Tangra Studios develops and publishes games and other services for web and mobile devices. In this policy, "Tangra Studios" refers to Tangra Studios Ltd. and its affiliates, which shall mean subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership. We may also refer to Tangra Studios as "We" or "Us".
This Privacy Statement aims to inform you in a transparent and clear way of the personal data that is collected, processed, and used by Tangra Studios in the context of our websites, apps, games, and services provided by us (jointly referred to as our "services"). It also explains how such data is processed and used. The protection of your personal information is important to us.
Your data is protected against unauthorized access and loss through the use of various electronic, technical, physical, administrative, and contractual measures. Tangra Studios has taken the necessary technical and organizational precautions to ensure that the regulations for data privacy are respected both internally and by external service providers.
II. What Is Personal Data?
The term "personal data" under data protection law refers to all information relating to a specific or identifiable person (e.g. name, address, telephone number, date of birth, or email address). Basically, you can use our services without providing personal information. However, the use of certain services may require you to submit personal information, e.g. registration for our games or participation in a competition. An IP address can also be considered personal data. An IP address is assigned to each device connected to the Internet by the Internet service provider so that it can send and receive data.
III. Information We gather And Ways To Gather It
1. Basic information about your account, which includes username, mail, and password
This information is needed to create your account. The email you provide is used to contact our team or retrieve your password if you forget it. Your username is shown to all other users as part of the services we provide. If the registration is via a social network or other means than the standard registration form, we provide, this base information is retrieved from that social networking account and may include, in addition to email, your name and surname and your profile picture and/or its URL. The data provided will be processed for the purpose of providing the service. The legal basis of this processing is Art. 6 paragraph 1 sentence 1 letter b GDPR. We store your data for as long as you are registered with us unless you delete it beforehand.
2. Payment information
You can provide us with information about you in order to purchase the services we offer. This information depends on the payment method and can be a country, IP address, invoice address, msidns, transaction dates, transaction ID, phone number, etc., and is also collected by the corresponding payment service providers listed. This information is needed to make payments and is kept for legal reasons, to comply with the laws of different countries, and provide support. The legal basis for this data processing is Art. 6 paragraph 1 sentence 1 letter b GDPR. For payments, we collect the geolocation of your IP address, which allows us to determine in which country you are located. The legal basis for this data collection is Art. 6 paragraph 1 sentence 1 letter c GDPR, as the processing is necessary for compliance with a legal obligation. The legal obligation arises from Directive 2006/112/EC (MOSS Directive). We also receive information from payment providers related to payment fraud prevention. The legal basis for this data collection is Art. 6 paragraph 1 sentence 1 letter f GDPR, as the processing serves the legitimate interests of our company.
3. Information you explicitly provide
We keep information that you explicitly provide to us, which may include comments, chat messages, or forum messages, as well as any other messages you write, profile pictures and photos you upload as well as any other information you write or provide in your profile.
4. Information you provide to our support.
You can provide us with additional information when you need our help. This information may include screenshots, a copy of messages, and any additional information that may be required to resolve the problem.
5. Additional information we receive about you due to usage of our services
In the process of using the services we offer, you provide and we maintain and process information about your progress, acquired experience, purchased products, unlocked content, interaction with other users, login information that includes IP address, device data, such as device name and operating system, browser type and language, country, hardware versions, redirecting URL, visited link pages, date, time, pages used, total time of use, frequency of use, etc., as well as cookies. We use this data to ensure the efficiency, security, and reliability of our services. IP addresses and the corresponding Internet information are saved for a period of time within the scope of our legal obligations regarding data retention. Data may also be retained for data security purposes to ensure the stability and reliability of our system. In certain circumstances, Tangra Studios may also use your IP address and the corresponding Internet information to track and prevent the use of multiple accounts for fraudulent purposes.
7. Information we gather from third parties
Various Facebook links are embedded on our website; this web presence is operated exclusively by Facebook Inc., 1601 S California Ave, Palo Alto, CA 94304, USA (Facebook).
In the context of our web presence, these links are identified by the Facebook logo or by the phrase ‘Like’ (no Facebook plugins are used).
If a user clicks one of these links, the Facebook plugins will be activated and will establish a direct connection via the user’s browser to a Facebook server.
