Privacy Policy Facebook Instant Games
CELLSOFT respects and protects your personal data.
CELLSOFT collects, processes or uses personal data exclusively within the applicable legal framework. Therefore, the high data protection level of the General Data Protection Regulation (GDPR) holds true.
1. Field of application
We develop games ("Facebook Instant Games") that are available on the social network Facebook, a platform provided by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). In this privacy policy we inform you on the collection, processing and use of data concerning the Facebook Instant Games.
Insofar as individual services of CELLSOFT have different privacy policies, these apply.
The Facebook Instant Games can only be accessed via the Facebook network, which is operated solely by Facebook, and only if you have registered for the Facebook network and are logged in to your Facebook account. The processing of data by Facebook when you register your Facebook account and every time you access the Facebook network is excluded from the field of application of this privacy policy. Likewise, cookies that Facebook may use for statistical evaluations when you access the Facebook platform are not within this privacy policy's scope. Facebook organizes the aforementioned data processing independently and on its own responsibility, without us having any influence on this. For further information on this data processing by Facebook see the Facebook's privacy policy: https://www.facebook.com/privacy/explanation.
2. Data processed when accessing and using the Facebook Instant Game
When you first access one of our Facebook Instant Games, Facebook will assign you one unique ID per Facebook Instant Game (the "Facebook Instant Game ID"), which is linked to your personal information, and will disclose this ID to us. Facebook also provides us with the first name you have entered in your Facebook account, your profile picture, the language selected, and the country you are playing from. Further, Facebook checks which other Facebook users, with whom you are connected on Facebook (so-called Facebook friends), have already played the respective Facebook Instant Game and notifies us of the results. CELLSOFT receives and uses the Facebook Instant Game ID and the other aforementioned data solely to create your player profile in the Facebook Instant Game to the extent necessary for using the game. Hence, the data processing in this context is carried out for the purpose of performing the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.
We would like to point out that CELLSOFT does not receive any additional personal data from your Facebook user account. CELLSOFT will not use the data to identify you or to create user profiles for purposes other than providing the Facebook Instant Games.
If you want to have the aforementioned data on you including the player profile deleted, you can, for example, send an email to contact.pegasus.ig@gmail.com. In order to be able to identify the data concerning you for deletion, we need your Facebook Instant Game ID. Please note that it is not possible to use the Facebook Instant Games without such a player profile. If you use our Facebook Instant Games again after deletion of your player profile, a new player profile will be set up for you.In order for you to access and play the respective Facebook Instant Game including all game functions, CELLSOFT collects and processes data on the use of the Facebook Instant Game (data on game progress such as completed levels, owned skins and player aids used, high scores achieved, ongoing and paused game sessions). This data is linked to the Facebook Instant Game ID and added to your player profile by CELLSOFT. The processing of this data for the use of the Facebook Instant Game is carried out for performance the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.
CELLSOFT does not receive any further personal data of your Facebook account and is not able to identify you via the Facebook Instant Game ID. CELLSOFT will not use this data to create user profiles for any other purpose than to provide the Facebook Instant Games.Each time you access a Facebook Instant Game, Facebook automatically logs your gender, age and the country you are located in while playing. Facebook collects this information as part of an analytics function to provide CELLSOFT with reports and analyses on the general use of the games, based on which CELLSOFT can gain insights for possible improvements and further developments of the Facebook Instant Games. As CELLSOFT only offers the Facebook Instant Games in the network operated by Facebook and therefore has no general access to the Facebook network, CELLSOFT generally does not obtain any information on Facebook user accounts or other data that would allow conclusions to be drawn about the identity of individual players. The only exceptions to this are the data mentioned in Sect. 2.1, which CELLSOFT only obtains and uses to create player profiles. Also, CELLSOFT will not merge the data from the analytics function with other data about individual players, in particular not with the data mentioned in Sect. 2.1.
