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Privacy Policy of BBG Entertainment GmbH

 

Version: 1.0 as of 1st of March 2013

 

BBG Entertainment GmbH, Cuvilliéstr. 14, 81679 Munich, Germany (hereinafter “BBG”), respects your right for privacy. BBG always endeavors to offer you an outstanding service for all products and services. In addition, BBG would, by means of this Privacy Policy, like to provide the Users of the offering with supplemental information concerning the handling of personal data. 

BBG will of course treat all personal data that a User transmits in the course of the business relationship in compliance with the applicable data protection provisions. The details about how BBG handles personal data can be found in this Privacy Policy. 

 

Structure:

 

1. Scope of application

2. Data categories and gathering of data

3. Use of data

4. Data integrity and security

5. Rights of Users

6. Information

7. Incorporation, validity and actuality of the Privacy Policy

8. Amendment of the Privacy Policy

9. Contact

 

1. Scope of application

This Privacy Policy is applicable to all websites operated by BBG under the domain ”myBrainTraining.com” (“offering”) and is oriented to the users of this offering (“Users”). 

If other offerings of BBG have a differing Privacy Policy, the differing Privacy Policy published on the respective website or in the respective offering shall apply. The BBG offering might contain cross-references ("links") to other websites of third-party providers. By clicking on such links you sometimes leave the websites or offering of BBG and reach the websites or offerings of third parties, for whose content, compliance with data protection, or Privacy Policy BBG assumes no responsibility. The BBG Privacy Policy does not apply to such websites or offerings of third parties. In particular, BBG is not responsible if the same data protection standards that are observed by BBG do apply on websites or offerings not operated by BBG. For this reason, Users should carefully read through the Privacy Policies of linked websites or offerings.

 

2. Data categories and gathering of data

BBG makes every effort to constantly optimize its products and services. For this purpose BBG would like to have a better understanding of the interests and wishes of its Users. Therefore BBG gathers personal data. 

2.1 Personal data

“Personal data” are individual details about personal or objective circumstances of a specific or determinable natural person. This is data such as e.g. name, mailing address, birth date and gender.

Information that the User provides to other Users via the offering of BBG (e.g. photos, interests) may also constitute personal data

2.2 Particular types of personal data

BBG does not gather any data that provides information concerning racial or ethnic heritage, political opinions, religious or philosophical convictions, labor union affiliation, health or sex life, unless the User voluntarily discloses such information in his communication with BBG. 

2.3 Master data

BBG gathers personal data to the extent that they are necessary for the establishment, substantive structure or modification of the contractual relationship between BBG and the respective User concerning the use of the offering of BBG ("master data"). This data includes for example a free to choose user name, the email address, name, address, birth date and picture of Users. BBG principally only gathers this data, if the User has submitted them voluntarily. 

The necessary data for the processing of payments will also be gathered. If the User purchases a premium account, BBG will gather the complete address of such User due to fiscal provisions. Further data necessary for the processing of payments (insofar as necessary or applicable for the direct debit procedure: Account holder, account number, bank; and for the payment by credit card: card holder, card company, card number, expiry date) will not be gathered by BBG, but directly by the involved payment service provider. BBG has no access to this data. The address of the User will be submitted to BBG by the payment service provider in the course of the settlement performed between BBG and such payment service provider.

2.4 Usage data

To the extent necessary for BBG, BBG will gather and use data of a User in order to enable and bill for the proper and contractually appropriate utilization of the products and services (“usage data”). Usage data are, in particular, characteristics for purposes of identifying the User, information concerning the beginning and end, as well as the type and extent of the respective use, and information concerning products and services utilized by the User.

Users can also access the offer of BBG through mobile devices (e.g. smartphones and tablets). In this case it might be necessary to collect addition technical data about the device (e.g. type of device and identification number), in order to provide the mobile use of the offer.  

 

3. Use of data

BBG gathers and processes personal data of Users only to the extent that BBG assumes that such gathering and processing reasonably serves its lawful business purpose and that the data have been voluntarily communicated by the User (for example, in forms or otherwise within the framework of the offering operated by BBG) in electronic or other communication. Relevant for BBG in this regard is the goal of product and service optimization in the interests of Users.

