Privacy Policy for “Touch Type Tale”

I.          Residents in the EEA, UK and Switzerland

1.         General Information

1.1.     Responsible Body

Below we explain to you which personal data is collected and processed by us when using our services and offers.

Pumpernickel Studio Software GmbH und Co. KG 
Windthorstraße 68
48143 Münster
Email: info[at]pumpernickel-studio.com

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person, this means all information that relates to a person.

1.2.     Legal Basis

As far as a legal basis is mentioned in this Privacy Policy, they relate to the General Data Protection Regulation.

We collect and process personal data based on the following statutory regulations:

  • Consent according to Article 6 paragraph 1  (a) General Data Protection Regulation (GDPR). Consent is any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, which indicates that the data subject consents to the processing of his personal data.

  • Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 (b) GDPR, this means that the data is required so that we can fulfill the contractual obligations to you or we need the data to prepare a contract closure with you.

  • Processing to fulfill legal obligations under Article 6 para. 1 (c) GDPR, this means that a processing of the data is required by law or other regulations.

  • Processing for the protection of legitimate interests in accordance with Article 6 para. 1 (f) GDPR, this means that processing is necessary to safeguard legitimate interests on our part or by third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail.

1.3.     Rights of affected

You are entitled to the following rights with regard to the processing of data by us in accordance with the respectively listed articles of the General Data Protection Regulation:

  • Information Right pursuant to Article 15 GDPR, i.e. the right to be informed about how your personal data is processed and which personal data is processed by us,

  • Right of rectification pursuant to Article 16 GDPR - i.e. the right to request the rectification of inaccurate personal data relating to you without undue delay, including the completion of incomplete data,

  • Right to erasure ("right to be forgotten") pursuant to Article 17 GDPR - i.e. the right to request the erasure of your personal data, provided that certain conditions are met,

  • Right to restriction of processing pursuant to Article 18 GDPR - i.e. the right to request the restriction of the processing of your personal data, provided that certain conditions are met,

  • Right to data portability pursuant to Article 20 GDPR - i.e. the right to demand that you receive your personal data that you have provided in a structured, common and machine-readable format and the right to transfer it to a third party, provided that certain conditions are met,

  • Right to object in accordance with Article 21 GDPR - i.e. the right to object to the processing of your personal data where the processing is based on our legitimate interests, provided that certain conditions are met.

  • Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating the GDPR.

1.4.     Data Erasure and Storage Duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage is deleted. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the processor is subject. Blocking or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

2.         Actual data processing

2.1.     Epic

You will need an Epic Account to use our game. When using the Peer to Peer Multiplayer Mode, Epic will use your Epic Account ID to connect you with another player. With respect to the Epic Account and the use of the Epic Account ID to connect with other players, the Epic Games, Inc. privacy policy applies.

2.2.     Storage of replays when using our game

(a)       Scope of data collection

When using our Game, we store replays of the individual matches. The following data is stored as part of the replays: map played, which keys were pressed, typing accuracy and typing speed, which player won and which player lost, when the game was played, and the Epic Account ID.

We use an external service provider based in the EU to store this data. We have concluded an data processing agreement with the external service provider.

(b)       Legal basis

The legal basis is Art. 6 para. 1 (a) GDPR.

The legal basis for the transfer of data to our external service provider is Art. 28 (3), GDPR.

(c)       Purpose of the data processing

The purpose is to improve the game. 

(d)       Duration of storage

Insofar as you have expressly consented to the storage of the replays, we delete or these only when you revoke your consent. The data of the consent will be deleted six months after receipt of the revocation.

(e)       Possibility of objection and deletion

You can refuse consent to the storage of replays when you first start the game. You can revoke your consent at any time in the options menu of the game.

2.3.     Support

(a)       Scope of data processing

You can contact our support via e-mail (support[at]pumpernickel-studio.com) to issue support requests and report bugs. In this case, your email address and the personal data that you send to us by e-mail will be stored.

The data is processed and stored by an e-mail provider we have commissioned with headquarters in Ireland, but the data is also stored outside the European Union in the United States of America.

(b)       Legal basis

The legal basis for the processing of data transmitted in the course of sending a support request or bug report via e-mail is Art. 6 (1) (b) GDPR. If the contact is aimed on another topic, the additional legal basis for the processing is Art. 6 (1) (f) GDPR.

The legitimate interest within the meaning of Art. 6 (1) (f) GDPR is to respond to a customer inquiry or to respond to a contact inquiry on other topics.

The processing by our email provider is based on Art. 28 (3), (6) and (7), Art. 46 (2) (c) DSGVO. The standard data protection clauses of the EU Commission are used in the contractual relationship with the provider with additional safeguards for European Union data subjects.

(c)       Purpose of the data processing

The purpose of the data storage is to contact you at your request, in particular for the purpose of support service.

(d)       Duration of storage

The data will be stored for as long as is necessary to process the inquiry. Insofar as these are commercial letters that must be retained in accordance with commercial and tax law, they will also be stored in accordance with the statutory retention periods.

(e)       Possibility of objection and deletion

You have the option to object to further use at any time. You can declare your objection by e-mail to: support[at]pumpernickel-studio.com. Data can only be deleted if there is no legal obligation to retain it; in this case, however, the data will be blocked for any other use. In the event of an objection, the conversation cannot be continued.

