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I. Controller, Scope

SpielFabrique is a service provided by SpielFabrique 360° UG (haftungsbeschränkt) (hereinafter also referred to as “Spielfabrique” or “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find full company and contact details on the website.

The protection of personal data has the highest priority for us. We would therefore like to inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data on the website https://spielfabrique.eu/ (hereinafter referred to as "Website").

II. General information about data processing

1. Purposes of processing

In principle, we only process personal data of users as necessary to provide a functional Website, our contents and to provide our services.

2. Legal basis for the processing of personal data

We mostly process personal data according to on one of the following legal bases:

Whenever we collect the data subject’s consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.

legal obligation
If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.

contract or pre-contractual measures
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

legitimate interests
If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis.

3. Data erasure and retention time

In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.

Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by the any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.

4. Transfer to third countries

Unless otherwise stated, all data processing operations take place within the EU or the EEA countries.

Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.

A transfer of personal data outside the EU or the EEA shall only take place on the basis of on an adequacy decision of the European Commission or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. A list of current adequacy decisions (as well as information about the effect of the ECJ’s ruling in the case C-311/18 on Privacy Shield) is available on the European Commission's website.

IV. Processing of personal data when submitting an application

If you submit an application to take part in one of our programs for games studios, we will collect the following personal data:

The above personal data, alongside further non-personal information, will be processed and used in order to create your user account, evaluate your application and make a decision regarding your participation in the program. In case your application is successful, we will store and process the above-mentioned data for the entire duration of the program for the purpose of executing the participation contract we will enter into with you. Thereafter, we may store your date for longer, in case you consent or in case we’re required to do so under applicable law. In case your application is unsuccessful and unless otherwise agreed with you, we will delete all data within three months of the selection of participants.

The legal basis for processing is therefore art. 6 par. 1 lit. b) GDPR.

V. Data Processors

In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This applies for instance to hosting providers. All experts, consultants and mentors that help us providing our services within the scope of the program will also have access to your data, strictly limited to the purpose of performing their duties and tasks within the scope of the program. None of these actors shall process your data for own purposes. As our programs are publicly funded, we may as well be required to share your data with public, statal or European money givers. As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors processing your personal data on our behalf.

VI. Processing in compliance with a legal obligation

Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations which we are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us in case you want to learn further details about such processing activities.

In such cases the legal basis of the processing is art. 6 par. 1 lit. c) GDPR.

VII. Use of Tracking technologies

1. Description and scope of data processing

In order to improve user experience of our Website and to enable selected functions, we implement cookies or other tracking technologies (hereinafter jointly referred to as “Cookies”) on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e. after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies). You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time. Failure to accept Cookies may result in minor limitations in our service’s functionalities. Cookies are stored on the user's computer and from there transmitted to our site. Therefore, you as a user have full control over the use of Cookies. You can deactivate or restrict the transmission of Cookies by adjusting the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. You can also manage your cookie preferences via recognized third-party services such as http://www.youronlinechoices.eu/ (if you’re based in the EU).

2. Strictly necessary Cookies

Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such IP address, log-in information, etc.

The processing of personal data through strictly necessary cookies – if any – is art. 6 par. 1 lit. f) GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1 lit. b) GDPR.

3. Other Cookies

In addition, we use third-party Cookies to monitor and evaluate user behaviour for statistics and market analysis purposes. Such Cookies are provided by third parties and implemented in our Website. Please refer to the following sections for details.

Such Cookies allow us to analyse your use of our service and improve it continuously. Analytics allow us to offer you a better service that meets your interests better.

Unless otherwise specified, the legal basis of processing through other Cookies mentioned below is your consent pursuant to art. 6 par. 1 lit. a) GDPR. Unless otherwise specified, the lifetime of Cookies used based on your consent expires upon withdrawal of your consent.


We implement "Google Analytics". Google Analytics is a web analysis service provided by Google Inc. The information generated by the Google Analytics Cookie about your use of our Website is generally transmitted to and stored by Google on servers in the United States. IP anonymization has been activated on our Website: this means that the IP address of users based within the European Union or the European Economic Area is abridged, and therefore anonymized, before being transferred abroad. Only in exceptional cases is the unabridged IP address transferred to a Google servers in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to draft reports about Website activity and to provide us with other services relating to Website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not put in relation with other Google data. You may object to the use of Cookies by selecting the appropriate settings on your browser, however please note that doing so may result in limited functionality of this Website. You can also prevent Google from collecting the data generated by the Cookie and relating to your use of the Website (including your IP address) and processing this data by installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. To find out further information about how Google handles personal data, please refer to Google's privacy policy: https://policies.google.com/privacy?hl=en.

VIII. Promotional e-mail messages

You can subscribe to our newsletter by entering your e-mail address in the respective form. You will then receive an automatic confirmation e-mail to the address you entered, which contains a link. The registration process is only completed once you confirm it by navigating to that link. We use your email address to send you updates, information and content related to our own services and programs. The data will not be passed on to third parties.

You can withdraw your consent to receive newsletters at any time without stating reasons by following the instruction provided in each newsletter sent, or by sending us an unambiguous notice at unsubscribe@spielfabrique.com. We will inform you about the right to withdraw your consent upon subscription to the newsletter service and within each newsletter sent.

The legal basis for processing your personal data is art. 6 par. 1a) GDPR.

IX. Data Subjects’ rights

As a data subject, you have the following rights pursuant to the GDPR: Your right of access - You have the right to ask us for copies of your personal information. Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. Your right to notification - If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients. Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section. Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please reach out for us at the contact details indicated on the Website if you wish to make a request. Your right to file a complaint You can also complain to a data protection authority if you do not agree on how we have used your data.

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

X. Amendments to this privacy notice

Due to the dynamic development of the Internet, new technologies and possibilities are constantly developing. To enable us to offer you these possibilities and technologies, we reserve the right to change this privacy notice for the future when introducing new, additional or when changing or extending existing services or service elements. The new privacy notice shall apply from the date of its update on the Website.