Logo PRIVACY POLICY PRIVACY POLICY This Privacy Policy applies to this website and all other products and / or services and / or games (collectively “the Services”) of Koch Media GmbH, Gewerbegebiet 1, 6604 Hoefen, Austria (“Koch Media”). Koch Media is serious about protecting users’ privacy and personal data. Our data protection practices comply with the legal regulations of the respective country of residence and the EU General Data Protection Regulation (GDPR). We process your data only for the purposes described herein. We will only collect the information we need to provide our services to you and to pursue our legitimate interests. We will not send you advertising nor will we share your information with third parties without your consent or other legal basis. We ensure that the law and this Privacy Policy are respected by us, our employees and external service providers who work or otherwise carry out services for us. For this we have taken appropriate technical and organizational measures, which correspond to the state of the art (more information under Security of Data). This Privacy Policy shall explain how Koch Media collects and uses personal and non-personal information when you use our services. If you have further questions or comments regarding privacy or to assert your legal rights, please contact Koch Media’s data protection officer, Mr. Liang Zhang to reach below Koch Media GmbH Lochhamer Str. 9 D-82152 Planegg Germany Tel .: +49 89 24 24 5 405 Fax .: +49 89 24 24 5 3405 E-mail l.zhang@kochmedia.com. PLEASE READ THE FOLLOWING PRIVACY POLICY, FOR INFORMATION REGARDING THE COLLECTION, USE AND DISTRIBUTION OF PERSONAL INFORMATION, CAREFULLY. WHEN YOU USE ANY ONLINE OR OFF-LINE GAME, PRODUCT, SERVICE OR WEBSITE FROM KOCH MEDIA OR REGISTER FOR ANY KOCH MEDIA ACCOUNT YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE ANY KOCH MEDIA SITE, GAME, PRODUCT OR SERVICE. 1. Personal and non-personal data What data Koch Media collects depends on what services you use. We collect personal as well as non-personal user data. Personal data collected by Koch Media is discussed in Section A below. Non-personal data is discussed below in Section B. The data controller of the collected personal data is Koch Media GmbH, Gewerbegebiet 1, 6604 Hoefen, Austria. A. Personal Data collected by Koch Media What is Personal Data Personal Data means any information relating to an identified or identifiable natural person. Personal Data is one that identifies you directly or indirectly (also in conjunction with other data) and that can be used to contact you online or offline. How does Koch Media collect Personal Data? Koch Media collects and uses Personal Data of our users only insofar as it is necessary for the provision of our services and to fulfill our obligations. The collection and use of Personal Data takes place regularly only with your consent. An exception applies to cases in which prior consent is not possible or where the processing of the data is permitted by law, for example in pursue of our legitimate interests. Lawful grounds for the processing of your data Insofar as we obtain the consent of the data subject for processing of Personal Data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as lawful ground. If the processing of Personal Data is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO serves as lawful ground. This also applies to processing operations prior to entering into a contract. Insofar as processing of Personal Data is required to fulfill a legal obligation that is subject to our company, Art. 6 para. 1 lit. c DSGVO serves as lawful ground. If processing is necessary to pursue the legitimate interests of our company or a third party, and if the interests, fundamental rights and freedoms of the data subject do not prevail over our interest, Art. 6 para. 1 lit. f DSGVO serves as lawful ground for processing. How long will your data be stored / Revocation of consent Your Personal Data will be deleted or blocked as soon as the purpose of processing is achieved. It may also be stored if provided for by the European or national legislator in EU regulations, laws or other regulations to which we are subject. Blocking or deletion of the data also takes place when a storage period prescribed by the laws mentioned expires, unless there is a need for further storage of the data for conclusion or fulfillment of the contract. Is the right to process Personal Data based on your consent in accordance with Art. 6 para. 1 lit. a GDPR the data will be deleted or blocked as soon as the purpose of the storage is canceled or if you revoke your consent. A revocation is possible at any time. Please contact our data protection officer for any inquiries. For more information please see Your Legal Rights. What kind of Personal Data is collected by Koch Media What Koch Media collects depends on the service you use: Games Online Account You can create an online account for our games to play online and / or to enhance your gaming experience. For this we collect and process your data when registering and creating the account. These include for example – surname; – username; – e-mail address; – postal address; – date of birth; – mobile phone number; – payment information. When you participate in online multiplayer games, your game-related profile information, game data, and stats are public. You can interact with your teammates in a variety of ways. We log the game data to ensure the stability and technical improvement of our games and for backup purposes. Personal Data can also be stored in this process. These data are collected only for the purposes stated above and will not be passed on to third parties. We collect information about which games are played, information about the playing time and which advertisements or links are clicked on. A personal identification of the user is based on the data stored in the cookie. Some of our services and / or products require an online account. As far as you voluntarily use our online services, we process your data with your consent in accordance with. Art. 6 para. 1 lit. a GDPR. You may