1. Responsible Body
Die Tech Recruiter GmbH, Buchenweg 25, 21039 Escheburg (hereinafter "Die Tech Recruiter" or "we") hereby informs you about the processing of personal data for which Die Tech Recruiter is the controller within the meaning of the EU General Data Protection Regulation (GDPR). In addition to the possibility of contacting us by mail, you can contact us at any time via [email protected]. According to Art. 37 GDPR, no data protection officer needs to be appointed for our company.
2. Website Visitors
The following subsections describe data processing activities for visitors of memory-game.net.
2.1 Server Log Data
When you access the website, certain information is sent to our website's server by the browser used on your end device for technical reasons and is processed there. (i) Purpose: Provision of the requested content, ensuring the security of the IT infrastructure, troubleshooting, and management of cookies. (ii) Data: The processed data are HTTP data: HTTP data are protocol data that arise technically when the website is called up via the Hypertext Transfer Protocol (Secure) (HTTP(S)): This includes the IP address, type and version of your internet browser, operating system used, the page called up, the previously visited page (referrer URL), and the date and time of the retrieval. HTTP(S) data also arise on the servers of service providers (e.g., when retrieving third-party content). (iii) Legal Basis: Our legitimate interest in operating an internet presence (Art. 6 para. 1 lit. f GDPR). (iv) Data Provision: The data is provided automatically by the browser. Without this, the use of the website is technically impossible. (v) Recipients: Recipients of the personal data are IT service providers whom we use within the scope of an order processing agreement. We have concluded an order processing agreement with DigitalOcean LLC (101 Avenue of the Americas, New York, NY 10013, USA) and instructed DigitalOcean to use Germany (Data Center Frankfurt/Main) as the server location for data processing. In the event of disruptions and malfunctions, DigitalOcean may also access the servers in Germany from so-called third countries such as the USA to perform maintenance work. To protect your data, DigitalOcean has concluded the EU Standard Contractual Clauses (2021/914; Module 3) with its subsidiaries in third countries and other subcontractors (viewable in DigitalOcean's Data Processing Agreement). Another recipient is the IT service provider Cloudflare Inc. (101 Townsend St., San Francisco, CA 94107, USA): We use Cloudflare as a Content Delivery Network (CDN), for DNS management, and to secure our IT infrastructure against attacks (e.g., DDoS). We have concluded an order processing agreement with Cloudflare Inc. Since Cloudflare operates a globally active network, HTTP data is technically routed via Cloudflare's infrastructure and logged. Cloudflare may also access this data from so-called third countries such as the USA as part of service provision, maintenance, or error diagnosis. To protect your data, Cloudflare has concluded the EU Standard Contractual Clauses (2021/914; Module 3) (viewable in the Self-Serve Subscription Agreement or the Cloudflare DPA). You can request a copy of the essential contractual contents of the Standard Contractual Clauses at any time. Furthermore, the Cloudflare companies (Cloudflare Inc.) are certified according to the EU-US Data Privacy Framework (pursuant to Article 45 GDPR), which can be viewed in the official register of the U.S. Department of Commerce. Further information can be found in Cloudflare's privacy policy at: https://www.cloudflare.com/privacypolicy/. Another IT service provider is STRATO AG (Otto-Ostrowski-Strasse 7, 10249 Berlin): We use the services of STRATO AG as a domain registrar and to provide the DNS infrastructure. We have concluded an order processing agreement with STRATO AG. The processing of data takes place exclusively in data centers within the European Union (Germany). For technical reasons, HTTP data arises on Strato's servers when resolving domain names and accessing our website. Further information on data processing by Strato can be found in STRATO AG's privacy policy at the following link: https://www.strato.de/datenschutz/. (vi) Storage Period: IP addresses of users are collected temporarily to ensure IT security (e.g., to defend against and analyze DDoS attacks), but are anonymized by shortening the last octet or completely deleted after 24 hours at the latest. Storage of IP addresses in plain text beyond this period does not occur unless this is exceptionally necessary in the event of security incidents for the preservation of evidence or to clarify legal violations. Pseudonymous usage data (such as browser type, referrer, or timestamp) are automatically deleted after six months, provided that no statutory retention obligations prevent this. (vii) Necessity: The provision of the above-mentioned personal data is neither legally nor contractually required. However, the processing of HTTP data (in particular the IP address) is technically mandatory to enable the connection to our servers, to deliver the website content correctly to your end device, and to ensure the stability and security of our IT systems against external attacks. Without the disclosure of this data, use of the website and retrieval of the services offered on it is technically excluded.
