Privacy Policy

Munich, February 18, 2022

With this information, the responsible body (“We”) named under Section 1 informs the user of the website (“You” or “User”) in accordance with Art. 13 and 14 of the General Data Protection Regulation (GDPR) about the collection and processing of personal data. At the same time, we will inform you if we store information in the terminal device that you use when you visit our website or if we access information that is already stored in your terminal device.

For the use of websites of other providers, which are referred to via links, for example, the data protection information there applies.

1.1 The data processor responsible for this website is: Wolpertinger Games UG, Karlstr. 68, 80335 Munich, Germany.
Contact e-mail: contact [@] wolpertingergames.com

1.2 We are not to appoint a data protection officer.

1.3 Our website is hosted by ALL-INKL.COM (www.all-inkl.com), i.e. it is technically provided on the web servers of this web host. The web host is a processor obligated by us according to Art. 28 DS-GVO.

If we collect personal data from you, you have the following rights as the “data subject”:

2.1 Right to Information: You can request information according to Art. 15 DS-GVO about your personal data that we process.

2.2 Right to Object: You have the right to object on the special grounds of Art. 21 Para. 1 DS-GVO. We will inform you about this separately from this information under "B".

2.3 Right to Rectification: If the information concerning you is not (or no longer) correct, you can request a correction in accordance with Art. 16 DS-GVO. If your data is incomplete, you can request a completion.

2.4 Right to erasure: You can request the deletion of your personal data under the conditions of Art. 17 DS-GVO.

2.5 Right to restriction of processing: In the cases of Art. 18 DS-GVO, you have the right to demand a restriction of the processing of your personal data ("blocking").

2.6 Right to Complain: If you believe that the processing of your personal data violates data protection law, you have the right under Art. 77 Para. 1 DS-GVO to complain to a data protection supervisory authority of your choice.

2.7 Right to data portability: In the event that you have provided us with personal data in accordance with Art. 20 Para. 1 DS-GVO, you have the right to transfer data that we process automatically on the basis of your consent or in fulfillment of a contract to yourself or to third parties in a structured, common and machine-readable format. The collection of the data for the provision of the website and the storage of the log files (subsection 3.1 below) are absolutely necessary for the operation of the website. They are therefore not based on a consent pursuant to Art. 6 Para. 1 Letter a DS-GVO or on a contract pursuant to Art. 6 Para. 1 Letter b DS-GVO, but are pursuant to Art. 6 Para. 1 Letter f DS-GVO justified. The requirements of Art. 20 Para. 1 DS-GVO are therefore not met in this respect.

3.1 Which data is processed for which purpose?

Each time the content of the website is accessed, the web server of our web host, where our website is stored, temporarily collects and stores information (data) from the internet browser of the accessing computer or end device of the user. This data may allow the user to be identified and is therefore personal data.

3.1.1 The following data is collected and stored by our web host:

• • IP address of the user,
  • Date and time the website was accessed,
  • the protocol, e.g. HTTP,
  • the request method "Get" or "Post",
  • Content of the request or specification of the retrieved file that was sent to the user,
  • the access status (successful transmission, errors, etc.),
  • the amount of data transferred in bytes,
  • incoming and outgoing data traffic ("traffic"),
  • a process identification number (“Process ID”),
  • the time it takes for the web server to respond to the user's request,
  • the website from which the user accessed it,
  • the browser used by the user, the operating system, the interface, the language of the browser and the version of the browser software.

3.1.2 The temporary storage of this user data is necessary for the course of a website visit in order to enable delivery of the website. For this purpose, the IP address of the user must be saved for the duration of the session (i.e. the website visit).

3.1.3 A further storage of the IP address with the following data from the above list beyond this purpose takes place in log files (logs). This is done so that our web host can ensure the functionality of the website and the security of the information technology systems.

3.2 On what legal basis is this data processed? The data from Section 3.1 is collected and processed by our web host for the stated temporary storage purpose and also for further storage purposes in accordance with Art. 6 Para. 1 Letter f DS-GVO. The legitimate interest in data processing also lies in this purpose. This legitimate interest is the interest of our web host, but also our legitimate interest in a functioning website.

3.3 Are there other recipients of the aforementioned data in addition to the person responsible? As our processor, our web host has technical access to the data mentioned in 3.1.

3.4 How long is the data stored? The data from 3.1.1 will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. When the website is provided, this is the case when the respective session has ended. The log files are retained for a maximum of 7 days, unless a security event requires longer retention.

3.5 Is there a provision obligation? You must provide our web host with the data from 3.1. Otherwise you will not be able to use our website technically and our web host cannot guarantee secure technical operation.