delete your user account and/or your public information at any time. Social Media Linking Many of our games offer the option to connect to your social media account in-game (e.g. Facebook, Xbox Live, Sony Playstation Network, Apple Game Center, etc.) to play with your friends, find new friends, or to share and compare scores. In these cases, the respective platform collects and uses your Personal Data. Koch Media has no influence on the processing. Please read the privacy policy of the platforms carefully. Analysis Tools Koch Media uses its own metrics analysis tools and other analytic technologies to collect non-personally identifiable information when you use our online products and services or play our games on your PC, console and mobile device. This is for analysis and statistics purposes. A user-based profile is not created. For more information see Cookies / Pixels. Websites When you visit our websites, access data is recorded in the log file on our servers. We record: Internet protocol, address / IP address, page from which the file was requested, date, time, browser type and operating system, page visited, data transfer, access status (file transfer, file not found, etc.). We use the log files to ensure the functionality of the website, to monitor traffic on our websites, to resolve technical issues, and to generate statistics that help us tailor our services to your needs. This is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. We do not store this data together with other Personal Data of the user. If it comes to an abuse of our websites, we can block IP addresses if necessary. The data is stored only for a limited period of time and only for as long as necessary to ensure the safety and functionality of our websites. On our websites, we use active Java Script content from external providers. By visiting our websites these external providers may receive Personal Data about your visit. In this case, processing of data outside the European Economic Area (EEA) is possible. You can prevent this by using a java script blocker such as install the browser plugin ‘NoScript’ (www.noscript.net) or disable java script in your browser. This can lead to functional restrictions on websites We also use cookies on our websites. They will be discussed below in a separate section (see Cookies / Pixels). Registration / Customer Service When you register for a Koch Media service or call our support team, Koch Media collects and uses necessary data to provide the service. This may include information such as name, company name, e-mail address, telephone number, mailing address or payment information. We only store them for as long as we need them to provide the respective service. E-mail contact / contact form You can contact us by e-mail or through our contact form at any time. In this case, the Personal Data transmitted by e-mail or with your inquiry will be stored. The data is used exclusively for communication. The data will be deleted as soon as it is no longer necessary for the purpose of its collection. This is e.g. the case when the respective communication is finished. You can object to the storage of your data at any time or revoke your consent. Newsletter You can sign up for our free newsletter on our websites. In addition to your e-mail address, we collect and save the time of the submission of your consent. Only then can we document that you have voluntarily registered. Your data will not be shared and will only be used to send newsletters. If you purchase goods or services on our web pages and deposit your e-mail address, this can subsequently be used by us for sending a newsletter. In such a case, the newsletter will only send direct mail for our own and similar goods or services. Our newsletters includes a so-called “web beacon”. This is a pixel-sized file that we use to analyze the reach and success of our newsletter and tailor it to your needs. This is our legitimate interest pursuant Art. 6 para. 1 lit. f GDPR. This data will only be forwarded to us anonymously. A user analysis is not possible on the basis of this data. We store your data only as long as the subscription to the newsletter is active. You can cancel the subscription at any time. You will find a unsubscribe link in each newsletter. Public information (online multiplayer games, community forum, blogs, Facebook, Twitter, etc.) For all public information, including user-generated content, the following applies: You can decide whether to post information about yourself on Koch Media websites or in games, in public online chat rooms, blogs, forums, message boards, or similar forums on our pages or other social media platforms. Everyone can have access or view this public information. Information that you provide in this form is public information and you must not expect privacy or confidentiality. You should be aware that Personal Data you provide in the course of these public activities can be read, collected or used by other users of these forums, and may also be used to provide you with unsolicited messages. Please also note that these contributions may be deleted or withdrawn by Koch Media in accordance with the terms of use of these pages. We are not responsible for personally identifiable information if you have chosen to enter it in these forums. Therefore, before publishing, make sure that your posts do not contain information that is inappropriate for the public. You should be aware that your posts can be retrieved from search engines and are accessible worldwide, without being specific to our portal. Deleting or correcting such entries is often not possible with foreign operators. Please make sure your privacy settings reflect your attitude. You may object to your data being processed by Koch Media at any time or revoke your consent. For more information, see Your Legal Rights. Sales of products For the distribution of our own or partner products we process personal data which we have collected directly from you or which has been collected by a third party and subsequently transmitted to us. We need this information, among other things, to process the