This Privacy Statement applies to the offer and use of the mobile game app "Sì Passione Game" (hereinafter "Sì Passione Game" or "App"), which is provided to you by Tabbler GmbH, An der Alster 42, 20099 Hamburg, Germany (hereinafter also referred to as "we" or "us") for use on your mobile device. We develop and publish free mobile games and applications that aim to entertain and inform people.
The app serves advertising purposes of the Armani and L'Oreal brands.
When you use Sì Passione Game we collect, process and use personal data. Because protecting your privacy is important to us, we would like to provide you with the following information about what personal data we collect when you use Sì Passione Game and how we handle that data. This privacy policy covers all personal data that is stored and processed when you use Sì Passione Game and reflects our handling of this data and our obligations in this regard as set out in the EU General Data Protection Regulation (EU Regulation 2016/679) (GDPR), the German Federal Data Protection Act (BDSG), the German Telemedia Act (TMG) and other laws on data protection in the Federal Republic of Germany.
Tabbler GmbH, 20099 Hamburg, Germany (detailed contact information can be found in the imprint within the App or at https://www.tabbler.io/), is the data controller for your data according to Art. 4 No. 7 GDPR.We take our data protection responsibilities seriously and your personal data will only be collected and processed by Tabbler GmbH in accordance with the law and this Privacy Statement.If you enter any data on the website(s) of L'ORÉAL Deutschland GmbH, Johannstraße 1, 40476 Düsseldorf, the L'ORÉAL Deutschland privacy policy applies, which can be accessed via: https://www.loreal.com/en/privacy-policy-links/
This statement relates to the processing of personal date or personally identifiable information about you as a data subject. We refer to this data throughout this statement as "personal data" or "data". This is information from which you can be identified and which can be used to learn personal or factual circumstances about you. This may also include uniquely assigned identifiers such as the IP address of your terminal device and other specific information of your mobile device or a user ID.
When processing your data, we comply with data protection laws and legal bases for data processing, which means that your data will
We will not use your personal data for purposes other than those set out in this Privacy Statement. In particular, we will not use your data for advertising purposes or transfer your personal data to third parties without your consent, unless we are required by law to disclose such data.The legal bases for the processing of your data may be the following:
As a data subject, you have various rights in connection with the processing of your personal data. For more information, please refer to the section "Your rights as a data subject" below within this Privacy Statement.
In most cases, we collect the data as part of your use of Sì Passione Game (e.g., to provide our services and to understand how you use our services and Apps) and in some cases you provide us with the data directly (e.g., when contacting us). Some of the data we may collect from you is necessary for us to be able to offer you our services free of charge.For this purpose, we ask for your consent when you use Sì Passione Game for the first time. For all data processing activities based on your consent, you can revoke your consent at any time.
Sì Passione Game will show advertisements in the game, which are not specific to a user or user data.Moreover, your IP address and general technical Information may also be collected from your device (the name and version of the app to which the ad is served, manufacturer and model, operating system name and version, the language of the operating system, etc.), to ensure that the App will run properly on your device. In addition, your activities within the app when using it (such as usage history and duration, user journey/visited and used areas, dwell time, tapping actions and interactions with the app or advertisements) are captured in a transaction record.The data as specified above is collected by our partners’ SDK integrated into the App. The information above will further be used for analytical purposes. For more detailed information on the data we process see Sections 5., 6. and 7. of this Data Privacy Statement. Subject to your privacy choice below, your personal data will be retained and processed until you revoke your consent. However, if you choose not to agree, we will anonymize your transaction record and process this anonymized data for fraud prevention purposes on the basis of our legitimate interests.If you consent to the collection of data for advertising and analysis purposes as part of your use of Sì Passione Game we may share the above data with the following categories of recipients and recipients:
These partners typically collect data through their own tools (software development kits or "SDK"). For these purposes, we contractually require our partners to obtain your explicit consent from their users. Below is a list of our partners that implement analytic SDKs through our Apps, as well as the privacy policies of their services that describe their handling of personal data and allow you to exercise your rights directly against them, as follows:
Some of these partners typically collect data through their own tools (software development kits or "SDK"), which is integrated in our App. An SDK, is a software component that may collect information directly from our Apps. For these purposes, we contractually require our partners to obtain your explicit consent from their users. You can find a list of our partners who implement advertising SDKs through our Apps, as well as the privacy policies of their services, which describe their handling of personal data and allow you to exercise your rights directly against them, below:
Users of the Sì Passione Game have the possibility, but not the obligation, to enter their data into L’Oreal website(s) to potentially receive free samples and qualify for a raffle. If you enter any data on the website(s) of L'ORÉAL Deutschland GmbH, Johannstraße 1, 40476 Düsseldorf, the L'ORÉAL Deutschland privacy policy applies, which can be accessed via: https://www.loreal.com/en/privacy-policy-links/ None of the data entered on L’Oreal website(s) is shared with Tabbler GmbH.Users of the Sì Passione Game may have the possibility, but not the obligation, to fill out a survey within the Sì Passione Game. The data provided in this survey will not be connected to any other data point. Data will be aggregated and Tabbler GmbH may share aggregated results with L’Oreal.Please visit our third party partners' privacy policies linked above for information on the personal data that they may have from all sources and your data protection rights (e. g. how you can access or delete the information they have about you) under applicable law in relation to the processing of your personal data. The list of our partners may be updated from time to time and is always available here in its current version. The transfer of your data is based on your consent (see above) and thus on the legal basis of Art. 6 (1) a) GDPR.
Data transfers to third countries
Show detailsPlatform-Wide Personalization and changing your privacy choice
Show detailsOur partner’s Data Privacy Statements
Our third party ad partners' privacy policies explain further details, including how and where your data is being processed and your data protection rights under applicable law in relation to the processing of your personal information. Please visit our third party ad partners' privacy policies linked above for information on the personal data that they may have from all sources, and your data protection rights (e. g. how you can access or delete the information they have about you) under applicable law in relation to the processing of your personal data.
I hereby consent to the use by Tabbler GmbH and its advertising and analytics partners of the following personal data in connection with my free use of Sì Passione Game. In order for the free offer of the App to be financed by advertising partners, I agree to the corresponding collection and transmission of the above data to partners of Tabbler GmbH for analysis and advertising purposes.
For all data processing activities based on your consent, you can revoke your consent at any time with effect for the future.
Special fees (beyond the regular transmission fees of your telephone or internet provider) do not apply for the withdrawal of consent. In the event of withdrawal of consent, your data will be deleted from the Sì Passione Game database; if deletion is not possible, restriction of the processing of your data will take the place of deletion.
When you install and use Sì Passione Game we may collect and process some of your data for various purposes. Some of the data we may collect from you is necessary for us to provide you with our services free of charge. Some of the data we may use from you is also necessary for us to comply with legal requirements to which we are subject or if we have a legitimate interest in using your data that outweighs your interests. Below you will find an overview of the purposes for which we collect your data and the legal basis for the use of your data.
We use your data
This data processing is essential to technically enable the full use of our App and is based on the legal basis of Art. 6 (1) b) GDPR.
To record usage data within Sì Passione Game we measure the so-called "customer journey". For this purpose, every click or tip within Sì Passione Game is logged and linked to your profile or stored on the server. For corresponding analyses, we store and use cookies, device identifiers and similar tracking technologies on your end devices and share your corresponding personal data within the scope of the free use of Sì Passione Game with selected partners to determine your interests and needs for the playout and optimization of advertising based on your usage behavior.
We only process and share your corresponding personal data for analysis purposes if you have given your consent to do so and on the basis of the legal basis of Art. 6 (1) a) GDPR.
For all the above purposes, the processing is limited to the following data:
Your data is processed on the basis of your consent (see above) and thus on the legal basis of Art. 6 (1) a) GDPR.