If the user clicks (follows) one of the links while visiting our website and is logged into their personal Facebook account, Facebook will be notified that the user has visited our website. Facebook may link your visit to the website to your account.
This information will be transmitted to Facebook and stored there. To prevent this, the user must log out of their Facebook account before clicking the link. The functions embedded in the links by Facebook, in particular the transfer of data and user information, are not activated when you visit our website, but only when you click the corresponding links.
The purpose and scope of data collection via Facebook, the processing and use of such data at Facebook, your respective rights, and personal setting options to protect your privacy are available in the Facebook privacy settings section (http://facebook.com/privacy/explanation.php).
Please contact us if you have further questions regarding the collection, processing, or use of your personal data and regarding the disclosure, correction, blocking, or deleting of data in this respect.
7.2. Facebook Visitor Action Pixel
We use the "visitor action pixels" from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook") on our website. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.
7.3. Facebook Connect
We offer you the option of easier registration for our games and services through Facebook. You can use your existing Facebook user account for this purpose. By clicking the "Log in with Facebook" link, you can use this registration method via our online portal. To do this, you need to already have a Facebook account or have access to Facebook. If you would like to register for one of our services using your Facebook account, the first step in the registration process will immediately redirect you to Facebook. Facebook will then ask you to log in or to register. Under no circumstances will we receive your personal access data (user name and password). In a second step, you will connect your Facebook profile with the service for which you would like to register. At this point, you will be told what data from your Facebook profile will be transmitted to us. This information is usually your "public information" on Facebook and information which you have made available to the public or authorized for the application in question. Information of this type generally includes your name, profile picture and cover photo, your gender, your networks, your username (Facebook URL), and your user ID number (Facebook ID). We will also use the email address you have saved with Facebook in order to contact you outside of Facebook. You can see an overview of information in your profile that is available to the public via the General Account Settings menu of your Facebook profile (https://www.facebook.com/settings?tab=applications). The legal basis for data collection and storage is your consent, within the meaning of Art. 6 paragraph 1 sentence 1 letter a GDPR. If you would like to remove the connection between Facebook Connect and our service, please log in to Facebook and make the required changes to your profile. We will then no longer have the right to use information from your Facebook profile.
8. Analytics Information
We use our own and external solutions to collect and process analytical data to improve performance, marketing campaigns, and the quality of our services. The third-party solutions that are used include Google Analytics, Facebook Analytics, Unity Analytics, and others. All third-party solutions adhere to the latest data protection laws and best practices.
8.1. Google Analytics
If you access this website via a mobile device (smartphone, tablet, etc.) you may object to the use of your data by Google by clicking a separate link in the dialog box displayed.
IV. Google Marketing Services
Transmission of your data to the USA cannot be excluded. We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.
V. Integrated Services And Third-Party Content
We use services and content provided by third parties on our website (hereinafter collectively referred to as "content"). For this kind of integration, it is technically necessary to process your IP address so that the content can be sent to your browser. Your IP address will therefore be transmitted to the respective third party provider. In each case, this data processing is carried out to safeguard our legitimate interests in the optimization and the commercial operations of our website, the legal basis of which is Art. 6 paragraph 1 sentence 1 letter f GDPR. The Java programming language is regularly used to integrate content. Therefore, you can object to data processing by deactivating Java operations in your browser. We have integrated contents from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; "Google") into our website:
1. "Google Maps" for displaying maps;
2. "Google Web Fonts" for using Google’s fonts;
3. "YouTube" for displaying videos.
Transmission of your data to the USA cannot be excluded. We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.
VI. Mobile Apps
Our apps are provided through various app and software platforms, including the Apple App Store, the Google Play Store, and social networks like Facebook. If you access, register with, or use the platform or social network, personal data may be collected and used by the respective platform or social network over which we basically have no influence. You can find all the relevant information in the data protection guidelines or provisions of the respective platform or social network.
To use our forums, you provide the personal registration data, which is used to register on our website or apps. The e-mail address is not visible to other users. Registration is necessary to be able to punish possible infringements of our Community guidelines by excluding those responsible from the forum. The legal basis for the storage of this data is Art. 6 paragraph 1 sentence 1 letter b GDPR. Our forum is monitored by moderators. In order to prevent and punish serious violations, we monitor your IP address. The collection of this information to combat fraud is based on our legitimate interests in accordance with Art. 6 paragraph 1 sentence 1 letter f GDPR, and serves to protect our forum. We expressly reserve the right to delete your comments if they are objected to as unlawful by third parties as well as they are in violation of the Forum Rules. You can object to this storage of the aforementioned data at any time.