payment and deliver the products. Inventory, usage and statement data are, if necessary, also processed beyond the fulfillment of a contract. Koch Media reserves the right to save IP addresses and log files for a limited period of time after using the website. This is to monitor and control that you comply with our terms and conditions, in particular to ensure proper execution of the payment you have authorized. This process serves, in particular, to prevent or clarify cases of abuse and, in certain cases, to transmit this data to the competent authorities. To enforce regulatory compliance, IP addresses and console IDs, if available, can be used to personally identify you. Incidentally, any other evaluation of the data takes place anonymously. If no law enforcement action is taken and no abuse pre-trial has been initiated, the IP addresses, log files and related Internet information will be stored for a maximum of six months under our statutory data retention obligation. Cookies / Pixels Koch Media uses Cookies and similar technologies to – to offer our services; – to ensure that our websites function properly; – learn more about our users and their interests; – and to make interesting offers and inform about our services. Cookies are small files that are used in your internet browser to track movements within web pages and to allow analysis of web page usage. We may associate Cookie information with personally identifiable information. The processing of Personal Data using Cookies and similar tracking technologies serves our legitimate interest and is based on Art. 6 para. 1 lit. f GDPR. Restrict / Deactivate Cookies Cookies are stored on your computer and transmitted by it to our website. Therefore, as a user, you have full control over the use of Cookies. You can deactivate the use of Cookies in your browser settings at any time and delete already stored Cookies. This can also be done automatically. Most browsers are automatically set to accept Cookies. If you do not wish to have Cookies stored on your computer or to be informed about their storage, you can prevent the installation of Cookies by adapting your browser software accordingly. In your browser settings, activate the option “Do not accept cookies” or “Do Not Track” (different depending on your browser). The instructions of your browser manufacturer will give you more information on how this works. However, we would like to point out that by preventing Cookies you may not be able to use all the functions of the website to the fullest extent. We also use Flash Cookies – also known as “locally shared items” – on our websites. Flash Cookies are small files, much like browser cookies, and are used to customize the design of web pages and store those requests. Flash Cookies only collect aggregated data. Like normal Cookies, Flash Cookies are small files on your computer. You can prevent Flash Cookies by adjusting your settings in the Macromedia Website Privacy Settings panel at www.macromedia.com. Please note that this Privacy Policy covers only the use of cookies by Koch Media, but not the use of Cookies by other advertisers. Technically necessary Cookies The purpose of using technically necessary Cookies is to facilitate the use of websites. Cookies store, for example, which items you have selected when buying in our shop and stores them in your shopping cart. We also use Cookies to save language settings or to remember search requests. Analysis, tracking and advertising cookies Koch Media uses its own metrics analysis tools and other analytic technologies when you use our online products and services or play our games on your PC, console and mobile device. These data are anonymous and not personal. The use of the analysis cookies is for the purpose of improving the quality and content of our websites. Through analysis cookies we learn how the website is used and so we can constantly optimize our offer for you. We also use Cookies to show you content that suits your interests and to monitor the website. Our pages access external ad companies whose ads are shown. These ads contain Cookies. Cookies posted via banner advertising are used by our advertising companies and Koch Media has no access to this information. You can deactivate and delete the use of Cookies in your browser settings at any time (see Restricting / Deactivating Cookies). Third Party Cookies Third Party Advertising Services Our websites contain third party advertisements and interactive links to third party websites. The third-party providers collect data about your online activities, such as the websites you visit, the automatic transmission of your IP address and the use of cookies. In this connection, no link is created between this information and your name, address, telephone number or e-mail address. We have no influence on the content and design of the linked external websites and their respective links. The data processing by these third parties is therefore not included in this Privacy Policy. The responsible providers are solely responsible for the content and design of these websites and for compliance with the provisions of the data protection acts. For more information about these services or how to disable these services, see the web pages for these services. You can deactivate and delete the use of cookies in your browser settings at any time (see Restricting / Deactivating cookies). Google’s retargeting tools Our websites use Google Inc.’s Google AdSense Resale Technology, 1600 Amphitheater Parkway Mountain View, CA 94043, USA (“Google”). This technology enables targeted ads to be shown to users who have already visited our online services and are interested in our services. Likewise users who are similar to the visitors of our websites can be addressed. Advertising is displayed using cookies. The information generated by the Cookie about the use of the website is transmitted to Google’s servers in the USA and stored there. If the IP address is transmitted, it will be shortened by the last 3 digits. With Cookies, the user behavior on a website can be analyzed and then used to deliver