Privacy Policy

 Last updated May 18, 2023

 

Hoby Labs SRL, 69 Pictor Brana, Selimbar, Sibiu, Romania, apps@hobbylabs.ro ("Hoby Labs" or "we") respects and protects your personal data. 

The following Privacy Policy is intended to provide you with more detailed information about the collection, processing and use of data in connection with our games offered as mobile applications ("the Games Apps").

Hoby Labs collects, processes and uses personal data exclusively in accordance with the applicable legal regulations. Therefore, the high data protection level of the General Data Protection Regulation ("GDPR") applies.

1. SCOPE OF APPLICATION

1.1 This Privacy Policy is intended for all users of the Games Apps ("Users"). If certain services or individual apps of Hoby Labs have a different data protection declaration, such declaration shall apply.

1.2 The scope of this Privacy Policy does not include services and offers of third parties that may be referred to in the Games App by so-called links. Hoby Labs neither assumes responsibility for their content nor for compliance with data protection regulations by these third parties, unless otherwise stated in the privacy policy of the linked content. This applies, for example, to links via which social networks such as Facebook or chat apps such as WhatsApp can be accessed, and to links in advertisements that are played. For information on the handling of the User's personal data and their respective protection on these platforms, please refer to the privacy statement on the respective platform.

2. DOWNLOADING AND INSTALLING THE GAMES APPS

When you download and install our Games Apps, the operator of the platform through which you obtain the respective app (for example Apple, Inc. for the AppStore and Google Ireland Limited for the Google PlayStore) collects personal data required for the download. These data include in particular your name, your e-mail address and your postal code, time of download, the IP address and the individual device identification number of your device (so-called IMEI), as well as your payment information, if applicable. This collection and processing of your personal data is, however, basically carried out solely by the respective platform operator without our participation in the data processing or our ability to influence it. In this respect, the data protection provisions of the platform operator apply, which can be viewed on the platform in question. We only receive and process personal data collected by the platform operator to the extent necessary for the download and provision of the Games App. If we process personal data as part of the installation, this is done on the basis of the contract on the subscription and use of the Games App that you concluded with us when downloading and installing the app, in accordance with Article 6 (1) sentence 1 lit. b) GDPR.

3. COLLECTION, PROCESSING AND USE OF DATA WHEN USING THE GAMES APPS

3.1 When you start and use Hoby Labs's Games Apps, depending on the Games App, a connection may be automatically established to the servers used by us in order to retrieve current content. Information that your device transmits to us is logged in the process. This includes the IP address of the device you are using, data on the operating system used as well as the installed Games App and its version, date and time (including time zone) of the respective access to the contents of the Games App as well as the information on which specific contents have been requested for the respective Games App. In addition, Hoby Labs may collect and process personal data in order to fulfill its contractual obligations with the User, e.g. to create the User's player profile. Depending on the respective Games App, this data includes name and IP address and data identifying the User's device.

3.2 Hoby Labs collects and processes these data in order to provide the Games App and the respective current content of the Games App. The provision of this data is not required by law, but is necessary for the conclusion of the user contract for the respective Games App and the associated service by Hoby Labs. The User may voluntarily provide Hoby Labs with further data with respect to the offer. The basis of this data processing for the fulfillment of contractual obligations is Article 6 (1) sentence 1 lit. b) GDPR.

4. IN-APP PAYMENTS

4.1 In some Games Apps, we may offer certain additional versions and content for purchase, e.g. the use of an ad-free version of the app. In order to conclude the corresponding contract and the associated payment processing, it is necessary to enter bank details or other payment-related data (e.g. credit card). We make use of RevenueCat to manage the in-app purchase functionality. If you make an in-app purchase, RevenueCat will receive a receipt containing information about that purchase. RevenueCat does not receive or process your payment information, such as a credit card number. For payment processing, we use the services provided by the respective operator of the platform through which you have obtained the Games App (for example, Apple, Inc. for the AppStore and Google Ireland Limited for the Google PlayStore). The aforementioned information will be processed accordingly together with the necessary usage data by the operator of the respective platform, insofar as this is necessary to process the payment. Details on the handling of your personal data in connection with the payment processing can be found in the privacy statement of the respective platform operator which can be viewed on the corresponding platform.