At the beginning and during a game, Facebook will also collect information about your game session, such as the respective Facebook Instant Game, the language used, the beginning and end of a game session, how you accessed and started the game, what elements and levels of the game you use, whether you successfully completed a level, and, if applicable, the number of other players. CELLSOFT analyses this data and uses the insights from these evaluations to further develop and optimise the design of the Facebook Instant Games. However, CELLSOFT only processes the Facebook Instant Game ID in connection with these evaluations of the game sessions and does not process any data from the player profiles which could provide information about the identity of individual players. It is therefore not possible for us to attribute the analysed data about the game sessions to individual persons. We also do not create profiles of individual players from these evaluations of game sessions, nor do we link these evaluations with data from the analytics function.
The data processing in connection with the above analyses of general game use and game sessions is based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR, which consists in the continuous improvement of our games to ensure the best possible, entertaining gaming experience. For such adjustments based on user experience, we need to know the actual use of the games.Furthermore, Facebook uses the aforementioned, recorded information independently and on its own responsibility for its own, individual purposes and also collects and processes additional data including information from your Facebook account for these purposes, without us being involved or having any influence on this. Details of this use of your personal data are explained in the Facebook privacy policy, which you can view under https://www.facebook.com/privacy/explanation.
We would like to point out that data processing by Facebook can also take place outside the EU or the European Economic Area, in particular on Facebook servers located in the United States. This can result in risks for the users, because, for example, the enforcement of the users' rights could become more difficult. In this particular case, Facebook and we guarantee that appropriate protection measures are in place in accordance with Article 44 et seq. GDPR. In particular, Facebook and we have agreed on the standard data protection clauses of the EU Commission as a precautionary measure which provide for appropriate protection measures for the specific case, such as encryption of the data, in accordance with Article 46 (2) lit. c) GDPR. The measures are also continuously developed and supplemented to the extent necessary to ensure an adequate level of data protection throughout.
3. Facebook Audience Network
Our Facebook Instant Games implement the so-called Facebook Audience Network, a service of Facebook for serving advertisements. This service is used by Facebook to display advertisements in our Facebook Instant Games. When an advertisement is to be displayed in a Facebook Instant Game or clicked on, Facebook will record notably your interaction with the advertisement, your IP address and, if applicable, your further usage behaviour after the click on the advertisement. Facebook processes this information in order to measure the success of the respective advertising and to provide us with excerpts of the results. However, Facebook only provides CELLSOFT with access to aggregated data on the results of the advertising feed, which CELLSOFT cannot trace back to individual persons. Besides, CELLSOFT only receives excerpts of data in the context of the advertisements that cannot be attributed to individual persons. In particular, CELLSOFT does not receive and process any IP addresses or cookies from user devices or other data that allow conclusions to be drawn about the identity of individual users.
Facebook autonomously decides on the specific advertisements that are displayed in each case and on the processing of your personal data in the context of selecting and playing these advertisements. CELLSOFT can only exclude certain categories, in particular sensitive categories (such as depictions of violence, politics, religion) by choosing between default settings. Facebook uses this information to display the advertisements: which specific Facebook Instant Game you are playing, information about your usage behaviour in the Facebook social network and your interaction with other content in the Facebook network, as well as information that you have entered in your Facebook account. Facebook also uses cookies for this purpose. Further information on the data processing by Facebook regarding the Facebook Audience Network can be found at https://www.facebook.com/ads/about/?entry_product=ad_preferences and is explained in the Facebook privacy policy: https://www.facebook.com/privacy/explanation.
