Privacy policy

Cologne Game Lab (“CGL”), is committed to protecting the user’s privacy and personal data. Personal data is collected and used strictly within the legal limits of applicable data protection law. With this privacy policy, we inform the user of the personal data we collect when they use the app Antura and the Letters and what purpose we use it for.

We collect and use the user’s personal data strictly within the legal limits of the data protection laws of the Federal Republic of Germany. We inform the user below of type, extent and purpose of any collection and use of personal data. The user can access this information at any time on our website at https://antura.org/privacy-policy

1. Data controller/Contact

The data controller for the purpose of data protection law is:

Cologne Game Lab
(Institut der TH Köln)
Schanzenstraße 28
51063 Köln
Germany

Please feel free to address any questions or concerns regarding data protection/privacy to privacy@antura.org.

2. Scope of data protection

Data protection concerns personal data. This is defined in Sec 3 para. 1 of the German Federal Data Protection Act (“Bundesdatenschutzgesetz”; “BDSG”) as any information concerning the personal and material circumstances of an identified or identifiable individual. This includes information like name, postal address, e-mail address or telephone number, but also usage date in some cases. Usage data are data required to use our app, for instance information about start, end and extent of use as well as login data.

3. Collection and use of the user’s data

3.1 Automatic data collection

When the user accesses our app while connected to the internet, their device automatically transmits certain data for technical reasons. The following data are stored separately from any other data the user may transmit to us:

• Date and time of access
• Device type and version
• Operating system
• Section of the app being used
• Unique anonymous user identity

Such data is stored for purely technical reasons and are never associated with any particular individual.

3.2 Voluntary data entered by the user

In order to fully enjoy our services, the user is asked to enter their age and gender. Such data helps create a unique identity for the user, stored locally and not automatically shared with us. This data is only shared with us voluntarily through the restricted parent/teacher section in the app. Furthermore, we allow the parent/teacher of user to voluntarily upload information about usage and themselves. Sharing any such information is voluntary and not required though we may need these and potentially additional data in order to handle to their support requests.

3.3 Community features

We provide interactive areas or services on our app, including the ability to share the app with friends via social media such as Facebook or Twitter. When the user uses community features, they should be aware that these areas are publicly accessible and all the personal information they share on these social media or have entered upon registration may be accessed by others. We are unable to control how other visitors to our websites and/or apps as well as social media users use such information. In particular, we are unable to prevent unsolicited communication to the user. Content shared in Interactive Areas may be available for an unlimited time. If at any time the user wishes any content to be removed, please let us know by e-mail to the address provided above.

3.4 Advertising

If the user consents, we will use the user’s personal data to provide them with certain offers and information customized to their needs and inform them of news, such as improved service offerings and other events. the user may opt out of the use of their data for such opinion and market research purposes at any time with effect for the future by notifying us accordingly using our contact information provided above.

4. Sharing data

As a general rule, the user’s personal data will be shared with third parties without their express prior consent only in the cases described below:

• If it serves investigations of illegal use of the platform or is required to pursue legal claims, personal data may be shared with law enforcement agencies and third party victims. Such transfer of data will be made only where there is specific evidence for illegal or abusive conduct. Data may further be shared where it serves the enforcement of terms of use or other contractual agreements. We are furthermore legally obliged to disclose certain information to certain public entities upon request. Such entities include law enforcement agencies that investigate administrative offences subject to fines, and tax authorities.
• From time to time, we may require the assistance of contractually hired third parties and external service providers in order to provide our services, for instance in the domains of sending information and advertisements (only where the user has explicitly consented beforehand). In these cases, we share information with such companies or individuals to enable them to carry out their tasks. Such external service providers are carefully selected and regularly checked in order to ensure the user’s privacy. Service providers may only use the data for the purposes specified by us. Service providers are furthermore contractually obliged by us to treat data strictly in accordance with this privacy policy and German data protection law.
• As our business evolves, the structure of Cologne Game Lab may change, for instance by a change in legal form or creation, acquisition or sale of subsidiaries, branches or parts of a company. In the course of such transactions, customer data will be transferred together with the relevant part of the company being transferred. In each case of a transfer of personal data to third parties to the extent described above, we will ensure that such transfer is made in accordance with this privacy policy and applicable data protection law.

5. Newsletter

We offer a free newsletter service via applications such as Telegram that the user may sign up to. In its newsletter, we inform our users about updates to the application or to provide the user with other information that may be of interest to them. Furthermore, our newsletter informs the user about offerings and products of our partners.

In order to receive the newsletter, the user may join the channel @Antura on the application Telegram.

The user may opt out of the newsletter at any time by leaving the channel on Telegram.

6. Contact form

We provide the user a contact form to make it easier for the user to contact us. If the user enters data in our contact form (First Name, Last Name, Email address, Country) and submits this data to us, we will store and use their data to the extent required to process their request. If we do not need the user’s data any longer, it is being deleted unless we are legally required to keep it.

7. App permissions

Our app requires the following permissions:

8. Local Storage

We use so called local storage to provide the user with a wide range of functionalities and to give them a better user experience. By using local storage we are able to recognize the user’s device and to distinguish their device from others. The sharing of the data is voluntary through the restricted parent/teacher section in the application.

9. Pseudonymous usage statistics

9.1 Usage profiles

When the user uses the app, we create local pseudonymous usage profiles for purposes of research or improvement of our service and to satisfy customer needs. Only usage data are used for the creation of such profiles, in particular play type and sessions. This data is only given to us voluntarily through the restricted parent/teacher section of the app.

Of course it is entirely up to the parent/teacher of the user what information they chose to provide us with. We feel obliged to give the parent/teacher of the user this choice according to the principle of data economy. If the user does not disclose certain information to us, they may not be able to receive additional support. However, all features of the app will always be available to the user.

9.2. Unity Analytics

We use Unity Analytics, a web analytics service provided by Unity Technologies SF (“Unity”). Unity Analytics may collect pseudonymous data on how the user uses our app. The information about the user’s use (including their truncated IP address) is transmitted to servers controlled by Unity in different countries and is stored there. Unity uses this information to analyse the user’s use of the app, to generate reports about app activities for app publishers and to provide further services related to app and internet use. Unity may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Unity.

The user can find detailed information about how Unity uses the user’s data in Unity’s privacy policy: https://unity3d.com/legal/privacy-policy

The user may prevent Unity Analytics from collecting data by always using the application offline.

10. Deletion of the user’s data

To the extent the user’s data is no longer required for the aforementioned purposes, it is deleted. If the user deletes their user account, their profile will be entirely and finally deleted. To the extent data must be retained for legal reasons, they are blocked and will not be available for use.

11. Right to access and correction

Of course the user is entitled, upon request, to disclosure regarding their personal data that we are storing. The user is also entitled to have any incorrect data corrected and rights to blocking or deletion. Please address any requests in such matters to our email address mentioned above or write to us at the address stated above.

12. Changes to privacy policy

We reserve the right to modify this privacy policy. The current version of the privacy policy is always accessible at https://www.antura.org/privacy-policy.