VIII. Social sharing
With your consent, we may send notifications to your device to provide information about service activity, service updates, promotional messages, and other similar messages. You can disable notifications by changing your device notification settings.
X. Data Transfer And Service Providers
We will treat your data as strictly confidential and will not disclose it to third parties unless we are legally permitted to do so. We may, in individual cases, be legally obliged to disclose your information, for example to investigating authorities, whereby disclosure will only take place to the extent required by law. We use the companies affiliated with us and/or third parties to provide services on our behalf. This is mainly for payment transactions by external service providers (Stripe, Epay, EasyPay, PayPal, etc.) and, in the event of default, by a debt collection company. Moreover, we provide your data to affiliated companies of the Tangra Studios for marketing purposes and to further develop and improve our games. These affiliated companies and external companies are under an obligation to handle your data confidentially and securely, and may only use your data insofar as it is required for completing the task they have been assigned. Service providers are generally involved as processors who are only authorized to process the personal data of users of this service in accordance with our explicit instructions.
XI. Privacy Policies of Linked Sites and Advertisers
Our websites and games may contain advertisements from companies other than Tangra Studios that may link to their own websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.
We offer in-game advertising on our web games allowing you to view video sequences from third-party providers funded through advertising. This allows paid content, for example, to be used free of charge.
The data you provide when using advertising media is collected and analyzed, which will be explained in more detail below. Our service provider Google Ad Manager by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) allows us to put this type of ad monetization into practice. The service provider assumes control of the in-game advertising networks. This involves some parameters being shared via an interface with the advertising networks: IP address, browser, operating system, region (more info). The aim of this transmission of information is to display the most relevant advertising material for the user. The advertising networks mentioned may possibly also process personal data, such as the IP address, in order to be able to provide that advertising material.
Opting out from personalized or contextual ads does not remove ads in our games. Limited ads, which do not process any personal data and are less relevant to the users, will still be shown.
The legal basis for the processing of information in connection to the in-game advertisement is your consent (Art. 6 paragraph 1 letter a GDPR). As a user, you can opt out of the use of personal data in advertising at any time in our Preference Center. In such a case, all pseudonymous information is anonymized, meaning that only limited ads will be shown.
XII. Security of Your Information
Tangra Studios implements reasonable security measures to protect the security of your information both online and offline, and we are committed to the protection of customer information. While we take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password) and to log out of your account after use. If your SNS account is hacked, this may lead to the unauthorized use of our services, so be careful to keep your account information secure. Unfortunately, the transmission of information over the Internet is not completely secure. Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access.
XIII. Exercising your rights
In order to exercise your rights, you can always contact us at email@example.com or through the support channels of the service you are using.
To manage your account information, you can use the profile settings feature in our services.
You have the following rights:
1. In accordance with Article 15 GDPR and Section 34 BDSG, you have the right to request information as to whether or not, and to what extent, we process personal data about you.
2. You have the right to have us correct your data in accordance with Article 16 GDPR.
3. You have the right to have us delete your personal data in accordance with Article 17 GDPR and Section 35 BDSG.
4. You have the right to have the processing of your personal data restricted in accordance with Article 18 GDPR.
5. You have the right, in accordance with Article 20 GDPR, to receive the personal data concerning you that you have provided to us, in a structured, commonly used, and machine-readable format and to transmit this data to another controller.
6. You can exercise your rights by contacting us via firstname.lastname@example.org.
We will respond promptly to any confidentiality claims. If you have an unresolved privacy or data use issue, you can contact your local data protection authority.
XIV. Period of time for keeping your data
Unless otherwise stated in these sections, we will store the data only as long as necessary to achieve the purpose of processing or to fulfill our contractual or statutory obligations including when it is required by laws, legal requests, government inquiries, or investigations of possible violations of our Terms and Conditions or to prevent other damage. In order to comply with tax regulations, your payment information is retained for at least 2 years.
XV. Services that we offer and children
Our services are not directed towards children and you can not use them if you are under 16 years of age. You must be old enough to consent to the processing of your personal data in your country.