4.1 Data and information processing requiring consent

If we are only allowed to collect and process personal data with your consent, we will inform you about this in our consent banner in the context of the consent dialog.

4.2 Use of email address and contact form data based on legitimate interests

4.2.1 Which data is processed for which purpose?

If you purchase goods or services on our website and deposit your e-mail address, we may subsequently use this information to send you product information by email regarding the booked product or similar products of the processor. In such a case, only direct advertising for our own similar goods or services will be sent by email. We will also send you emails related to your transactions, such as order confirmations, shipping notices, invoices etc.

It is possible to subscribe to a free newsletter on our website or in our app, which contains direct advertising for our products or products of our cooperation partners. When you sign up for the newsletter, the data from the input mask will be transmitted to us or the email address already stored will be 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.

We will use the information you provide to send you press releases and newsletters. We use MailerLite as our email marketing automation platform. By providing your email contact, you acknowledge that the information you provide will be transferred to MailerLite for processing in accordance with their Privacy Policy and Terms. MailerLite will be responsible for sending the newsletter on our behalf. 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.

The purpose of storing the email address is 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 shipment and to prevent misuse. Furthermore, for information regarding ongoing bookings, the proper execution of the contract is the purpose of the contact.

The transfer to the service provider is done for the purpose of sending the newsletter as automated mailing.

4.2.2 On what legal basis is this data processed?

The legal basis for the processing of the data when sending out the newsletter due to the prior acquisition of goods or services is Article 6 para. 1 sentence 1 (f) GDPR in conjunction with § 7 para. 3 UWG.

The legitimate interest within the meaning of Art. 6 para. 1 (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 Art. 6 para. 1 (a) GDPR.

The legal basis for contacting in connection with current bookings is Article 6 para. 1 (b) GDPR.

The legal basis for the transfer of the data to the shipping service provider is Article 28 para. 3, 6 and 7, Article 46 para. 2 (c) GDPR. The standard data protection clauses of the EU Commission are used in contractual relation with the provider.

4.2.3 Are there other recipients of the aforementioned data in addition to the person responsible?

As our processor, our web host has technical access to the data mentioned in 4.2.1. The data is also stored and processed by MailerLite (www.mailerlite.com) as stated in 4.2.1.

Our direct email communication from wolpertingergames.com is hosted, stored and processed by Microsoft Inc. ("Microsoft") on our behalf. Any further use is not made by the service provider. The service provider is located outside the European Union in the USA.

4.2.4 How long is the data stored?

The data from 4.2.1 will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case for the personal data sent to us by email or the contact form when the respective correspondence with the user has ended and the storage is not required for other reasons. The conversation is over when it can be inferred from the circumstances that the facts in question have been finally clarified.

If we have received your email address as part of the purchase of goods or services, it will be used for the delivery of advertising until you object to further use.

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 mailing, if you revoke your consent. The data confirming the order of the newsletter will be stored for the same amount of time.

The emails sent, as far as business letters are concerned, are stored for the duration of retention periods of the Tax Code or the Commercial Code. The further emails are deleted as soon as no further response by the user has to be expected.

You may object or revoke your consent to the use of the e-mail address for advertising 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 for future use by emailing privacy [@] wolpertingergames.com. In the case of opposition by email, the implementation of the cancellation or blocking can take up to 5 working days; In this period, you may still receive advertising emails. You can not contradict the use of the email address for addressing in the context of the performance of the contract. If you no longer wish this, you would have to delete the account or have it deleted, otherwise we would not be able to properly fulfil the contract.

4.2.5 Is there a provision obligation?

You are not obliged to provide us with data from 4.2.1. You don't have to communicate with us.

4.3 Use of the session cookie "wbk_sid" based on legitimate interests

4.3.1 Which data is processed for which purpose?

As soon as you use the login form or the contact form, the session cookie "wbk_sid" is stored on your end device by default. This cookie contains a long combination of numbers and letters ("ID"). The purpose of the cookie is that the user can be recognized as such and distinguished from abusive users (e.g. SPAM bots) when the sending of login data or contact information is called up.

4.3.2 On what legal basis is this data processed?

The information in this cookie represents personal data. However, the use of the "wbk_sid" cookie does not require any data protection consent, because the data processing is necessary to protect the legitimate interests of the website operator and because the interests or fundamental rights and freedoms of the person concerned, the require the protection of personal data do not prevail. The legal basis for data processing is therefore Art. 6 Para. 1 Sentence 1 Letter f GDPR.