targeted product recommendations and advertising based on the interests of the user. If you prefer not to receive targeted advertising, you may disable Google’s use of cookies for these purposes by visiting https://www.google.com/settings/ads/. You can deactivate and delete the use of Cookies in your browser settings at any time (see Restricting / Deactivating Cookies). Please note that Google has its own privacy policy that is independent of ours. We assume no responsibility or liability for their policies and procedures. We encourage you to read Google’s privacy policy (https://www.google.com/intl/en/policies/privacy/). Google Tag Manager Koch Media uses the Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage web page tags from one interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not collect personally identifiable information. The tool triggers other tags, which may collect data. Google Tag Manager does not access this data. If disabled at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. Google Analytics Koch Media uses Google Analytics, a web analytics service provided by Google Inc. “1600 Amphitheater Parkway Mountain View, CA 94043, USA (” Google “). The use includes the Universal Analytics operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID, thus analyzing the activities of a user across devices. These tools use “Cookies”, which are text files placed on your computer that allow the website to analyze how users use the website. The information generated by the Cookie about the use of the website (including your IP address) is transmitted to and stored by Google’s servers in the United States or in certain other countries. If IP anonymization is enabled, Google will, for IP address within a Member State of the European Union and other parties to the Agreement on the European Economic Area, abbreviate / anonymize the last eight digits of the IP address. Only in exceptional cases will the full IP address be sent and shortened to Google servers in the United States or certain other countries. Google will use this information on behalf of the website’s provider to evaluate your use of the website, to compile reports on the website activity for website operators and to use the website provider other services related to website activity and the Internet Use. Our legitimate interest in data processing also lies in these purposes. Sessions and campaigns stop after a certain amount of time. By default, sessions will end after 30 minutes of no activity and campaigns after six months. Google will not link your IP address with other Google data. You can refuse the use of Cookies by making the appropriate settings in your browser. Please note, however, that you will not be able to use the full functionality of this website. In addition, you can prevent the collection and use of data (cookies and IP addresses) by downloading and installing the browser plug-in at https://tools.google.com/dlpage/gaoptout?hl=en-US. Opt-out cookies prevent future collection of your data when you visit this website. To prevent Universal Analytics tracking across devices, you must opt-out on all systems you use. For more information, see Cookies. More information about the Terms of Service and Privacy can be found at http://www.google.com/analytics/terms/en.html or at https://www.google.com/intl/en_uk/policies/. Facebook Plugins Koch Media uses social media plugins. For example, the “Like” button from the social networking site facebook.com. These plugins are operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins can be identified by one of the Facebook logos. When an user accesses one of our web pages containing one of these plugins, the internet browser connects directly to the Facebook servers. Facebook sends the contents of the plugins directly to the user’s browser and back. If you have activated scripts in your browser and have not installed a script blocker, your browser will forward your Personal Data to Facebook without any separate request. If logged-in, an immediate assignment of the data to the Facebook profile is possible. Since we have absolutely no control over the amount of data that Facebook collects with the help of these plugins, we would like to inform the user about our current level of knowledge: The plugins that are integrated mean that Facebook will be notified when the user has accessed the corresponding page on our website. If the user is logged in to Facebook at the same time, Facebook can assign a visit to the user’s personal Facebook account. When the user interacts with the plugins, for example by clicking on the “Like” button or posting a comment, the information is immediately transmitted by the browser directly to Facebook, where it is stored. If the user does not use Facebook, the service can still capture and store the IP address. For more information on how much data is collected and why and how it is then processed and used by Facebook, as well as information about user rights and the settings that are available to protect the privacy of users, you can access the Facebook Privacy Policy www.facebook.com/policy.php. If you do not want Facebook to collect data from the Koch Media website and link it to the information stored on Facebook, please log out of your Facebook account before visiting our websites and block the execution of Facebook script content in your browser. If you are not logged in to Facebook or have not (yet) agreed to your data being collected and used, you should not click on Facebook plug-ins. Facebook Pixels Koch Media also uses Facebook Pixels. The Facebook Pixel is part of the code implemented in our website. Its goal is to show conversions (it shows which devices were used by a user in an action) to create a so-called lookalike audience (ie, to reach users with advertisements that have features similar to other customers and to generate comprehensive statistics on the use of our website. When you visit our website, the Facebook Pixel creates a direct link to the Facebook servers. In this case, the Facebook server will be informed that you have visited our website and Facebook