3.1 Data logging for internal system purposes and statistical purposes

In addition to the data directly provided by Users, BBG’s system automatically records information, namely usage data, during the visit to BBG’s offering. This might include data such as browser type, browser language, geographical origin, date and type of the visit, access time or the address of the visited pages, the User’s IP address and the domains from which the User is accessing BBG’s offering. 

IP addresses serve the purpose of the clear identification of the computers which are connected with the Internet. The location of the computer can also be derived from this. The IP address is transmitted with each server enquiry so that the server knows where the answer has to be sent to. The IP address is allocated to each user of an Internet-Service-Provider (ISP) as soon as he connects with the Internet. The ISP can understand which IP address at which time was allocated to which of its customers. As long as the IP address is stored there, it is theoretical possible to determine the identity of the connection holder via the ISP. BBG stores the IP address of the User which he possesses during his registration, when logging in, when placing an order as well as in the event of the deactivation of the user account. BBG uses it to recognize the session and for the defense against attacks.

3.2 Analysis of the offering 

The offering of BBG uses among others Google Analytics, a web analytics service of Google Inc. (“Google”). Google Analytics uses so-called “Cookies”, text files, which are stored on your computer and which enable an analysis of the use of the offering by the User. The information about the use of the offering by the User (including his IP address) generated by the cookie is transmitted to a server of Google in the USA and stored there. Google shall use this information in order to evaluate the use of the offering of BBG, in order to compile reports about the activities of Users on the offering for BBG as operator and in order to provide further services associated with the use and the internet use. Google shall also if applicable transmit this information to third parties insofar as this is stipulated by law or insofar as third parties process these data by order of Google. Google will in no way combine the IP address of a User with other data of Google. Users can prevent the installation of the cookies by a corresponding setting of the browser software; BBG however points out that in this case Users can if applicable not use all functions of the offering of BBG in full. By using the offering of BBG Users declare that they agree with the processing of the data collected about them by Google in the manner described above and for the afore-mentioned purpose. The Users can object to the collection and use of their IP address by Google Analytics (more detailed information in this respect under: 

https://tools.google.com/dlpage/gaoptout?hl=en. 

BBG points out to its Users that in the offering of BBG Google Analytics was extended by the code offered by Google “gat._anonymizeIp();” in order to guarantee an anonymisation of the collected IP addresses.” 

3.3 Analysis of play behavior for scientific and commercial purposes

In the course of the performance of the contractual relationship between BBG and the User, BBG analyses the play behavior and the play results of the User for the respective User (for more details please refer to number 3.6). Besides, it is possible that BBG will collect and store anonymized data about the actions of Users on the offerings of BBG and about their results for scientific and commercial purposes. Game data will be statistically evaluated with respect to the play time, the age, the gender and the geographic location of the respective User and his achievements and results. BBG uses special software for this purpose. All data is evaluated in an anonymized way and is deleted on a regular basis. The results of this evaluation help BBG to improve the quality of its products and services. 

3.4 Combining of Data

In the course of the performance of the contractual relationship between BBG and the User, BBG combines statistical data with personal data of the User for the respective User (for more details please refer to number 3.6). Besides, statistical data will only be combined with personal data of the Users, if this is necessary for the prevention of infringements or breach of contract. If BBG notices that a User is in violation of this agreement, BBG reserves the right to combine the IP Address of this User with other stored data about him in order to be able to notify him about his violation of this agreement. 

3.5 Cookies

BBG uses so-called “cookies.” A cookie contains information that the BBG offering sends to the User’s browser, which then stores the information on the User’s system. If cookies are used, BBG’s offering is able to note information about the User and his settings until the User closes the current browser window (so-called “session cookies”) or until the user deactivates or deletes the cookie or the validity of the cookie expires. BBG uses cookies for purposes as described below.

3.5.1 Session Cookies 

BBG uses session cookies when registered or non-registered Users use the BBG offering through a website provided by BBG. In this case, BBG’s web server automatically sends a session cookie to the User’s browser, which makes it easier for the User to navigate in the offering. The session cookie contains a value, by means of which the BBG software can determine which page is supposed to be displayed when the User clicks the “back” button in his browser. In addition cookies contain information about the User ID, which BBG automatically allocates to each User. The cookies also contain data about the language and territory selections of User. The cookie is deleted as soon as the User logs out or closes his browser session. 