4.3.3 Are there other recipients of the aforementioned data in addition to the person responsible?

As our processor, our web host has technical access to the data mentioned in 4.3.1.

4.3.4 How long is the data stored?

If the user closes the browser, the cookie is automatically deleted from the user's operating system. It is therefore only valid for the duration of the visit to the website (session cookie).

4.3.5 Is there a provision obligation?

You are obliged to provide us with data from 4.3.1. Otherwise you cannot use the login form or the contact form.

4.3.6 Consent to the use of cookies?

Your consent to the storage of information about the "wbk_sid" cookie in your terminal equipment or our access to this information stored in your terminal equipment is dispensable because storage and/or access are absolutely necessary for you to be able to use the login form or the contact form ( § 25 Para. 2 No. 2 TTDSG).

4.4 Use Google Analytics based on legitimate interests

4.4.1 Which data is processed for which purpose?

The website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). This software collects information about how you use the website and compiles various statistics. The increased usage data include in particular the concrete selection of links, the length of stay on individual pages and the order of use of the website, the frequency of the page request. This data is collected together with your IP address. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server outside of Europe in the USA and stored there.

We have activated a so-called IP anonymization on the website, this means that the IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area prior to retransmission to the USA.

Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google itself describes here https://www.google.com/policies/privacy/ its data processing activity.

The purpose of the processing is to analyze this website and the usage behavior of its visitors.

4.4.2 On what legal basis is this data processed?

The legal basis for the processing of data when using the website is Article 6 para. 1 (f) GDPR.
The legitimate interest within the meaning of Art. 6 para. 1 (f) GDPR is a customer-oriented design of the website, which meets the requirements of the users and takes their user preferences into account.
The legal basis for the transfer of data to Google are Article 28 para. 3, and Article 45 para. 3 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), this means that the data protection level of the service provider is recognized as being equivalent to the GDPR, although it is based in the USA.

4.4.3 Are there other recipients of the aforementioned data in addition to the person responsible?

As our processor, Google has technical access to the data mentioned in 4.4.1.

4.3.4 How long is the data stored?

The data is already anonymized directly after the survey. Personal data is therefore collected only in the context of the transfer and not permanently stored.

4.3.5 Is there a provision obligation?

You are obliged to provide us with data from 4.3.1. Otherwise you cannot use the login form or the contact form.

4.4.6 Objection and removal possibility

You can prevent the storage of cookies, including the generation and transmission of data to Google, by restricting or prohibiting the use of cookies in your browser software. This may result in the deactivation of non-Google-related cookies as well as the inability to use all functions of this website to the full extent.

You can prevent the collection of the data generated by the cookie and your use (including your IP address) and their transmission to Google as well as the processing of this data by Google by downloading the browser plugin available under the following link and to install:

Google Analytics Opt-out Browser Add-on.

5.1 If we want to store information in the end device that you use when you visit our websites and/or want to access information that is already stored in your end device, we will ask you for your consent on the basis of clear and comprehensive information . This is done via a consent banner used by us. We obtain any necessary consent before accessing it. You can revoke your consent at any time. However, your consent is not necessary for certain purposes specified in the law, so that we do not ask for it in these cases. On the one hand, consent is not required if the sole purpose of storing information in the end user's terminal equipment or the sole purpose of accessing information already stored in the end user's terminal equipment is to transmit a message via a public telecommunications network. On the other hand, consent to the use of your end device is not required if the storage of information in the end user's end device or access to information already stored in the end user's end device is absolutely necessary so that we as a provider of a telemedia service can provide a telemedia service expressly requested by the user can provide.

5.2 Such access to end devices is possible via certain technologies. The most well-known technology concerns cookies. Cookies are objects that can be stored in the internet browser or by the internet browser on the user's end device. If a user calls up a website, the server of the operator of the website or a third party can read the cookie stored there via the user's operating system and consequently the information stored there. A cookie can, but does not have to, contain a characteristic character string that enables the user's browser to be clearly identified when the website is called up again.

5.3 Removal option: The user can prevent or restrict the installation of cookies by setting their browser accordingly. Cookies that have already been saved can also be deleted at any time by the user via their browser. The settings for this depend on the respective browser. However, if the user prevents or restricts the installation of cookies, this may mean that not all functions of the website can be used to their full extent. What applies to cookies also applies to other technologies that use the user's end device.

5.4 Cookies and similar technologies requiring consent: Our consent banner on the website provides information on cookies and similar technologies requiring consent.

5.5 Cookies and similar technologies that do not require consent: With regard to cookies and similar technologies that do not require consent, we have documented internally that consent under Section 25 (2) TTDSG is not required.