 

II.         U.S. Residents and other Countries

1.         About this policy

1.1.   This Privacy Policy describes the different ways we may collect, use, and share information through or in connection with Touch Type Tale (the “Game“ or “TTT“).  For information on our policies regarding the collection, use, and disclosure of information when you use the Pumpernickel website, please visit https://www.pumpernickel-studio.com/imprint.

1.2.     This policy also provides contact details and important information about your data protection rights.

 

2.         What player information do we collect?

The type of information we collect depend on how you interact with TTT.  For example, we do not automatically collect personal data by providing the application or through gameplay in singleplayer mode. But if you link your account to or access it via a third-party service, we and/or that service will collect information.

In general, the information we collect and generate relating to players may include:

  • Usage information (including a randomly generated identifier and basic details, game progress, achievements, preferences)
  • Analytics information (collected by third-party services and used to track usage , crash information)
  • Third-party information (if you link your account to or access it via a service like Epic, or interact with us on Discord)
  • Other content you create or provide (such as text chat or messages, videos, and images you share)

Please note that if we ask you to provide us with information and you choose not to, you may not be able to fully access TTT and/or some features may not operate as intended.

 

3.      How we use player information

We and our third-party service providers use information relating to players to provide, develop and promote TTT.  More specifically, we use players information to:

  • Provide and manage our games, including your use of our games
  • Improve our games (including by providing language, help and instructions)
  • Better understand how TTT is used (including checking crash reports that are shared with us and analysis of usage behaviors)
  • Manage alpha, beta or early access tests (including collecting feedback)
  • Provide customer service assistance, including responding to your correspondence or requests
  • Allow players to participate in certain multi-player features, including by:
    - Displaying leader boards, nicknames, and achievements
  • Detect and address security risks, hacking, cheating and other activities that harm the experience of our games
  • Detect fraud and other unlawful activity
  • Exercise legal rights and comply with legal obligations

When using our  Game, we store replays of the individual matches. The following data is stored as part of the replays: map played, which keys were pressed, typing accuracy and typing speed, which player won and which player lost, when the game was played, and the Epic Account ID.

We use an external service provider based in the EU to store this data. We have concluded a data processing agreement with the external service provider.

We use information that does not identify you (including information that has been aggregated or de-identified) for any purpose and without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

 

4.          Automated decision-making

We do not make any legally significant decisions about individuals based solely on automated decision-making.

 

5.         Sharing player information

We may share or allow third-party services to collect information through TTT. Depending on how you interact with the Game, common examples might include sharing:

  • With platform partners (to facilitate gameplay when you access TTT through a platform);
  • With other users (for example, rank and nickname will be shared in a multi-player session);
  • With third-party service providers that operate on our behalf (for analytics or if you submit a crash report);
  • When we believe we must in order to comply with the law or to protect you, Pumpernickel, or others (for example, in response to court order or subpoena, as part of an investigation of fraud or other illegal activity, or violation of our terms or policies, or if necessary to protect others from death or serious harm to body or property);
  • With your permission (for example, if you link an Epic Games account).
  • We may also share information that does not identify you with third parties, including aggregate or de-identified information.

You will need an Epic Games account to use our game.  When using the Peer to Peer Multiplayer Mode, Epic will use your Epic Account ID to connect you with another player. With respect to the Epic Account and the use of the Epic Account ID to connect with other players, the Epic Games, Inc. privacy policy applies.   Epic and any other third-party providers you interact with through TTT have different privacy practices than Pumpernickel, so we encourage you to review their privacy policies before sharing your information with them.

 

6.         Children

TTT is intended to be enjoyed by a general audience.  We do not knowingly collect or use any personal data relating to children (usually considered to be under the age of 13, depending on where you reside) without seeking any required parental approval in accordance with applicable legal and regulatory obligations.  If you are a parent or guardian and you believe that we have collected information from your child in a manner not permitted by law through TTT, we ask that you e-mail us at info[at]pumpernickel-studio.com. If we become aware that a child under 13 has provided us with personal data, we will take steps to remove the child’s information from our records to the extent required by law.

 

7.         International transfers

Your information, including personal data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Pumpernickel will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

 

8.          Data retention

Pumpernickel will retain your information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

 

9.         California Residents

The California Consumer Privacy Act or “CCPA” provides consumers residing in California certain rights with respect to their personal information. If you are a California resident, you may have the right to: (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

You or your authorized agent may make these requests by contacting us as described in “Contact Us” below.  Note that we may ask you for additional information to help us verify who you are before completing your request. If we receive your request from an authorized agent, we may ask for evidence that you gave that person authority to submit requests to exercise rights on your behalf.

We (or our service providers) collect the following categories of personal information, as described in the CCPA:

  • Identifiers (such as user name);
  • Other personal information (like billing address or payment card info);
  • Demographic information (like ages);
  • Commercial information (including achievements);
  • Internet or electronic network activity (for example, gameplay usage details);
  • Geolocation information (such as may be derived from your IP address);
  • Inferences drawn from any of these categories.

For details about the information we collect and the categories of sources where we got that information, please see “What player information we collect?” above. We collect personal information for the business and commercial purposes described in “How we use player information” above.

Pumpernickel does not sell the personal information we collect.  We will, however, disclose personal information as described in this policy to the following categories of recipients :

  • Business partners (for example, if you use account linking services or multi-player sessions);
  • Other users (for example, if you use multi-player matchmaking);
  • Service providers (as described in “Sharing player information?” above);
  • Government entities or other third parties in response to a legal request.

Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant.

You will not be treated differently or discriminated against for exercising any of your rights.

 

10.      Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

11.      Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: info[at]pumpernickel-studio.com