4.2 The use of these payment services is mandatorily required by the platform operator in order for us to be allowed to offer the app on the respective platform and also serves to provide you with an easy and smooth payment process in the app.

4.3 This data processing in connection with the purchase of additional content in the respective Games App, including payment processing, is carried out for the conclusion and processing of the contract regarding this content and thus on the basis of Article 6 (1) sentence 1 lit. b) GDPR.

4.4 You may wish to review Google’s Privacy Policy and RevenueCat’s Privacy Policy.

5. SUPPORT REQUESTS AND CONTACT VIA THE GAMES APP

5.1 If you notify our customer support or otherwise contact us (e.g. with a contact form in the Games App), the information you provide in the contact, including the contact details given there, will be processed for the purpose of handling your enquiry and processing it, including investigating and rectifying any problems in the Games App and in the event of follow-up questions. In the event of a request to our customer support via the Games App, information on the Games App, your game progress, Player-ID and, if applicable, the problematic part of the game as well as technical data on your device will also be processed automatically.

5.2 We process this data in accordance with Article 6 (1) sentence 1 lit. b) GDPR, as far as you contact us within the framework of an existing contract for the use of the Games App or for the purpose of initiating such a contractual relationship. Otherwise, the storage and use of the data takes place on the basis of Article 6 (1) sentence 1 lit. f) GDPR, whereby our legitimate interest is the careful processing of your respective request and the solution of any technical problems.

6. ERROR REPORTING AND USAGE ANALYSIS VIA FIREBASE

6.1 The Games App implements functions of the Firebase service which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

6.2 Data on the general use of the app are collected and evaluated via the Firebase service (so-called Google Analytics for Firebase). At the same time, reports on errors and crashes that occur in the app are generated to analyze and resolve these errors and crashes. For these purposes, information on whether and how you use certain parts of the Games App is collected together with the IP address and other technical data on your device and the configurations assigned to it (hereinafter "Device-Related Data"), such as the manufacturer and model of the device, the language setting and the advertising ID as well as the country from which you use the app. In order to generate error reports, details about the error that occurred, information about the affected Games App and, if necessary, game-relevant data will be collected and processed additionally, but only if such an error occurs while you are using the app. Google evaluates such data on our behalf and compiles aggregated reports for us. We use these reports to gain insight into the general use of the Games App as well as into the errors that have occurred, in order to use this information to improve the content and functions of the app and, in particular, to eliminate existing errors and problems. In addition to this we also get access to the in-game activity of individual users through Google, based on an anonymized user-id. Nevertheless it is not relevant for Hoby Labs which User used the respective app and to what extent. It is therefore not a matter of creating user profiles for Hoby Labs but rather of providing functional Games Apps through the analysis of aggregated reports from Google. Google may also transfer these data to servers operated by Google LLC in the USA and analyze them there. However, in member states of the European Union or in other states that are party to the Agreement on the European Economic Area your IP address will be shortened and thus made anonymous before it is transmitted to a Google server in the USA.

6.3 Google also processes the aforementioned data collected via the Firebase service to the extent covered by its own privacy policy which you can find at https://policies.google.com/privacy. There you will also find additional information on Google's handling of personal data.

6.4 We would like to point out that the transmission of data to servers in the USA used by Google LLC may involve additional risks, for instance the enforcement of your rights to these data may be more difficult. In order to counter these risks, we have concluded the standard data protection clauses by the EU Commission with Google LLC for this data transfer and also stipulated appropriate protective measures therein, which, depending on the need for protection of the data, also include data encryption and can be improved in accordance with the legal and technical conditions for appropriate protection of the data. If data is transferred to Google LLC in the USA, such transfer is based on Article 46 (2) lit. c) GDPR.

