Headup GmbH Privacy Policy

  1. Name and address of the person responsible

 

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is the:

 

Headup GmbH

Nordstr. 102

52353 Düren

Germany

E-mail: info@headupgames.com

Website: http://headupgames.com

 

  1. Name and address of the data protection officer

 

Mr Frederik Bocklaff

c/o NIMROD Attorneys at Law
Bockslaff Kupferberg GbR
Emser Street 9
10719 Berlin
Phone: +49 (0) 30 544 61 793
Fax: +49 (0) 30 544 61 794
E-Mailinfo@nimrod-rechtsanwaelte.de

 

  1. Definitions
  1.          "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

  1.       "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

  1.       The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

 

  1.       "Special categories of personal data" are data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person

 

  1. Data processing in our game

In the following we inform you about the collection of personal data when using our game. The controller pursuant to Art. 4 No. 7 GDPR is Headup GmbH, see I.

We do not process any of your personal data when you use our game.

 

  1. Technical requirements, setting up an account with a gaming platform operator

In order to use the content and services of Headup, you must have Internet access and a user account with a gaming platform operator. We offer our content and services via the following gaming platform operators, although not all content may be available via every platform.

 

 


Please note

The controller for all data collected, used and processed in connection with the data collected, used and processed by the gaming platform operators is the respective gaming platform operator. Headup is in no way involved in the collection, use and processing of data by a gaming platform operator. The contact details and privacy policy of the individual gaming platform operators can be found here:

 

https://store.steampowered.com/?l=german

https://store.steampowered.com/privacy_agreement/german/

 

https://www.gog.com/

https://support.gog.com/hc/de/articles/212632109-Datenschutzrichtlinie?product=gog

 

https://www.epicgames.com/site/de/home

https://www.epicgames.com/site/de/privacypolicy

 

https://store.playstation.com/de-de/pages/latest/

https://www.playstation.com/de-de/legal/privacy-policy/

 

https://www.xbox.com/de-DE/microsoft-store

https://privacy.microsoft.com/de-de/privacystatement

 

https://store.nintendo.de

https://store.nintendo.de/de/privacy-and-cookies

 

https://www.apple.com/de/app-store/

https://www.apple.com/de/legal/privacy/

 

https://play.google.com

https://policies.google.com/privacy

 

 

  1. Data subject rights and your right to lodge a complaint with the supervisory authority

 

As a person affected by the processing of your personal data, you can assert the following rights against us in accordance with the GDPR and the respective national regulations ("data subject rights"):

  1.     Rights of data subjects

a) Right to information in accordance with Art. 15 GDPR: You have the right to request information about the personal data stored concerning you, in particular about

- the purposes of processing

- the data categories

- the recipients to whom your data is transferred, in particular recipients in third countries or international organisations

- the planned storage duration or, if not possible, the criteria for determining this duration

- the existence of a right to rectification or erasure of the data or to restriction of processing or a right to object to such processing

- the existence of a right of appeal to a supervisory authority

- the origin of the data if we have not collected it directly from you

- the existence of automated decision-making, including profiling, and in particular meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

- the appropriate safeguards pursuant to Art. 46 GDPR when transferring your data to a third country or an international organisation.

The exceptions according to § 34 BDSG apply.

b) Right to rectification in accordance with Art. 16 GDPR: You can demand that we rectify incorrect personal data concerning you without undue delay and, if necessary, complete incomplete personal data.

c) Right to erasure in accordance with Art. 17 GDPR: You can request that we erase your personal data if the legal requirements for this are met. This may be the case, for example, if

- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed

- you withdraw your consent, which is the basis for the data processing, and there is no other legal basis for the processing

- you object to the processing of your personal data and there are no overriding legitimate grounds for the processing, or you object to data processing for direct marketing purposes

- the personal data have been processed unlawfully

- the deletion of the data is necessary to fulfil a legal obligation under Union law or the law of the Member States

- the data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

The exceptions of Art. 17 para. 3 GDPR apply.

d) Right to restriction of processing pursuant to Art. 18 GDPR: You can request that we restrict the processing of your personal data if

- you contest the accuracy of the personal data for as long as we need to verify the accuracy of the data

- the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead

- we no longer need your personal data, but you need it to assert, exercise or defend legal claims

- you have objected to processing pending the verification whether our legitimate grounds override yours.

e) Right to data portability pursuant to Art. 20 GDPR: At your request, we will provide you with your personal data that you have provided to us in a structured, commonly used and machine-readable format so that you can transfer it to another controller. However, you are only entitled to this right if the data processing is based on your consent or is necessary to fulfil a contract and the processing is carried out using automated procedures.

f) Right of revocation in accordance with Art. 7 para. 3 GDPR: You have the right to revoke your consent to us at any time. As a result, we will no longer continue the data processing based on this consent in the future.

g) Right to object in accordance with Art. 21 GDPR: If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR, you have the right to object to the processing of your personal data if there are reasons for this arising from your particular situation or if the objection is directed against direct advertising or against profiling, insofar as it is associated with such direct advertising. In the event of an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests or we need your personal data for the establishment, exercise or defence of legal claims.

For profiling, the exception of § 37 BDSG applies.

If you wish to exercise your right of cancellation or objection, simply send an e-mail to info@headupgames.de.

h) You also have the right under Art. 77 GDPR to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or workplace.

  1.       Deadlines for the fulfilment of data subject rights

We generally fulfil requests within one month. However, this period may be extended due to the specific rights of the data subject or the complexity of your enquiry. In this case, we will inform you of the reasons for this within the one-month period.

 

 

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