3.5.2 Other Cookies

Further cookies will be used in connection with the usage of Google Analytics (see number 3.2), Social Media-Plugins (see number 3.9), as well as the possibility to use Single-Sign-On (see number 3.8). For further information please refer to the respective paragraphs of this Privacy Policy.

3.6 Contractual relationship

BBG uses personal data of Users to the extent necessary for the establishment, performance or ending of the contractual relationship with the respective Users. This is the case if, among other things, Users wish to utilize the products and services of BBG via the BBG offering. 

3.6.1 Establishment

Both the simple transmission of specific personal data by the User (for example, in specific forms for product or service orders), as well as the registration of a User for use of the BBG Service and/or other services offered by BBG, might be necessary by way of electronic or other communication as part of the use of the BBG offering. 

3.6.2 Performance

To the extent necessary for the performance of the contractual relationship between BBG and the respective Users, BBG uses personal data of Users, for example, for the transmission or furnishing of products or services within the framework of the use contract that has been concluded and for the use possibilities in connection with the use contract (for example, downloading the translations or asking for support etc.). BBG processes usage data of the respective User for the User, to provide such User with functions of the offering that the User requests. This may include the display of the User’s progress or options to compare the User’s results with the results of other users, e.g. with the results of respective reference groups or, in the course of the use of a friends list created by the User, with users on such list. For this purpose, BBG analyses the play behavior and the play results of the User and combines statistical data with personal data of the User, as required to render the possible uses requested by the User.

In addition, relevant data are used in order to gain knowledge of malfunctions or an abuse of BBG’s offering.

For purposes of payment processing, BBG has the right to forward User data to service providers engaged to collect the fee if this is necessary to do so in order to determine the fee and obtain settlement from the User. 

If BBG collaborates with third parties for purposes of the rendering of the services, BBG will obligate them to observe the applicable data protection provisions and guarantee adequate data protection.

If the operation of the entire offering or a portion of the offering or a product or service of BBG, for which Users have registered, is transmitted to a third party in whole or in part, BBG is entitled to provide such third party with the Users’ personal data for the purpose of the further operation of the offering or portions of the offering or the product or service.

3.6.3 Payment processing

BBG is also entitled to make User payment data available to an assigned service provider. BBG cooperates with e.g. Paypal S.à.r.l. et Cie, S.C.A. from Luxemburg and with Moneybookers Limited from the United Kingdom. Insofar as Users provide credit card data to BBG for the payment in the real time process the credit card numbers are used exclusively for the payment processing and no other purposes. BBG can use the services of a provider for fraud management of the payment process in order to create an increased degree of security against fraud for the benefit of the Users and BBG and to promote the protection of financial information.

3.6.4 Termination

BBG also uses personal data of the respective affected parties in the course of the termination of the contractual relationship with a User to the extent necessary to wind up the obligatory relationship. This can include, for example, the settlement of an outstanding balance. 

3.7 Communication 

User data can be used within the framework of communication. In this regard as well, BBG will adhere to standards set by applicable data protection regulations. 

3.7.1 User inquires

In the event of inquiries by Users, BBG will process personal data for the purpose of answering them. 

BBG archives correspondence with Users with the goal of improvement of BBG’s products and services and BBG’s offering and for its own business purposes. 

3.7.2 Surveys

BBG shall occasionally request Users to provide data within the framework of surveys. The User is at liberty to decide whether he would like to provide corresponding information and consents to the collection and processing of these data. The survey data are used for monitoring and improving the offer, the products and services as well as for improving the offer of services of BBG.

3.7.3 Communication between Users through the offer

Some information, among others the communication between Users about offers of BBG – e.g. within a board, can also be visible for other Users of the offer of BBG. BBG recommends Users to handle their data carefully and sparingly as well as to carefully weigh up what and with whom the User communicates.

The communication about the offer of BBG is as a general rule not subject to any control of the contents by BBG. Nevertheless, BBG reserves the right to delete entries at its own discretion and to exclude Users from the further use in particular if entries satisfy factual elements which are relevant under criminal law or are not compatible with the aims of BBG.