6.5 We only use Firebase for the data analyzing purposes described above, if you consent to it. In these cases, the legal basis for the processing of your data is Article 6 (1) sentence 1 lit. a) GDPR. You may revoke an already granted consent for data processing at any time with effect for the future. We have further concluded a data processing agreement with Google in accordance with Article 28 GDPR on data processing in the context of error analysis. Accordingly, Google will only process the data collected in this context in accordance with our instructions for this purpose. This forwarding of data to Google is therefore based on Article 28 GDPR.

7. PARTNER SERVICES FOR ADVERTISING IN THE GAMES APPS

We integrate services of advertising networks in the Games Apps with which we cooperate in order to be able to display third-party advertising to you while you are using the Games Apps.

In this context we use services of different advertising networks, whereby the personal data concerning you may be sent to several of the integrated advertising networks. By integrating different advertising networks, we ensure that only advertisements are displayed that are approved and specifically available by the advertiser for the respective country from which you have installed and use the relevant Games App. We generally make our Games Apps available worldwide which is why the advertisements shown in them are subject to different legal requirements depending on the User's country. The advertisement networks each work with different advertisers who may target their ads to only certain countries and adapt them solely to the legal requirements applicable there. In addition, advertisers have also set certain restrictions, such as a general maximum number of advertisements to be displayed per user or certain media in which the advertisements are to be displayed. However, we can only view individual advertisers and advertising campaigns relevant to our Game Apps in very limited cases in advance and therefore cannot evaluate them more precisely. To ensure that we are nevertheless always able to display advertising that has been approved by the advertiser for the User's region and may be specifically played, we use different advertising networks. Since we can only provide the free Games Apps by financing it through advertising, we have a legitimate interest in generally displaying advertising to the individual User in our Games Apps in order to generate revenue and to be able to continue to offer the apps free of charge, if possible worldwide.

However, personalisation of displayed advertising is only activated to the extent permitted by law. In particular, we only use data of a User who resides in the EU to display personalized advertising to this User if the respective User has consented to this in advance. In these cases, the legal basis for the processing of your data in connection with personalized advertising is your consent pursuant to Article 6 (1) sentence 1 lit. a) GDPR. You may, of course, revoke an already granted consent for data processing for personalized advertising at any time with effect for the future. Please note that we also display advertising to finance the free Games Apps if you have not consented to personalized advertising or have revoked such consent. In that case the advertising displayed will not be personalized, i.e. not adapted to your personal interests and usage habits. Only general information will be taken into account, for example the respective Games App and the country from which the app was installed and launched. More details on the display of these non-personalised advertisements and their legal basis are explained below for the individual advertising services.

For some games we may also offer you the option of purchasing a paid, ad-free version. In ad-free versions, of course, no advertising services are implemented and accordingly no data processing takes place for the purpose of displaying advertising in the app.

7.1 Google AdMob

7.1.1 The advertising network AdMob which is operated by Google is also used in our Games Apps to integrate third-party advertising. In this context, Google receives information about the respective Game App (name, category and language of the Game App), Device-Related Data of your device as well as the IP address of your device, which is, however, shortened and only used in an abbreviated form, and information about some of your interactions in the app. The aforementioned data may also be transmitted to Google LLC servers in the USA for the AdMob service. Google processes this data in order to select specific advertisements without giving us the opportunity to exert any further influence, and to limit the display of an advertisement, especially in the case of multiple displays to a specific User. We have no insight into the selection of specific advertisements and the related data processing, nor do we have any more precise setting options to be able to influence this. Google uses the collected data in accordance with Google's privacy policy.

7.1.2 Google also records whether and if so, how you interact with the advertisement, the IP address and individual Device-Related Data of your device as well as, if applicable, your further usage behavior following a click on the advertisement, in order to evaluate the success of the respective advertisement together with the aforementioned data and to properly invoice us and the advertiser accordingly. Based on their evaluations, Google also creates aggregated reports for us on the scope and results of the advertising. However, this only gives us access to aggregated data on the results of the advertising which Hoby Labs cannot trace back to individual persons.