2.2 Local Storage (Game Data)
We use so-called "Local Storage" technology on our website. This involves data being stored locally in your browser's cache on your end device, which remains and can be read even after the browser window is closed or the program is ended, unless you clear the cache. (i) Purpose: The purpose of data processing is to enable and maintain the gaming operations of memory-game.net. This includes the local storage of game progress, levels reached, individual game statistics (e.g., number of moves required, best times), and the player name you have chosen. The use of this technology serves to provide you with a continuous user experience without you losing your progress every time you visit the website again. No change in purpose is planned. (ii) Data: The processed data includes: Game State Data: Current level, status of revealed cards, scores achieved. Performance Data: Timestamp of the start and end of the game, duration of game rounds, number of clicks/moves. Identification Data: A nickname (pseudonym) freely chosen by you. (iii) Legal Basis: The legal basis for storing information on the user's end device is our legitimate interest in providing a functional and user-friendly online game whose core function requires the storage of progress (Section 25 para. 2 no. 2 TDDDG). Subsequent processing of the data is based on our legitimate interest in designing an attractive range of games (Art. 6 para. 1 lit. f GDPR). (iv) Data Provision: The data is actively generated through your interaction with the game and automatically written to the local storage by your browser. (v) Recipients: The data remains exclusively local on your end device. For technical reasons, no transmission of this data to our servers or to other third parties takes place. At no time do we have access to the information stored in your browser's local storage. (vi) Storage Period: The data in the local storage is intended to be permanent. It remains on your end device until you actively remove it by deleting the website data or the browser cache in your browser settings. (vii) Necessity: The provision of this data is technically necessary for the use of the game's save function. If you prevent the use of Local Storage through appropriate settings in your browser, game progress and statistics cannot be permanently saved; however, use of the basic functions of the website remains possible.
3. Consent Management & Cookies
3.1 Necessary Cookies: We use cookies on our website. Cookies are small text files that can be stored on the user's end device via the browser when visiting the website. When a website is accessed again with the same end device, the information stored in cookies can be read and processed. In doing so, we use processing and storage functions of your end device's browser and collect information from the browser's memory. In the structure of these privacy notices, we distinguish between necessary cookies and statistics cookies. Cookies that are technically necessary for the functioning of the website (so-called necessary cookies) cannot be deactivated via the cookie management function of this website. However, cookies can generally be deactivated in the respective browser at any time. Different browsers offer different ways to configure cookie settings in the browser. However, we would like to point out that some functions of the website may not or no longer function properly if you generally deactivate cookies in your browser.
3.1 InMobi Choice (Consent Management Platform)
We use the Consent Management Platform (CMP) "InMobi Choice" in version 3.0 on our website. This is a service provided by InMobi Technologies Pte. Ltd. (Singapore). In accordance with Art. 27 GDPR, Taylor Vinters Europe Limited, Clifton House, Fitzwilliam Street Lower, Dublin, D02 XT91, Ireland (E-mail: [email protected]) has been appointed as the official EU representative. (i) Purpose: Management and documentation of consent decisions. The service enables compliance with the IAB Transparency and Consent Framework (TCF 2.2/2.3) as well as the Global Privacy Platform (GPP). Note: Until your decision is made, only cookie-less signals are processed for technical reasons in order to provide the service. (ii) Data: HTTP data (IP address, browser, date/time) as well as TCF/GPP data (encrypted "Consent String", CMP ID: qKaq5_F8_LWEu, consent status). (iii) Legal Basis: Legitimate interest in the legally compliant control of consents (Art. 6 para. 1 lit. f GDPR) as well as accountability (Art. 5 para. 2 GDPR). Storage in the browser in accordance with ยง 25 para. 2 no. 2 TDDDG. (iv) Data Provision: The data is provided automatically by the browser and through your interaction with the banner. (v) Recipients: The recipient is InMobi Technologies Pte. Ltd. in Singapore. The data transfer is secured by Standard Contractual Clauses (SCC) approved by the European Commission, ensuring an adequate level of data protection (Art. 46 para. 2 lit. c GDPR). Further details: https://advertising.inmobi.com/privacy-policy/. (vi) Storage Period: Consent information is stored for 13 months; audit logs are kept for 30 days. (vii) Opt-out: A general opt-out for InMobi can be declared here: https://www.inmobi.com/page/opt-out/.