will assign this information to your personal Facebook profile. This process is designed to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and may help to optimize future advertising efforts. Our legitimate interest in data processing also lies in these purposes. The data collected is anonymous to us, so do not provide us with any conclusions about the identity of the users. For more information see Cookies. Further information about the collection and use of your personal data via Facebook as well as your rights and options can be found here: https://www.facebook.com/about/privacy/. How to disable the feature is explained here: https://en-en.facebook.com/business/help/1415256572060999?helpref=uf_permalink. For this you must be logged in with your Facebook account. Facebook Insight When you visit our Facebook pages, Facebook save Cookies on your device. The data collected includes the age group, gender, education, occupation, relationship status and other information that is publicly available on your Facebook profile. This serves Facebook and us to find out more about your interests and hobbies and to make you more suitable offers. This is also our legitimate interest. We point out that Facebook currently does not offer the operators of a fan page any possibility to control or to restrict the Facebook Insight cookie. If you do not agree, we ask you not to visit our fan page. You also can deactivate the use of Cookies in your browser settings at any time and delete already stored Cookies. For more information see Cookies. Twitter conversion Tracking We use Twitter Inc.’s Conversion Tracking Service, 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). This tracking records when a user of our website clicks on a link posted by Twitter. In this way, we and Twitter can see if a login has taken place. The identity of the user remains anonymous. In addition, we use the Tailored Audiences Service from Twitter. This allows us to approach our website users with targeted ads. To do this, Twitter uses a code snippet (tag) that we have integrated into our website. During this process, no personal data will be collected. Tailored Audiences is also used to create meaningful target lists. This is also our legitimate interest in processing your data. For more information about the privacy policies of Twitter, see their privacy policy (https://twitter.com/privacy?lang=en). You can customize your privacy settings for custom ads at this link: https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-ads Twitter also supports “Do not Track” (DNT). If you have activated this option in your browser, Twitter will not receive browser-related information (browser cookie ID) from web partners with which it can tailor ads for you. Mobile Tracking Technologies In our mobile apps we use so-called mobile tracking technologies. We use these services to collect data about the use of our apps so we can constantly improve our offerings. When using our apps, the data you submit will be collected and analyzed. In this regard, the following data is compiled: IP address that is immediately anonymized, MAC address, anonymized device ID (identifier for advertisers – IDFA or Google Advertiser ID – GAID), browser type, language settings, ISP, network status, time zone , URL of entry and exit pages, date of access and time, clickstream data and other statistical information about the use of our services. A direct individual identification based on this data is not possible. The data collected in this way is used to create anonymous user profiles. The data collected by the tracking technologies will not be used to personally identify a visitor to our web pages without his express consent. The capture and storage of the data can be disabled at any time with future effect by adjusting your mobile device’s settings as follows: If it’s an Apple mobile device (IFDA): Open your mobile device settings (such as iPhone or iPad) and select the “Privacy” menu item. Under “Advertising,” you can turn off ad tracking. For Android devices: Open the settings in your app list and tap the “Show” button. If the ad window is open, you can disable the Google Advertising ID. You can also reset your IFDA or Google Ad ID or assign a new one in the settings. Your Legal Rights You can revoke a given consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation. You can also request information from us at any time as to which Personal Data we process from you (Right of Access, Art. 15 GDPR). Insofar as the data concerning you is incorrect or incomplete, you have a Right of Rectification (Art. 16 GDPR). In certain cases, you have the right to request a restriction of processing. Details can be found in Art. 18 para. 1 DSGVO. You can demand that the Personal Data concerning you shall be deleted immediately (Right to Erasure, Art. 17 GDPR). In particular, we are required to immediately erase this information if the data is no longer necessary for the purposes for which it was collected or if you revoke your consent. Further deletion obligations can be found in Art. 17 para. 1 DSGVO. Please note, however, that statutory provisions provide for a retention period and we are allowed to store data for the settlement of disputes, for the enforcement of our Terms of Use and due to technical and legal reasons (e.g. backup files). This data may only be deleted after periods of time specified by law. If you have the right to rectify, delete or restrict the processing by us, we are obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort (Notification Obligation, Art. 19 GDPR). You also have the right at any time, for reasons arising from your particular situation, to prevent and object the processing of your Personal Data, pursuant to Art. 6 para. 1 lit. e or f DSGVO. You also have the right to receive personally identifiable information you provide to us in a structured, common and machine-readable format. You also have the right to transfer this data to another person without hindrance (Right to Data Portability, Art. 20 GDPR). Without prejudice to any other administrative or judicial remedy, you