When you use Sì Passione Game we also automatically collect and store certain data and process it for the following purposes:
Your use of our App is automatically logged by our web servers.
The web servers we use automatically store data about the retrieval of our web services in so-called server log files. This is the following data:
The above data is processed for security purposes, for general fraud prevention and as a precaution against attacks on our web services. An automated combination of this data with data from other data sources does not take place. Insofar as our server logs also automatically log your IP address, this is done exclusively for the purpose of ensuring the security of our systems or for fraud prevention purposes and the IP address is automatically deleted after 30 days at the latest.
The processing of this data is therefore carried out to protect the legitimate interests of Tabbler GmbH as the provider of Sì Passione Game and on the legal basis of Art. 6 (1) f) GDPR.
In addition, the above-mentioned usage data is processed and we process it in general and anonymous form to evaluate the use of Sì Passione Game in general. Only general information is collected, e.g. when which contents from our offer are accessed or which pages are visited most frequently, the names of the requested files as well as their access date and time.
This data also includes the models and product names of the end devices used to play Sì Passione Game, the version of the operating systems, their display resolutions as well as general information about when which content from our offer is accessed, the names of the requested files or which content is accessed most frequently as well as their access date and time.
This data is used exclusively for the purpose of designing Sì Passione Game according to your needs, i.e. to continuously improve our services and, if necessary, to identify and eliminate security gaps. We will not use this information for any other purpose without your explicit prior consent.
This data does not allow any conclusions to be drawn about your person.
This data is processed to protect the legitimate interests of Tabbler GmbH as the provider of Sì Passione Game and on the legal basis of Art. 6 (1) f) GDPR.
In addition to the other cases mentioned in this Data Privacy Statement, your personal data will only be transmitted without your express, prior consent in the following cases:
To operate our Apps and services, we sometimes rely on third-party providers (so-called processors). In order for these companies to perform their services, your data must be transferred to them. We have concluded a contract for commissioned processing with these processors in accordance with Art. 28 GDPR and they implement the strict requirements of the data protection authorities when using your data. For all service providers that support us in the provision of our services, we ensure compliance with data protection law through this contract and strict controls that your data is handled exclusively in accordance with our instructions and that it is not passed on to third parties. In addition, we take further measures to protect and secure your data. These will only be further processed outside the European Economic Area if the service provider in question guarantees us that it will comply with the requirements of European data protection law.
The following service providers (processors) cooperate with us on the basis of the purposes stated in each case:
For more information, please see the justrack’s Privacy Policy at: https://justtrack.io/privacy-policy/
For more information, please see the Amazon Web Services Privacy Policy at: https://aws.amazon.com/compliance/data-privacy/?nc1=h_ls.
Please note that, to the extent necessary, we may transfer your personal data to our partners or to service providers based outside of the European Economic Area (EEA) and process your data on servers outside of the European Economic Area (EEA) on condition that the partners or service providers provide sufficient guarantees in relation to required level of data protection, e.g. through a (sub-contracting) data processing agreement which is based on the standard contractual clauses approved by the European Commission Decision (EU) 2021/914 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679, or based on other applicable transborder data transfer mechanisms.
We have implemented appropriate safeguards with our third party partners and service providers. We consistently ensure the strict data protection made legally binding in the European Union and we ensure that your data is handled in accordance with the provisions of this Data Privacy Statement.
We are obliged to protect your privacy and treat your personal data confidentially. Your data will be stored in our databases, which are only accessible to us and employees specifically trained in data protection.
If we use support from third-party service providers who process your data on our behalf in order to provide our web services, we have ensured that they are subject to the strict conditions of this Data Privacy Statement, and that the use of your data beyond the cases described in this Data Privacy Statement will not take place. All contractors, service providers and their employees are subject extensively to our instructions and are also in particular legally obliged to observe, and trained in, the protection of your data.