7.1.3 Further details on the processing of data by Google can be found in Google's privacy policy (https://policies.google.com/privacy) and in the information on the use of data from integrated Google services (https://policies.google.com/technologies/partner-sites?hl=de).

7.1.4 The basis for data processing as part of the AdMob service is our legitimate interest pursuant to Article 6 (1) sentence 1 lit. f) GDPR. It is our legitimate interest to play advertising to Users in order to finance the creation and further development of the free Games Apps. Financing through advertising allows us to generally offer the Games Apps worldwide. It is also in our legitimate interest to use the AdMob network which is specifically tailored to advertising for apps, to display advertising that fits as coherently as possible into the format of the Games Apps and is not perceived by Users as annoying or inappropriate. As the Games Apps are available free of charge and are solely for your entertainment purposes, it is not apparent that your interests are overriding in this respect. For certain Games Apps we also offer you the option to use a paid, ad-free version of the Game Apps.

7.1.5 The transfer to servers of Google LLC in the USA is based on Article 46 (2) lit. c) GDPR. For this transfer we have agreed the standard data protection clauses of the EU Commission with Google LLC. Together with these clauses, we and Google LLC have also defined and implemented appropriate protection measures that take into account the need for protection of the data in each specific case and include encryption of the data. These measures are also continuously adapted in accordance with the legal and technical conditions for effective protection of the data in order to provide continuous assurance of an adequate level of protection.

8. APPLE SIGN-IN

8.1 In some Games Apps that require you to register with a player profile, you may also create your player profile by signing in to your Apple services profile (called an Apple ID account) if you express your consent to do so by clicking on the appropriate Apple connection button. The function required for this ("Apple Sign in") is provided by Apple Distribution International Ltd Hollyhill Industrial Estate, Hollyhill, Cork, Ireland ("Apple"). The necessary feature (called "Apple Sign In") is provided by Apple Distribution International Ltd. Hollyhill Industrial Estate, Hollyhill, Cork, Ireland ("Apple"). We do not have access to the login details of your Apple profile. After verification of your login data, we will only be informed about the following data from your Apple profile: the registered name, your Apple ID, your language setting, and the country from where you are playing.

8.2 Data processing for Apple Sign in is legally based on your consent (Article 6 (1) sentence 1 lit. a) GDPR) which you give when calling up Apple Sign in and subsequently entering your login data to your Apple ID account. You may revoke your consent at any time with effect for the future.

8.3 By using Apple Sign in, Apple may receive the information that you have created a player profile for the relevant Games App. Information on how Apple handles your personal data can be found in Apple's privacy statement at: www.apple.com/de/privacy

8.4 In the event that the Apple Sign in feature transfers personal data concerning you to Apple, Inc. in the USA, Apple has ensured prior to the transfer that this transfer is covered by the EU Commission's standard data protection clauses pursuant to Article 46 (2) (c) of the GDPR. Apple and we also take additional technical security measures to protect your data, including appropriate encryption, pseudonymisation and reducing data processing as far as possible

 

9. GOOGLE SIGN-IN

9.1 In some Games Apps that require you to register with a player profile, you may also create your player profile with the help of your Google account, if you express your consent to do so by clicking on the appropriate Google connection button. The function required for this ("Google Sign-In") is provided by Google LLC, with offices at 1600 Amphitheatre Parkway, Mountain View, California 94043, United States, ("Google LLC"). We do not have access to the login details of your Google profile. After verification of your login data by Google LLC, we will only be informed about the following data from your Google profile: the registered name, your registered email address and your Google ID.

9.2 Data processing for Google Sign-In is legally based on your consent (Article 6 (1) sentence 1 lit. a) GDPR) which you give when calling up Google Sign-In and subsequently entering your login data to your Google account. You may revoke your consent at any time with effect for the future.

9.3 Further details on the processing of data by Google LLC can be found in Google's privacy policy (https://policies.google.com/privacy) and in the information on the use of data from integrated Google services (https://policies.google.com/technologies/partner-sites?hl=de).