3.8 Single-Sign-On

For the use of its offering, BBG offers the User the opportunity to register using the data stored in a User's account at Facebook or Google+. By using this feature, data is transferred from Facebook or Google+ to BBG if the User previously consents. With the information provided by Facebook and Google+, an account at BBG is created. The Facebook or Google+ account of the user will not get linked with the service(s) of BBG, data will only be sent once from Facebook or Google+ to BBG.

3.9 Social Plugins

The offering of BBG uses so-called plugins of the company Facebook (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA). These represent links to the social network of Facebook or integrate linking possibilities available at Facebook. With their help, Users can take advantage of features of the social network of Facebook directly within the offering of BBG, i.e. even without switching to the pages of Facebook (in the following: „Facebook plugins”). The best known Facebook plugin is the „Like” button, which adds the possibility to recommend the offering or parts of the offering of BBG to friends. Facebook plugins immediately connect to the Facebook servers and transmit data to Facebook. BBG has no influence on this connection and the transferred data. In particular, regardless of whether the User interacts with a Facebook plugin, the information that the User visited the offering of BBG is transferred to Facebook. If the User is logged in to his Facebook account at that time, this information is also assigned to his account. However, even if the User in not logged in to his Facebook account, information is transmitted to Facebook, which can possibly be assigned to the current or a future User account. The extent of additional data collection, processing and usage by Facebook as well as their purpose comply with the privacy notices of Facebook, which can be accessed at http://de-de.facebook.com/policy.php. There is also more information about User rights and the possibility of adjustments / setups for privacy protection.

3.10 Access to data by third parties designated by User

The User may agree that a certain third party gains access to the data stored in his account. For this purpose, the User may determine such third party as an administrator for his account. The third party can then access all data stored in the User's account. The User shall declare his consent towards the third party and if necessary revoke it in the future. BBG will grant the third party access to the data until the User declares in writing to BBG, that the third party should not be an administrator for the account anymore or that the consent towards the third party was revoked.

The same applies if a User account registration is performed by a third party with the User’s consent.

3.11 Advertising, market and opinion research

In addition to the degree which is admissible according to the statutory regulations BBG shall only collect, process and use personal data of Users for purposes of advertising and/or purposes of market and opinion research insofar as the respective User has explicitly previously consented to a collection, processing and use for purposes of the market and opinion research or to a processing and use for purposes of advertising.

3.11.1 Information about the BBG Service per email

If Users declare their permission to use and process their email address, BBG will send the desired information to the respective Users, usually in the form of newsletters or invitations to participate in special offers or competitions. 

In order to send newsletters or other information to Users per email (“Newsletter-Service”) BBG needs at least one valid email address of the Users. 

For the registration to the Newsletter-Service BBG uses the so-called double-opt-in procedure. In this procedure Users will only receive newsletters or other information after they have clicked on a special link for confirmation, which will be sent to their email address after their registration for the Newsletter-Service. This procedure should guarantee, that the respective User is the owner of the submitted email address. The confirmation through the special link has to be made within a short timeframe after the registration or the submitted email address will be deleted from BBG’s database. Until the owner of the email address confirms his wish to participate in the Newsletter-Service, another registration with this email address for the Newsletter-Service will not be possible. 

If the User has provided BBG with his email address during an existing customer relationship with him, BBG may send such information regarding services to the User, which are similar to the services which he has already requested. Users can object to the use of their email address for the receipt of such BBG information at any time, without incurring transmission costs for this other than the transmission costs according to the basic rates. BBG will inform the User in every such newsletter or email about his rights and offer him the possibility to directly object the receipt of further newsletters or information. 

3.11.2 Market research

BBG can use information stored about Users for internal surveys about demography, user interests and user behavior. This use is carried out anonymized. For purposes of advertising and market research BBG can evaluate information about Users in an anonymized and aggregated form. If and insofar as BBG uses User data for creating user profiles it shall discontinue their use if this is objected to by the respective Users.

3.12 Data transmission 

BBG is entitled to transmit and store Users’ personal data to other member states of the European Union or within the European Economic Area for the purposes stated in this Privacy Policy. The transmission of personal data to countries outside or the European Union or the European Economic Area requires the explicit permission of the User.

BBG will not transmit any personal data to third parties in any unlawful way. 