You will only receive personalised advertising via Facebook Audience Network if you have consented to this in your Facebook settings. The legal basis is therefore Art. 6 (1) (a) GDPR. Of course, you can withdraw your consent at any time for the future by changing your Facebook settings under the following link: https://www.facebook.com/ads/preferences. Please note that we can only provide the Facebook Instant Games free-of-charge with advertising funding. This means that even if you do not consent to receive personalised advertising, you will still see ads in Facebook Instant Games, but they will not be personalised, i.e., they will not be tailored to your personal interests. We have a legitimate interest in displaying advertisements in our Facebook Instant Games in order to generate revenue and thereby offer our games to you for free. There is also no indication that your interest in not receiving advertising through Facebook Audience Network is prevailing when you voluntarily play our Facebook Instant Games for free. The associated data processing is therefore justified in accordance with Art. 6 (1) (f) GDPR.
The data processed within the Facebook Audience Network can be transferred to Facebook servers, which are also located in the United States. We have concluded the standard data protection clauses adopted by the EU Commission with Facebook for transferring data by the Facebook Audience Network, having included the implementation of appropriate protective measures. Facebook and we also regularly review the need for possible additions and, if necessary, the implementation of additional appropriate protection measures within the meaning of Article 44 et seq. GDPR, to the extent as this is necessary to continuously grant a suitable level of data protection.
4. Usage analysis via Firebase
The Instant Game implements functions of the Firebase service, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
Data on the general use of the Instant Game are collected and evaluated via the Firebase service (so-called Google Analytics for Firebase). For these purposes, information on whether and how you use certain parts of the Facebook Instant Games is collected together with the IP address, a hash of your Facebook Instant Game ID 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 Instant Game. At no time will personal data from your player profile, such as your username and Facebook Instant Game ID, be transmitted to Google in clear text.
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 Instant Game, in order to use this information to improve the content and functions of the Instant Game 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 anonymous user-id. Nevertheless, it is not relevant for CELLSOFT which User used the respective Instant Game and to what extent. It is therefore not a matter of creating user profiles for CELLSOFT but rather of providing functional Instant Games through the analysis of aggregated reports from Google. Google may also transfer these data to servers operated by Google LLC in the USA and analyse 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.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.
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.
We only use Firebase for the data analysing purposes described above, if you consent to it via your Facebook settings. 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.
5. Storage period and erasure of data
We process your personal data as long as it is necessary to achieve the purposes of the processing, or is prescribed by a legal obligation to store the data. Subsequently, the data is deleted in accordance with statutory laws.
Data that we store for legal reasons, however, is stored for as long as this is required by law. After expiry of a statutory retention period, the data will be deleted without undue delay, unless there are other reasons within the meaning of Art. 17 (3) GDPR opposing the deletion.
6. Data security
CELLSOFT has taken appropriate technical and organisational measures to protect personal data against accidental loss, damage, unauthorised access or unauthorised changes. In particular, CELLSOFT will transmit data only in encrypted form. However, CELLSOFT points out that privacy and data security cannot be guaranteed for transmissions outside CELLSOFT's sphere of influence.
7. Transmission to Third Parties
Personal data will only be passed on to third parties - unless otherwise set out elsewhere in this privacy policy - without the express consent of the user, if this is necessary for the provision of CELLSOFT's services or for contract execution with the user (e.g. for the technical provision of the offer, see Sect. 7.2). Accordingly, the data are transmitted to such service providers (such as technical service providers) in our legitimate interests pursuant to Art. 6 (1) (f) GDPR, namely to provide access to our Facebook Instant Games. Of course, before passing on the user's personal data, CELLSOFT ensures that the relevant service provider has taken appropriate technical and organizational measures to ensure the security of the data.