6.1 In order to be able to obtain a legally required consent from you for certain services or functions or to observe your revocation in this regard, you will be shown a consent banner. Your consent or non-consent affects our use of your end device (computer, laptop, smartphone, tablet) through cookies or similar technologies, with which information can be stored on your end device or read from it. Your consent may also be required for the processing of personal data by us or third parties in accordance with Art. 6 Para. 1 Sentence 1 Letter a DS-GVO, which is associated with your use of our websites. In certain cases, the law allows us to use your end device without your consent and/or also to process your personal data subsequently without your consent.

6.2 We use the consent banner to inform you about all services or functions that require your consent before we use the service or function. The consent banner consists of an overview of all processing operations that require consent and describes details so that you as a user can assess the meaning and scope of your consent. You can agree to each process via a button/click area by activating it or rejecting this process by deactivating it. There are three choices:

• Choosing "Make selection and save" means that the user's decision is saved as he made it through his selection via the buttons/click area. All services and functions that require consent and to which the user agrees are active and can be used. The services and functions that cannot be used without consent are not integrated on the website.
• Choosing "Reject all and save" means that this decision will not be saved. The decision of the user is therefore that he does not consent to anything that requires his consent and has the consequence that all services and functions that require consent do not work for this user. The banner will be hidden.
• Choosing "Accept and save everything" means that all services and functions that require consent are "sharp". This means that you have given your consent in accordance with the GDPR and also agree to the use of the end device. The banner will then disappear.

In the course of his further use of the websites, the user can actively cause the consent banner to be displayed by revoking a given consent or by obtaining a consent that is not initially required. To do this, he clicks on the “Consent Settings” link. The consent banner reappears.

Your consent can therefore be revoked at any time with effect for the future. A later revocation no longer affects the legality of the access or the storage of information that took place up to that point.

6.3 All of the above three user decisions (“make selection and save”, “reject everything and save” or “accept everything and save”) are made via the browser of the user’s end device in the so-called “local storage” on the user’s end device saved. The storage there is permanent. The information is stored in the "wbkConsent" object. This technique is not actually a cookie. The information in the "wbkConsent" also has no personal reference, i.e. the user is not recognized when he calls up the WBK user's website again. The selection decision for consent is not stored on our server. This use of the user's end device does not require consent in accordance with Section 25 Paragraph 2 No. 2 TTDSG (user request).

7.1 SSL/TSL

For security reasons and to protect the transmission of confidential content, for example by means of inquiries that you send to us as the site operator, our websites are equipped with an active SSL or TLS encryption. An encrypted connection can be recognized by the fact that the address line of the browser changes from "http://" to "https://" and a lock symbol can be seen in the browser line. As a result of this encryption, data that you transmit to us cannot be read by third parties.

7.2 End-to-End Communication

If you contact us using an email address provided on our website, the transport of the content of the email to us is not end-to-end encrypted. This means that the e-mails are usually encrypted during transport via the e-mail provider involved, but are unencrypted on the servers there. Contacting us via the contact form provided is therefore technically secure communication.

7.3 Video Embedding

Insofar as you can view videos on our website that are marked as external links to third-party websites, this is done exclusively via the technology of linking to the respective linked website or to a video portal of a third-party provider. These videos are stored there under the responsibility of the respective third-party provider under data protection law. The website referred to in each case or the respective video portal is therefore not directly embedded in our website. This ensures that user information is not transmitted to the portal when the website on which the video is integrated is loaded. It is also guaranteed that the mere link cannot set cookies or similar technologies for tracking user activities of the portals or the advertising partners of these portals on your end device. Only after you deliberately click on the video preview image is a connection to the third-party portal established and the associated data processing triggered. However, this and the possible data processing of your user data on the linked portal then only takes place if you wish to see the video there. The resulting data processing is beyond our control and is the responsibility of these third-party providers, who provide more or less detailed information about their data processing. If you do not agree to the data processing by the third party, please do not click on the video thumbnail. 

Special right to object according to Art. 21 Para. 1 DS-GVO

You have the right, for reasons that arise from your particular situation, at any time against the processing of your personal data, which is based on Article 6 Paragraph 1 Letter f DS-GVO (processing to protect our legitimate interests or those of a third party ), objection according to Art. 21 Para. 1 DS-GVO. You can address the objection to the address in Section 1.1.

We will then no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves us to assert, exercise or defend legal claims.

In the event of your objection, you must explain to us your interests (your “particular situation”) in detail so that we can reconsider your interests. If our interests in further storage do not prevail, the personal data stored in the course of making contact will be deleted. If these still prevail, we will continue to process the data.