 

4. Data integrity and security

BBG endeavors to achieve a level of correctness of the stored personal data of Users that is corresponding to the current standards. For this purpose, BBG will take a precautionary measure by allowing individual persons reasonable access to the stored personal data of Users in order to check, correct or anonymize (if necessary), block or delete such data. Within the framework of BBG’s offering Users also have the opportunity, following authentication, to independently inspect and/or modify the data they have transmitted.

The protection of personal data that BBG has received from Users of the offering is an important component of the company philosophy of BBG. BBG protects personal data of Users of offerings of BBG against loss, abuse and modification by means of modern security measures of a physical, technical and administrative nature. All servers are hosted by selected partners within the European Union, who can ensure the same data security as BBG and are obliged to comply with data protection law.

As is the case with all transmissions of data via the Internet, however, a residual risk also remains in the case of sending and receiving personal data. 

BBG points out to Users that, in spite of the stringent requirements BBG places on data protection, all information that a User voluntarily releases via the Internet can also potentially be used by others. For this reason, BBG cannot assume any responsibility or liability for the disclosure of information as a result of errors in data transmission and/or unauthorized access by third parties. 

 

5. Rights of the Users

Each User has a right to the correction, blocking and deletion of his personal data in accordance with the statutory provisions. If the User does not undertake any amendment or deletion himself, BBG is available at the address stated at the end of this Privacy Policy and is happy to receive corresponding applications. BBG will appropriately amend or, as the case may be, delete personal data of Users of BBG’s offering as quickly as possible. BBG points out that, due to technical and organizational conditions, it is possible that, even after the request for amendment or deletion, some measures will still be carried out that have already begun, but have not yet been completely executed, after Users notified BBG of the request for deletion. BBG likewise points out, however, that deletion of User data is only possible if it is not precluded by legal provisions, particularly with respect to data for billing and/or bookkeeping purposes.

Each User is at liberty at all times to object to the processing and use of his personal data for purposes of advertising or the market and opinion research. In particular Users can object to the use of their email address for the receipt of newsletters and/or information of BBG at all times without other costs incurred to the Users for this purpose than the transmission costs according to the basic tariffs. BBG will clearly point out their right to objection to its Users both when collecting the email address as well as with each use in newsletters or other information.

BBG can be contacted at the address stated at the end of this Privacy Policy for corresponding applications or, as the case may be, communications by Users. 

 

6. Information

Users as well as third parties sometimes have a right to information with respect to the data gathered and stored by BBG. 

In specific individual cases, BBG is entitled to give information or obligated to give such information to the competent offices on the basis of statutory provisions. 

6.1 Users right to information

In response to a request by a User, BBG will at no charge give information concerning all personal data stored by BBG concerning him. In principle, such information is transmitted in electronic form (via email). Such Customer inquiries are to be directed to the address stated at the end of this Privacy Policy. 

If the User takes advantage of this opportunity for the issuance of information via email, the stated email address (both sender and recipient) will not be used for any purpose other than the issuance of information and the documentation thereof. 

6.2 Third parties right to information

In individual cases, BBG can be entitled to inform third parties concerning personal data of the Users of offerings of BBG. BBG reserves the use of its right to give information in individual cases following detailed review and careful consideration.

If BBG is legally obligated to forward its data to local, state, national or international agencies, BBG will comply with such obligation. 

In addition, BBG will disclose data to third parties if applicable statutes and regulations require so. 

Moreover, BBG can disclose information in order to review or prevent illegal activities or a suspicion of fraud or to initiate appropriate counter-measures or in order to enforce or apply the contracts of BBG. 

 

7. Incorporation, validity and currentness of the Privacy Policy

By using the offering and the services associated therewith, Users consent to the use of data described above.

Version 1.0 of this Privacy Policy dated 01.03.2013 is currently valid. 

 

8. Amendment of the Privacy Policy

BBG reserves the right to amend this Privacy Policy from time to time, but BBG will always observe the applicable statutes concerning data protection. BBG recommends that Users review the current Privacy Policy at the time of each visit to the BBG offering. BBG will naturally inform the Users in advance if it wishes to use the Users’ personal data to a greater extent than set forth in this Privacy Policy. 

 

9. Contact

Your interest is important to BBG. You can reach BBG at:

 

BBG Entertainment GmbH

Department: Privacy Policy

Cuvilliéstr. 14

81679 Munich

Germany

info@bbg-entertainment.com