have the right to file a complain to a supervisory authority, in particular in the Member State of residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is violates the GDPR. Please direct your data protection request to the data protection officer of Koch Media. B. Non-personal information collected by Koch Media Non-personal data cannot be used to identify or contact you. Koch Media collects non-personal data about your use of our online, off-line and mobile games and services both on our website and in the course of game play and software usage (on PC, mobile and console platforms). Koch Media may collect certain non-personal data including gender, zip code, information about your computer, hardware, software, such as your hardware settings and components, platform, media, browser information, including your browser type and the language you prefer, referring and exit pages, including landing pages and pages viewed and used devices including device event information, including crash reports, request and referral URL’s and system activity details (e.g. whether you encountered an error playing our games or lost internet access). We also collect other Non-personal data such as feature usage, game play statistics and scores, user rankings and click paths as well as other data that you may provide in surveys, via your account preferences and online profiles or through purchases, for instance. We may also receive either non-personal or public information from third parties in connection with market and demographic studies that we use to supplement personal data provided directly by you. We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches. In addition to personal information, Koch Media collects, among other things, non-personal information when you actively enter it into various online, offline or mobile activities, including online and mobile purchases, game registration and marketing surveys. 2. Security of data We commit ourselves to data security within the framework of the applicable data protection laws. Your Personal Data is protected against unauthorized access and loss through the use of various electronic, technical, physical, administrative and contractual measures. Koch Media has taken the necessary technical and organizational precautions to ensure that the privacy policy is adhered to both internally and by external service providers. We adhere to generally accepted industry standards to protect the personal information we provide in both transmission and storage. All Koch Media employees are required to comply with data security and privacy practices, and have appropriate instructions and are trained on a regular basis. For payment transactions, your data is encrypted using the SSL process. Our employees are not authorized to request further user data such as bank details or passwords. Persons requiring access for technical, business, or editorial maintenance of the server and portal are legally bound by a confidentiality and non-disclosure agreement Please note, however, that no electronic communication or electronic storage method is completely secure. We remind you that despite our high standards, information that you voluntarily provide on the Web is never guaranteed to be 100% secure. There is always the danger that third parties will gain unauthorized access. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee absolute security. Koch Media is not responsible or liable for the disclosure of data due to data transmission errors or unauthorized access by third parties. 3. Disclosure of personal data to third parties General Your personal information is shared globally with companies of the Koch Group (to affiliates, affiliates and the parent company). Due to the corporate structure, all companies of the Koch Group have a legitimate interest in the transfer pursuant to Art. 6 para. 1 lit. f DSGVO. From time to time, Koch Media employs third party contractors to collect personal data on our behalf to provide email delivery, product, or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. Koch Media will only pass your personal and/or billing-related data to third parties, external service providers and investigative authorities as far as this is required to fulfil the agreement. We ask some third party contractors, such as credit agencies or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors’ needs and preferences. When our third party contractors collect and/or have access to the personal information you provide to Koch Media, Koch Media requires that they adhere to our stated privacy policies and protect the confidentiality of personal information they collect or have access to in the course of their engagement. These third parties are prohibited from using your personal data for any other purpose without your specific consent. Therefore, you may opt in to allow us to share your Personal Data with these companies and organizations that provide products or services that we believe may be of interest to you. To opt out of further communications from a marketing partner or sponsor with whom your information has been shared, please contact that partner or sponsor directly. In any case, you will be notified before your personal data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your data with that party. Payment processing takes place via external service providers (e.g. credit card companies, banks, Paypal). Your protected interests are considered according to the legal provisions. External service providers are obliged to treat your data confidentially and securely and may only use your data as far as this is required to fulfil their duties. In the event of payment arrears, Koch Media will, if necessary, instruct a collection company or a lawyer to collect the payable amount. The required data are passed for this purpose and utilized in compliance with our Privacy Policy. In other cases, your personal information will only be disclosed to third parties with your express consent. However, we may share non-personally identifiable information (in a form that you do not personally identify) with