3.2 Hotjar Web Analysis
If you have given your consent for this, we use the web analysis tool Hotjar on our website. With the help of Hotjar, we can examine your usage behavior on our website in pseudonymized form. You can deactivate data processing by Hotjar at any time in our "Cookie Board" or use the following opt-out link: https://www.hotjar.com/legal/compliance/opt-out. Alternatively, you can deactivate Hotjar cookies for the browser currently in use by deactivating the storage of cookies in your browser settings. (i) Purpose: The purpose of data processing is to increase the efficiency of our resource use for our web offering and the satisfaction of visitors through (usage-based) optimization of our web offering by measuring the use of our web offering. The focus here is primarily on the handling of special features of our web offering. No change in purpose is planned. (ii) Data: The processed data are: HTTP Data: Log data that arise technically when using Hotjar via the HTTP(S) protocol (IP address, browser type/version, operating system, referrer URL, date/time). Hotjar End Device Data: IDs generated by Hotjar for (re-)recognition as well as the IP address (anonymized by shortening the last octets for regional identification). Hotjar Measurement Data: Device-related raw data (sources, location region, browser/end device, page views, length of stay, mouse movement data) to create device-related usage profiles. An identification of your person (civil name) does not take place. Hotjar Report Data: Aggregated reports based on the analysis of raw data. Recordings of the session and the session duration are possible. (iii) Legal Basis: Your consent (Art. 6 para. 1 lit. a GDPR; Section 25 para. 1 TDDDG). (iv) Data Provision: The data is provided automatically by the visitor's browser. (v) Recipients: The recipient of the data within the scope of order processing is Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta. Hotjar Ltd uses the subcontractor Amazon Web Services EMEA SARL ("AWS"), Luxembourg, for hosting (server location Germany). Access from third countries such as the USA is secured by EU Standard Contractual Clauses (2021/914; Module 3). Furthermore, the Amazon companies are certified according to the EU-US Data Privacy Framework, viewable at: https://www.dataprivacyframework.gov/participant/4424. (vi) Storage Period: The data is deleted after 12 months at the latest. (vii) Necessity: The provision is neither legally nor contractually required. There is no obligation to provide it. In the event of non-provision, we cannot perform an analysis of usage behavior by Hotjar.
4. Advertising & Other Services
The following subsections describe ad-related and technical management services.
4.1 Google AdSense
We use the Google AdSense service on our website. This is a service of Google Ireland Limited for integrating advertisements. Google AdSense uses cookies and so-called web beacons (invisible graphics), with which information such as visitor traffic on this website can be analyzed. (i) Purpose: The purpose of data processing is the monetization of our free web offering by displaying advertisements. The data is used to increase the relevance of the ads for users, improve reports on campaign performance, and avoid a user seeing the same ads multiple times. In the case of consent, profiles of usage behavior are also created to display personalized advertising. No change in purpose is planned. (ii) Data: The processed data includes: HTTP Data: IP address, type and version of the web browser, operating system used, the page called up, date and time of the retrieval. Online Identifiers: Cookie IDs (e.g., for storing consent or for advertising preferences), device IDs. Interaction Data: Data about clicks on ads, viewed advertising material, and user behavior on the website in connection with the displayed ads. (iii) Legal Basis: The legal basis for storing information on the end device (cookies) as well as for the subsequent processing of personal data is your express consent according to Art. 6 para. 1 lit. a GDPR as well as Section 25 para. 1 TDDDG. (iv) Data Provision: The data is provided automatically by the visitor's browser or read from the set cookies. (v) Recipients: The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited uses Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as a subcontractor. Access to the data from the USA cannot be excluded. The transfer is secured by the EU Standard Contractual Clauses. Furthermore, the Google companies are certified according to the EU-US Data Privacy Framework, which can be viewed in the official register of the U.S. Department of Commerce at the following link: https://www.dataprivacyframework.gov/participant/4424. Further information on data use by Google can be found at: https://policies.google.com/privacy. (vi) Storage Period: The cookies set by Google AdSense have different terms (usually between 30 days and 2 years), unless they are deleted by you beforehand. The pseudonymized data is automatically deleted after the statistical evaluation has expired. (vii) Withdrawal: You can withdraw your consent at any time with effect for the future via our "Cookie Board" or prevent the installation of cookies by setting your browser software accordingly.
4.2 Google Tag Manager & Search Console
(i) Purpose: We use the Google Tag Manager to manage website tags (e.g., for AdSense or Hotjar) centrally via an interface. The Tag Manager itself does not record any personal data except for the technically necessary IP address for loading the service. We use the Google Search Console to monitor the technical health of our website and indexing in Google Search. (ii) Legal Basis: The legal basis is our legitimate interest in efficient management of our website and in optimizing discoverability in search engines (Art. 6 para. 1 lit. f GDPR). (iii) Recipients: Google Ireland Limited, Dublin, Ireland (secured by EU-US Data Privacy Framework).
5. Rights of the Data Subjects and Other Information
(i) We do not use automated individual decision-making procedures. (ii) You have the right to request information at any time about all personal data that we process from you. (iii) If your personal data is incorrect or incomplete, you have a right to rectification and completion. (iv) You can request the deletion of your personal data at any time, provided that we are not legally obliged or entitled to further process your data. (v) If the legal requirements are met, you can request a restriction on the processing of your personal data. (vi) You have the right to object to the processing, insofar as the data processing takes place for the purpose of direct marketing or profiling. (vii) If the processing takes place on the basis of a balance of interests, you can object to the processing, stating reasons arising from your particular situation. (viii) If the data processing is based on your consent or within the framework of a contract, you have a right to the transfer of the data provided by you, provided that this does not affect the rights and freedoms of other persons. (ix) If we process your data based on a declaration of consent, you have the right to withdraw this consent at any time with effect for the future. The processing carried out before a withdrawal remains unaffected by the withdrawal. (x) You also have the right to lodge a complaint with a data protection supervisory authority at any time if you are of the opinion that data processing has taken place in violation of applicable law.