender. Such data helps create a unique identity for the user and it’s stored locally. This data is only shared with us voluntarily by accepting it the first time the game is launched and/or enabling it in the restricted parent/teacher section in the app. Sharing any such information is voluntary and not required. ### 3.3 Community features We provide interactive areas or services on our app, including the ability to share the app with friends via social media such as Facebook or Twitter. When the user uses community features, they should be aware that these areas are publicly accessible and all the personal information they share on these social media or have entered upon registration may be accessed by others. We are unable to control how other visitors to our websites and/or apps as well as social media users use such information. In particular, we are unable to prevent unsolicited communication to the user. Content shared in Interactive Areas may be available for an unlimited time. If at any time the user wishes any content to be removed, please let us know by e-mail to the address provided above. ## 4 Sharing data As a general rule, the user’s personal data will be shared with third parties without their express prior consent only in the cases described below: - If it serves investigations of illegal use of the platform or is required to pursue legal claims, personal data may be shared with law enforcement agencies and third party victims. Such transfer of data will be made only where there is specific evidence for illegal or abusive conduct. Data may further be shared where it serves the enforcement of terms of use or other contractual agreements. We are furthermore legally obliged to disclose certain information to certain public entities upon request. Such entities include law enforcement agencies that investigate administrative offences subject to fines, and tax authorities. - From time to time, we may require the assistance of contractually hired third parties and external service providers in order to provide our services, for instance in the domains of sending information and advertisements (only where the user has explicitly consented beforehand). In these cases, we share information with such companies or individuals to enable them to carry out their tasks. Such external service providers are carefully selected and regularly checked in order to ensure the user’s privacy. Service providers may only use the data for the purposes specified by us. Service providers are furthermore contractually obliged by us to treat data strictly in accordance with this privacy policy and German data protection law. - As our business evolves, the structure of Cologne Game Lab may change, for instance by a change in legal form or creation, acquisition or sale of subsidiaries, branches or parts of a company. In the course of such transactions, customer data will be transferred together with the relevant part of the company being transferred. In each case of a transfer of personal data to third parties to the extent described above, we will ensure that such transfer is made in accordance with this privacy policy and applicable data protection law. ## 6 Contact form We provide the user a contact form to make it easier for the user to contact us. If the user enters data in our contact form (First Name, Last Name, Email address, Country) and submits this data to us, we will store and use their data to the extent required to process their request. If we do not need the user’s data any longer, it is being deleted unless we are legally required to keep it. ## 7 App permissions Our app requires the following permissions: | Permission | Purpose | | --- | --- | |Access to device information (iOS and Android) |To create a unique anonymous identity for the user | | android.permission.ACCESS_NETWORK_STATE android.permission.GET_TASKS android.permission.INTERNET android.permission.VIBRATE | Android specific permissions to determine if device is connected to the internet and license | ## 8 Local Storage We use so called local storage to provide the user with a wide range of functionalities and to give them a better user experience. By using local storage we are able to recognize the user’s device and to distinguish their device from others. The sharing of the data is voluntary through the restricted parent/teacher section in the application. ## 9 Pseudonymous usage statistics ### 9.1 Unity Analytics We use Unity Analytics, a web analytics service provided by Unity Technologies SF (“Unity”). Unity Analytics may collect pseudonymous data on how the user uses our app. The information about the user’s use (including their truncated IP address) is transmitted to servers controlled by Unity in different countries and is stored there. Unity uses this information to analyse the user’s use of the app, to generate reports about app activities for app publishers and to provide further services related to app and internet use. Unity may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Unity. The user can find detailed information about how Unity uses the user’s data in Unity’s privacy policy: The user may prevent Unity Analytics from collecting data by always using the application offline. ## 10 Deletion of the user’s data To the extent the user’s data is no longer required for the aforementioned purposes, it is deleted. If the user deletes their user account, their profile will be entirely and finally deleted. To the extent data must be retained for legal reasons, they are blocked and will not be available for use. ## 11 Right to access and correction Of course the user is entitled, upon request, to disclosure regarding their personal data that we are storing. The user is also entitled to have any incorrect data corrected and rights to blocking or deletion. Please address any requests in such matters to our email address mentioned above or write to us at the address stated above. ## 12 Changes to privacy policy We reserve the right to modify this privacy policy. The current version of the privacy policy is always accessible at ****Last updated:** 13 Mar 2023**