third parties. When Personal Data is transferred to agents / service providers under the terms of the contract, they are bound by applicable privacy laws and other legal regulations, as well as the Privacy Policy of Koch Media. Koch Media may also disclose Personal Data to law enforcement agencies or the relevant civil authorities to enforce legal rights and to comply with the law, or to comply with a decision by a government agency or other competent authority, or if we have reason to believe that disclosure is required to respond to potential or actual violations or interference with our rights, property, reputation, business operations, users or others who may be harmed, or if we believe disclosures are required to protect our rights or us against fraud, or to comply with any Koch Media lawsuit, court order or legal process served. Data transmission to a country outside the European Economic Area (EEA) Koch Media is part of a global organization, and the computer systems on which we collect, store and use information are predominantly in the EEA. In certain circumstances, we may use data storage facilities outside the EEA (for example, in the US or Asia). Your personal data will only be transferred to third countries if this is absolutely necessary for the fulfillment of the purpose of the contract or if you have explicitly consented to the transmission. When submitting your data to a third country, we comply in particular with Articles 44 – 49 GDPR. More information can be found under the item Your Legal Rights. 4. Revocation / Deletion of your data You have the right to correct or deleted data that you have entrusted with us at any time. Please send an e-mail to l.zhang@kochmedia.com to our data protection officer for requesting the deletion or correction of your account details. You can also make your inquiries by phone or post. We will gladly review, update or remove the information. We remind you that it is required to keep certain data for certain periods in order to settle disputes, enforce our User Agreement and technical and regulatory requirements. This data may only be deleted after periods of time specified by law. Further information can be found under the point Your Legal Rights. 5. Non-liability for third parties We remind you that in various technical areas we work with external partners who also offer websites and services accessible from our sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave the Koch Media site and go to the site you selected. As we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as Koch Media. These third party websites and services should have their own privacy policies. We assume no responsibility or liability for such declarations or activities that take place at other sites. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website you should consult that site’s privacy policy before providing any personal information. 6. Children Protecting the privacy of children is particularly important to us. Koch Media understands that parents, guardians or other adults often use our family services, including for use by minors. If a child under the age of 16 (or below the minimum age in the Member State concerned, which can be lower) submits Personal Data to Koch Media and we learn that such Personal Data contains information of a child below 16 (or below the minimum age in the area, which could be lower) and there is no effective consent, we will delete the data as soon as possible. It is our policy to comply with any applicable law protecting minors. The consent of children under the age of 16 is only lawful if the parents have given their consent. Each member state of the EU can reduce the age to a maximum of 13. Koch Media, taking into account the available technology, makes efforts to make sure that the parents have given their consent to children. Nevertheless, we would like to make parents aware that age verifications can be technically bypassed. Please do not leave your children unattended on the Internet and explain their importance to the proper handling of their data. 7. Modification of the Privacy Policy Koch Media reserve the right to modify and update this Privacy Policy at any time in accordance with applicable privacy laws. If we change our Privacy Policy, we will post those changes to this Privacy Policy, the website or other places so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material or significant changes to this Privacy Policy, we will notify you by email or by a notice on the applicable websites or during log in. Please visit this page frequently. Revisions to terms affecting existing Koch Media services shall be effective thirty (30) days after posting. Your continued use of our websites, games, online and mobile products and services will signify your acceptance of the changes to our Privacy Policy. 8. Third Party Products and/or Services Users may register for other services from our websites. Certain products and/or services available on our service are provided to you in partnership with third party(s) and may require you to disclose personally identifiable information in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you choose to register for such products and/or services your personally identifiable information will be transferred to such third parties and will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy practices and policies of such third parties and, therefore, you should review the privacy practices and policies of such third parties prior to providing your personally identifiable information in connection with such products and/or services. 9. Questions and comments If you have any questions, concerns or remarks about data privacy, please contact our data protection officer Mr. Liang Zhang by email to l.zhang@kochmedia.com. We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. Cookies are small text files that can be used by websites to make a user's experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission. This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. 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