In order to prevent the loss or misuse of the data stored by us, we take comprehensive technical and organizational safety precautions, which are regularly reviewed and adjusted to meet technological advances. If it is within our sphere of influence, we use in particular modern encryption techniques as well as a variety of other measures to prevent third parties from obtaining unauthorized information.
However, we would like to point out to you that due to the structure of the internet, it is possible that the data protection regulations and the above-named security measures of other persons or institutions not within our area of responsibility cannot be observed. In particular, data transmitted in a non-encrypted form can be read by third parties, even if it is sent via email. We have no technical influence on this occurrence. In these cases, it is the responsibility of the user to protect the data it provides against misuse, by encryption or other methods.
Automated decision making occurs when an electronic system uses personal data to make decisions without human intervention.
If we make an automated decision based on automated processing of personal data, we must either obtain your explicit written consent to do so or it must be justified in the public interest. Furthermore, we must take reasonable steps to protect your rights.
Automated individual decisions based on your personal data or profiling within the meaning of Art. 4 No. 4 and 22 GDPR will not take place unless you have expressly consented to it.
We will retain your personal information only for as long as we need it for your use of Sì Passione Game or to fulfill your requests or our legitimate interests, the purposes for which we collected your personal information, or as long as permitted or required by law:
When we no longer need your personal data, we will delete it from our systems and records or anonymize it so that you can no longer be identified.
We may retain certain personal information to comply with our legal and regulatory obligations and to enable us to administer our rights (such as pursuing our claims in court), or for statistical purposes.
As a data subject of the data processing through your use of Sì Passione Game you have the following rights listed in this section.
If you wish to exercise any of your rights set out below, please contact us using the contact details set out in the "Contact Us" section below.
Please note that we may request proof of your identity and extensive information about your query before we can process it.
Within the framework of the applicable statutory provisions, you have the right at any time to obtain free information about the data stored about you personally, its origin and recipients, and the purpose of the data processing. On presentation of the respective prerequisites, you may also have the right to the rectification of incorrect data, the restriction of the processing, and the erasure of data.
Some forms of data processing are only possible on the basis of your explicit consent. You can withdraw consent already given at any time. The legitimacy of the data processing carried out until the withdrawal will remain unaffected by the withdrawal.
Regarding the data that we process automatically on the basis of your consent or in the performance of a contract, you generally have the right to access it yourself or have it provided to a third party in a customary, machine-readable format. If you require the direct transfer of this data to a third party, this will only take place if this is technically possible with reasonable effort.
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 (1) f) GDPR (data processing on the basis of our legitimate interest); this also applies to any profiling based on this provision within the meaning of Art. 4 No. 4, 22 GDPR.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
The objection can be made without any formalities.
In the event of data privacy violations caused by us, you have the right to lodge a complaint with the competent supervisory authority. The supervisory authority responsible for Tabbler GmbH in data protection law matters is the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI), the contact details of which can be found in the following link: https://www.datenschutz-hamburg.de/wir-ueber-uns-kontakt/wie-erreichen-sie-uns.html.
Should you have any questions or comments about the handling or use of your personal data, should you require information about the personal data stored about you, or should you wish to exercise your other rights named above, you can contact us by post at Tabbler GmbH, An der Alster 42, 20099 Hamburg or by sending an email to privacy@tabbler.io.
As legally stipulated, we have appointed a data protection officer for our company:
Mr. Stephan Krämer, LL.M. (Attorney at law, Germany)
KINAST Rechtsanwaltsgesellschaft mbH
Hohenzollernring 54
50672 Köln, Germany
You can contact our data protection officer via his website http://www.kinast.eu or via email at privacy@tabbler.io.
We always keep this Data Privacy Statement up to date. Therefore, we reserve the right to change it from time to time and to update any changes in the collection, processing or use of your data. Therefore, please read this privacy policy regularly.
You can access the current version of this Data Privacy Statement at any time under the "Data Privacy" section within the App or at https://www.tabbler.io/games_Si Passione Game_privacy
Status: 16.09.2024 (Version: 1.0)