9.4 The transfer to servers of Google LLC in the USA is based on Article 46 (2) lit. c) GDPR. For this transfer we have agreed on the standard data protection clauses of the EU Commission with Google LLC. Together with these clauses, we and Google LLC have also defined and implemented appropriate protection measures that take into account the need for protection of the data in each specific case and include encryption of the data. These measures are also continuously adapted in accordance with the legal and technical conditions for effective protection of the data in order to provide continuous assurance of an adequate level of protection.

10. FACEBOOK LOGIN

10.1 In some Games Apps, you will need to create a player profile and provide some information (such as the player name you choose) according to the registration form. In some Games Apps, we also offer you the option of creating a player profile by entering the login data of your Facebook user account (so-called "Facebook Login", formerly known as "Facebook Connect"), if you express your consent to this by clicking on the corresponding button to connect to Facebook ("Log in with Facebook"). The Facebook Login function is offered by Facebook. The login data of your Facebook account will be sent directly to Facebook. We do not have access to your login data. After verification of your login data, Facebook only informs us about the following data from your Facebook user account: the registered name, your profile picture, your language setting, and the country from where you are playing. Facebook further checks which other Facebook users with whom you are connected on Facebook (so-called "friends") have already played the respective Games App and provides us with this information. Hoby Labs receives and uses the aforementioned data to set up your player profile in the Games App. We also use the information about your friends on Facebook to enable you to invite a Facebook friend to a joint game session and to easily start this game session. However, we only process this information to the extent necessary for a joint gaming session.

10.2 By using the Facebook Login function, Facebook receives the information that you have created a player profile for the relevant Games App and can link this information to your Facebook user account. Information on how Facebook handles your personal data can be found in Facebook's privacy statement at: https://www.facebook.com/privacy/explanation

10.3 Data processing with the Facebook Login function is legally based on your consent (Article 6 (1) p. 1 lit. a) GDPR) which you give when calling up Facebook Login and subsequently entering your login data to your Facebook account. You can revoke your consent to data processing when using Facebook Login at any time with effect for the future.

10.4 The transfer of your personal data to Facebook in this context is based on Article 46 (2) lit. c) GDPR. In this respect, above statements of section 9.5 apply accordingly.

11. INVITING PLAYERS USING LINKS

11.1 In certain Games Apps, you may also be able to create an invitation to a shared gaming session with a direct link to the specific gaming session in order to send this invitation to a contact via a messenger app or by other means (e.g. e-mail). When the invitation to a game is created, a specific link is generated in the Games App that leads directly to the gaming session in the Games App.

11.2 To generate the direct link to the gaming session and to match the relevant Users in the same gaming session, we use the Firebase Dynamic Links service provided by Google. When the recipient clicks on an accordingly generated link to a gaming session, Google collects the recipient's IP address as well as information about the respective Games App and Device-Related Data about the used device. Google uses these data on our behalf to direct the recipient to the correct game in the Games App. For this purpose, the App must determine whether it was your contact who has clicked on the link and for which gaming session you have invited the recipient.

11.3 The data processing in connection with the direct link to the gaming session is carried out for the purpose of giving players an easy and direct way to start a gaming session with others and is therefore legally based on Article 6 (1) sentence 1 lit. f) GDPR. Our legitimate interest is to make it as easy and convenient as possible for our Users to start a game together and thus to provide Users with a special gaming experience. This is also in the interest of our Users, both the sender and the recipient of invitations to play a game. A possible conflicting interest of a recipient to the effect that their data is not transferred to Google is allowed for by the fact that such a data transfer only takes place if the recipient voluntarily clicks on the sent invitation link and thereby expresses that he or she accepts the game invitation. From this point on, it can no longer be assumed that the recipient has a conflicting interest regarding the processing of his or her personal data through our Games App.