We store the data collected by us in the context of access and use of the Facebook Instant Games (i.e. data of the player profile including Facebook Instant Game ID, first name, profile picture, language, country, friends who also play the game, and data on the use of the game such as game progress and completed levels, used skins and player aids and achieved high scores) via third party services. We use the Alibaba Cloud service, provided by Alibaba Web Services ("Aliyun"), and the Google Cloud and Google Firebase services, both provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). These services also record the IP address of your device when you use the Facebook Instant Games and store it for a maximum of 30 days. However, CELLSOFT does not receive the IP addresses directly and only exceptionally obtains insight into IP addresses recorded by these services and only if a valid legal basis exists, in particular if this is necessary to protect the legitimate interests of CELLSOFT. Aliyun and Google also transfer the collected data to their servers in the United States. We use these services to provide the aforementioned data for playing the Facebook Instant Games efficiently and with the lowest possible susceptibility to errors, thus ensuring the smooth use of the game functions. The legal basis for the associated data processing is Art. 6 (1) (f) GDPR, whereby our legitimate interest is an optimal, technically flawless provision of the Facebook Instant Games. We have concluded the standard data protection clauses adopted by the EU Commission with Google and Aliyun to safeguard the transfer of data to the USA. We have also concluded a data processing agreement with Google and Aliyun. The forwarding of personal data to Google and Aliyun in connection with the aforementioned services is therefore based on Article 46 (2) lit. c) and 28 GDPR.
Otherwise, CELLSOFT will not pass on the user's personal data to third parties unless the user has expressly consented to the transfer (Art. 6 (1) (a) GDPR), or CELLSOFT is entitled or obliged to do so by legal provisions or court orders. In the latter case, the transmission is carried out by CELLSOFT to fulfil a legal obligation pursuant to Art. 6 (1) (c) GDPR.
8. User rights
1. Right to object
The user has the right to object at any time to data processing based on Art. 6 (1) (e) or (f) GDPR for reasons arising from his particular situation, unless CELLSOFT can prove compelling reasons worthy of protection, which outweigh the interests of the user, or the processing serves to assert, exercise or defend legal claims. The user can object to data processing for the purpose of direct advertising at any time without special reasons being required.
2. Right to information
The user has the right to obtain free of charge from CELLSOFT the personal data stored by CELLSOFT concerning him or her, the processing purposes, their origin, which transfer to which recipients or categories of recipients took place, the storage period and the rights of the data subjects available to him or her.
3. Right to correction, deletion and/or restriction of data processing
Furthermore, the user has the right to request at any time the correction of incorrect data, the deletion and/or restriction of the processing of personal data stored about him or her, insofar as there is no legal obligation for CELLSOFT to keep records or other reasons in the sense of Art. 17 (3) GDPR which prevents deletion. Insofar as this includes personal data that is necessary for the provision of services to the user, the deletion or restriction of the processing of this data can only take place when the user no longer uses CELLSOFT's services.
4. Right to data portability
If the user provides data relating to him or her and CELLSOFT processes such data on the basis of the user's consent or in order to fulfil the contract, the user may request that he/she receives such data in a structured, current and machine-readable format from CELLSOFT or that CELLSOFT transmits such data to another controller, insofar as this is technically possible (so-called right to data portability).
5. Right to revoke consent
Any consent given by the user to the use of personal data can be freely revoked by the user at any time with effect for the future.
6. Right to complain to a supervisory authority
The user may also lodge a complaint with a supervisory authority against data processing which he or she considers to be in breach of the statutory provisions.
9. Changes to the Privacy Policy
CELLSOFT reserves the right to change this privacy policy at any time, while CELLSOFT will always comply with the legal requirements of data protection. Therefore, CELLSOFT recommends that users regularly take note of the applicable privacy policy. CELLSOFT will inform users in advance of any further use of data, for example via in-game notification or so-called push notifications in your browser, if you allow such push notifications.
10. Adult
To delete the data collected by our Applications and Games in Facebook, you will need to follow the instructions. Please go to here privacy management tool for Facebook applications and here privacy management tool for Facebook Instant Games. After that, check the game you want to delete data and select Remove; if you want to delete all of data that is relevant to your Facebook account, please check the box Delete posts, videos or events that “name of the game you select” posted on your timeline.
11. Contact us
To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.
In relation to the Facebook Instant Game:
Data Protection Officer, responsible for the management and safety of your personal information
contact.pegasus.ig@gmail.com
This document was last updated on December 13, 2021
