Welcome to FRITZI – A revolutionary Tale, which you may be accessing through one of our websites (“Websites”) or one of our mobile software applications (“Apps”) (the Websites and Apps will sometimes be collectively referred to as the “Platform”). The Platform is operated by TrickStudio Lutterbeck GmbH (“we,” “us,” or “our”). We believe that the privacy and security of your information and data (“Information”) is very important. This Privacy Policy (“Policy”) explains the type of Information we collect from users of the Platform, how that Information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully.
Any updates or modifications to this Policy will be posted to our website on this page. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy. This Policy is effective as of July 19, 2018 and has not been modified since that date.
Our Platform is operated out of Germany but can be accessed worldwide. Residents of the European Economic Area (“EEA”), which includes the member states of the European Union, should consult the sections of this policy relating to the
“Rights of EEA Residents” (under the
“Your Rights” section below) and
“International Data Transfers” for provisions that may apply to them.
INFORMATION WE COLLECT AND HOW WE USE IT
Types of Information
We may collect the following types of Information through our Platform:
(1) “Personal Data” such as your name, e-mail address and phone number and other information that can be used to directly identify you (which, in some cases, may include certain Device Information);
(2) “Device Information” which is information relating to the computer or device you are using when you access our Platform, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.
(3) “Usage Data” which is data related to your use of the Platform such as the pages you visit, the sites you use before or after visiting ours, your actions within the Platform, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, WiFi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Platform through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).
Personal Data
You may enter the Websites and browse their content without submitting any Personal Data. However, we will need to collect relevant Personal Data to provide you with certain services offered by the Platform, including if you choose to contact us or otherwise communicate with us in any way, subscribe or opt in to our newsletter, alerts, or other communications, or participate in a contest or promotion.
We use the Personal Data that we collect to respond to your requests, communicate with you regarding the Platform and our content, send you promotional e-mails, guard against potential fraud, and provide you with the applicable services, features or functionality associated with your submission. When you submit Personal Data through the Platform, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving your consent to the collection, use and disclosure of your Personal Data as set forth in this Privacy Policy.
Device Information & Usage Data
Whether or not you submit Personal Data, any time you visit our Platform, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and also in aggregate form for internal business purposes, such as optimizing the Platform, evaluating the popularity of content, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.
Information to and from Social Networks
We may provide functionality that will allow you to connect to our Platform through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”). If you connect through a Social Network, we may collect Personal Data from your profile, such as your name, username, and e-mail address, and we will use that Personal Data for the purposes set forth herein. In addition, our Platform may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.
SHARING OF INFORMATION
In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes. We only share your Information with third parties for the purposes described below.
We contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including content streaming, email and hosting services, software development, data management, management of quizzes and polls, marketing, and administration of contests and other promotions. We call them our “Service Providers.” We may share your Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Information only for such purposes.
We may also share or transfer Device Information and Usage Data in aggregated, anonymized form with or to our affiliates, licensees, partners and Service Providers for administrative, analytical, research, optimization, and security purposes, but no such Information will be linked with your Personal Data or be used to identify or contact you.
Finally, we may share your Information: (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements; or (iii) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Notwithstanding any of the above, we will not share your Personal Data if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018.
AUTOMATED DATA COLLECTION / COOKIES
We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Platform and customizing the content offered to you on the Platform. Such technologies include:
(1) Cookies. Cookies are text files placed in your computer’s browser to store your preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the Platform and the content, offerings, or advertisements you see on the Platform. For example, we may use cookies to personalize your experience on the Platform or remember any settings you have chosen. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, not accepting cookies may make certain features of the Platform unavailable to you.
(2) Web Beacons. We may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
(3) Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits (“SDKs”) that are incorporated into the Platform to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about your device or use of the Platform. A mobile SDK may act as the mobile version of a web beacon (see “Web Beacons” above).
By visiting the Platform, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Platform through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you. Please note that no such tracking technologies will collect any Personal Data from you unless you choose to submit it to us.
PERSONAL DATA RETENTION
We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Platform or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
PRIVACY AND SECURITY
It is entirely your choice whether or not you provide Personal Data to us. We take reasonable precautions to protect your Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at info@trickstudio.de
LINKS TO THIRD PARTY PLATFORMS
Our Platform or communications may contain links to third party websites over which we exercise no control, including the form of embedded content, sponsored content or co-branded content. Except as set forth in this Policy, we do not share your Personal Data with those third parties and are not responsible for the privacy policies of any third party or their management of your Personal Data. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third party websites prior to submitting any Personal Data to such sites.
YOUR RIGHTS
Opting Out of Communications
As described above, we may use the Personal Data we collect from you to send you newsletters or other communications from us, including those promotional in nature. If you do not want to receive such communications, you can opt out by using the unsubscribe link at the bottom of our communications.
Disallowing Cookies and Location Data Collection
You can opt out of the collection and use of certain information, which we collect about you by automated means, by changing the settings in the device you use to access the Platform. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Platform.
Your Right to Access, Review, and Delete Personal Data
Under certain laws, including the GDPR, you may also have the right to: obtain confirmation that we hold Personal Data about you, request access to and receive information about the Personal Data we maintain about you, receive copies of the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, object to the continued processing of your Personal Data, and have the Personal Data blocked, anonymized or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law. If you qualify, in order to exercise these rights, please contact us as set forth below.
TrickStudio Lutterbeck GmbH
Neusserstr. 476
50733 Köln
Germany
E-mail: info@trickstudio.de
We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
Please understand, however, that we reserve the right to retain an archive of such Personal Data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.
Rights of EEA Residents
This section of the Privacy Policy is applicable to residents of the EEA, which consists of the member states of the European Union. This section also applies to residents of Switzerland and, in the event of its departure from the EU, residents of the United Kingdom. Residents of the EEA, UK and Switzerland are referred to here as “EEA Residents.”
From May 25, 2018, all processing of Personal Data of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Data and on the free movement of such data (“GDPR”).
Under the GDPR, we are both the controller and a co-processor of the Personal Data of EEA Residents. Our purpose for collecting and processing Personal Data from EEA Residents is to provide them with the features and functionalities of our Platform and information regarding our Platform. The legal basis for collecting Personal Data is because it is necessary for performance of a contract between us to provide you with the Platform and its related features and functionality. We also rely on your consent to receive information about our Platform. You may withdraw consent from receiving marketing and promotional communications by clicking the “Unsubscribe” link on the communication or sending an e-mail to info@trickstudio.de with the subject line “Opt Out.” If EEA Residents do not provide Personal Data to us or withdraw consent for processing such Personal Data, we may not be able to provide such residents with certain features or functionalities of the Platform or information regarding the Platform.
EEA Residents may obtain information about the Personal Data that we hold about them by contacting us at info@trickstudio.de.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such policy will be re-posted in the “Privacy” section of our Platform with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy. If you have any questions about the changes that were implemented, please contact us at
info@trickstudio.de and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Platform after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Platform or opt out by sending us an appropriate notice.
YOUR AGREEMENTS
You represent and warrant that any Personal Data you provide us is true and correct and relates to you and not to any other person.
If you use the Platform, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.