11.4 From the aforementioned data, Google also compiles reports on the use of links to Games Apps which we evaluate. These reports provide us with information about the use of the generated links, the functioning of the link and any subsequent app openings or installations of the relevant Games App. However, we do not receive any information about the user navigation following the click on the link. All these reports only contain aggregated data and do not allow us to draw any conclusions about individual Users; data about individual Users are not visible to us. The data processing described above is necessary to protect our legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR), whereby our legitimate interest is to be able to provide users with the best possible functionalities in our Game Apps in order to offer users an optimal gaming experience. For this purpose, we need insights from the Users' interactions with the provided links and their functionalities.

11.5 Google also processes the aforementioned data collected via the Firebase service to the extent covered by its own privacy policy which you can find at https://policies.google.com/privacy. There you will also find additional information on Google's handling of personal data.

11.6 We would like to point out that the transmission of data to servers in the USA used by Google LLC may involve additional risks, for instance the enforcement of your rights to these data may be more difficult. In order to counter these risks, we have concluded the standard data protection clauses by the EU Commission with Google LLC for this data transfer and also stipulated appropriate protective measures therein, which, depending on the need for protection of the data, also include data encryption and can be improved in accordance with the legal and technical conditions for appropriate protection of the data. If data is transferred to Google LLC in the USA, such transfer is based on Article 46 (2) lit. c) GDPR.

12. ERROR EVALUATION USING GOOGLE CRASHLYTICS

12.1 In order to detect and correct technical errors, we use the “Crashlytics” diagnostics service operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (hereinafter: “Google”). 

12.2 Crashlytics and the error reports generated by the software are used to record and analyse errors. The resultant information is used to maintain and improve our App. Should usage of the App lead to unexpected errors or the App crashing, specific information, such as the device type, operating system version, date and time of the error, country in which the query originated, and language selected for the operating system, will be sent to Crashlytics. You can find more information about data protection at Crashlytics here: fabric.io/terms.

12.3 Processing is necessary to safeguard the prevailing, legitimate interests of the data controller (Art. 6, para 1 (f) GDPR). We have a legitimate interest in offering our customers a flawless product and in making its use as simple and secure as possible.

12.4 You can prevent Crashlytics from processing your data at any time by deactivating the recording and transfer of usage information and diagnostics data by Crashlytics in the settings of the App. This option is deactivated in the App’s default delivery state.

12.5 Personal data is transmitted to Google through the use of Crashlytics. Google acts as a service provider for us within the context of commissioned processing. Google processes personal data in the US as well, and has signed up to the EU-US Privacy Shield Framework. You can find more information on the EU-US Privacy Shield Framework at www.privacyshield.gov/EU-US-Framework.

13. STORAGE, STORAGE PERIOD AND DELETION OF DATA

13.1 We will process your personal data for as long as is necessary to achieve the purposes of the processing, is required by law to retain the data or is necessary for other reasons. Subsequently, the data will be deleted in accordance with the statutory provisions.

13.2 However, we retain data that we store for legal reasons for as long as this is legally required. After expiry of a statutory retention period, the data are deleted immediately, unless there are other reasons preventing deletion in terms of Article 17 (3) GDPR.

14. DATA SECURITY

Hoby Labs has taken appropriate technical and organizational measures to protect personal data against accidental loss, damage, unauthorized access and unauthorized alteration. In particular, Hoby Labs's data are only transferred in encrypted form. Hoby Labs however clarifies that data protection and data security cannot be guaranteed for transfers outside Hoby Labs's sphere of influence.

15. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

15.1 Personal data will only be transferred to third parties without the User's explicit consent if this is necessary for the provision of Hoby Labs's services (e.g. for the technical provision of the offer), unless stated otherwise at another point in this Privacy Policy. Accordingly, a transfer of data to such service providers (such as technical service providers) takes place in order to protect our legitimate interests pursuant to Article 6 (1) sentence 1 lit. f) GDPR, namely in order to be able to provide our Games Apps for retrieval at all. Of course, Hoby Labs will ensure that the respective service provider has taken appropriate technical and organizational measures to guarantee the security of the data before forwarding the User's personal data.

15.2 We store the data which we collect when the Games Apps are used with the help of third-party services. We use the Google Cloud and Google Firebase services, both of which are provided by Google. These services may also collect and possibly store the IP address of your device when you use the Games Apps, but for a maximum of 30 days. However, Hoby Labs does not receive the IP addresses directly and only views IP addresses collected by these services in exceptional cases and only if a legal basis exists, in particular insofar as this is necessary to protect Hoby Labs's legitimate interests (e.g. during maintenance work or in the event of the investigation of technical problems). Google also transfers the collected data to their servers in the USA. We use these services to provide the aforementioned data for playing the Games App efficiently and with the lowest possible error rate to thereby ensure a smooth use of the game features. The legal basis for the associated data processing is Article 6 (1) sentence 1 lit. f) GDPR, whereby our legitimate interest is an optimal, technically sound provision of the Games App. As we have already explained several times above, we have concluded the standard data protection clauses adopted by the EU Commission with Google to safeguard the transfer of data to the USA. We have also concluded a data processing agreement with Google. The forwarding of personal data to Google in connection with the aforementioned services is therefore based on Article 46 (2) lit. c) and 28 GDPR.

15.3 Otherwise Hoby Labs will not pass on the User's personal data to third parties, unless the User has expressly consented to the transfer (Article 6 (1) sentence 1 lit. a) GDPR) and Hoby Labs is neither entitled nor obliged to transfer the data due to legal regulations or court orders. In the latter case, Hoby Labs will transfer the data in order to fulfill a legal obligation according to Article 6 (1) sentence 1 lit. c) GDPR.

16. USER RIGHTS

16.1 Right to Object

The User has the right to object at any time, for reasons arising from the User's particular situation, to data processing based on Article 6 (1) sentence 1 lit. f) GDPR, unless Hoby Labs can prove compelling reasons worthy of protection outweighing the User's interests, or the processing serves to assert, exercise or defend legal claims. The User may object to data processing for the purpose of direct marketing at any time without having to furnish special reasons for doing so.

16.2 Right to Information

The User has the right to obtain from Hoby Labs information on personal data concerning the User stored at Hoby Labs, on purposes of the processing, where such data come from, what kind of disclosure has been carried out, recipients or categories of recipients to whom personal data have been disclosed, storage period, and on the data subject's rights, free of charge, in writing or electronic form.

16.3 Right to Rectification, Erasure and/or Restriction of Data Processing

The User also has the right to demand at any time the rectification of inaccurate data, the deletion and/or, under the legal conditions, the restriction of the processing of the personal data stored about this User. The right to erasure exists only to the extent that Hoby Labs is not legally required to retain the data and that there are no other reasons in terms of Article 17 (3) GDPR that prevent the erasure. Insofar as this includes personal data that are necessary for the provision of services to the User, the erasure or restriction of the processing of such data may only be carried out once the User no longer uses Hoby Labs's offer.

16.4 Right to Data Portability

Moreover, in case the User has provided personal data concerning the User, and Hoby Labs has processed these data due to the User's consent or for the purposes of performance of contract, the User has the right to request to be provided with these data from Hoby Labs in a structured, commonly used and machine-readable format, as well as the right to have this information transmitted by Hoby Labs to another data controller, where it is technically feasible (so-called right to data portability).

16.5 Right to Withdraw a Consent

All consents to the use of personal data declared by the User can be freely revoked by the User at any time with effect for the future.

16.6 Right to Lodge a Complaint with a Supervisory Authority

The User may also lodge a complaint with a supervisory authority against a data processing which in the User's opinion violates the statutory provisions.

17. CHANGES TO THIS PRIVACY POLICY

Hoby Labs reserves the right to change this Privacy Policy at any time, and Hoby Labs will always comply with the legal requirements of data protection. Therefore, Hoby Labs recommends that Users regularly take note of the most up-to-date Privacy Policy. Hoby Labs will inform Users in advance on further use of data, for example by messages in this respect, in the Games App or by so-called push notifications, insofar as you have allowed such push notifications.



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