RealPool

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1) Introduction and controller contact details

1.1 We are glad you are visiting our website and thank you for your interest. Below we inform you about how your personal data is handled when you use our website. Personal data is any data by which you can be personally identified.

1.2 The controller for the processing of personal data on this website within the meaning of the General Data Protection Regulation (GDPR) is Rafael Wörner, Honigbart Studios, Konrad-Adenauer-Straße 18, 69221 Dossenheim, Germany, tel.: +4915679796569, e-mail: info@realpool.gg. The controller is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data.

2) Data collection when visiting our website

2.1 When using our website for information only — i.e. when you do not register or otherwise submit information to us — we only collect data that your browser transmits to the server (so-called "server log files"): the website visited, date and time of access, the amount of data sent in bytes, the source/referrer from which you reached the page, the browser used, the operating system used, and the IP address used (where applicable in anonymised form). Processing is carried out pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or otherwise used. We reserve the right, however, to check the server log files subsequently if there are concrete indications of unlawful use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content, this website uses SSL or TLS encryption. You can recognise an encrypted connection by the "https://" prefix and the lock symbol in your browser bar.

3) Hosting & content delivery network

To host our website and display its contents, we use a provider that delivers its services — itself or through selected sub-contractors — exclusively on servers within the European Union. All data collected on our website is processed on those servers. We have concluded a data-processing agreement with the provider that ensures the protection of our visitors' data and prohibits unauthorised disclosure to third parties.

4) Cookies

To make visiting our website appealing and to enable the use of certain functions, we use cookies — small text files stored on your device. Some are automatically deleted when you close your browser ("session cookies"); others remain on your device longer and allow page settings to be saved ("persistent cookies"). Where cookies also process personal data, processing is carried out pursuant to Art. 6(1)(b) GDPR to perform the contract, pursuant to Art. 6(1)(a) GDPR in the case of consent given, or pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website. You can set your browser to inform you about the setting of cookies and decide individually about their acceptance, or to exclude their acceptance generally. Please note that the functionality of our website may be limited if cookies are not accepted.

5) Contacting us

5.1 When you contact us (e.g. by contact form or e-mail), personal data is processed solely for the purpose of handling and answering your enquiry and only to the extent necessary. The legal basis for processing this data is our legitimate interest in answering your enquiry pursuant to Art. 6(1)(f) GDPR. If your contact is aimed at a contract, the additional legal basis is Art. 6(1)(b) GDPR. Your data is deleted once the matter has been conclusively resolved and provided no statutory retention obligations apply.

5.2 Brevo — For sending transactional e-mails, i.e. event-driven messages triggered by a specific user action (such as conclusion of a contract, registration or password reset), we use this provider: Brevo GmbH, Köpenicker Str. 126, 10179 Berlin, Germany. On the basis of our legitimate interest in effective and user-friendly e-mail communication, we pass on the data you provide when performing such a user action to this provider pursuant to Art. 6(1)(f) GDPR so that it handles the mail dispatch on our behalf. We have concluded a data-processing agreement with the provider that protects our visitors' data and prohibits disclosure to third parties.

6) Comment function

Within the comment function on this website, in addition to your comment, the time the comment was created and the commenter name you chose are stored and published on this website. Your IP address is also logged and stored — for security reasons and in case the person concerned violates third-party rights or posts unlawful content through a comment. We need your e-mail address to contact you should a third party object to your published content as unlawful. The legal bases for storing your data are Art. 6(1)(b) and (f) GDPR. We reserve the right to delete comments if third parties object to them as unlawful.

7) Data processing when opening a customer account

Pursuant to Art. 6(1)(b) GDPR, personal data continues to be collected and processed to the extent required when you provide it to us when opening a customer account. Which data is required for opening the account can be seen from the input mask of the relevant form on our website. You can delete your customer account at any time by sending a message to the controller's address stated above. After deletion of your customer account, your data is deleted, provided all contracts concluded thereunder have been fully processed, no statutory retention periods conflict, and we have no remaining legitimate interest in continued storage.

8) Use of customer data for direct advertising

8.1 Newsletter subscription — If you subscribe to our e-mail newsletter, we send you regular information about our offers. The only mandatory detail for sending the newsletter is your e-mail address; providing further data is voluntary. For newsletter dispatch we use the double opt-in procedure, ensuring you only receive the newsletter once you have expressly confirmed your consent by activating a verification link sent to the address provided. By activating the confirmation link you give us your consent pursuant to Art. 6(1)(a) GDPR; we store your IP address entered by your ISP and the date and time of registration in order to be able to trace possible misuse of your e-mail address at a later point. You may unsubscribe from the newsletter at any time via the link provided for this purpose or by a message to the controller named above.

8.2 Brevo — Our e-mail newsletters and other promotional e-mail communication are sent via this provider: Brevo GmbH, Köpenicker Str. 126, 10179 Berlin, Germany. On the basis of our legitimate interest in effective and user-friendly e-mail marketing, we pass on the data you provided on registration to this provider pursuant to Art. 6(1)(f) GDPR so that it handles the mail dispatch on our behalf. We reserve the right — solely on the basis of your express consent pursuant to Art. 6(1)(a) GDPR — to carry out a statistical performance analysis of mail campaigns using web beacons or tracking pixels in the sent e-mails, measuring open rates and specific interactions with the newsletter content. You can revoke your consent to mail tracking at any time with effect for the future. We have concluded a data-processing agreement with the provider.

9) Data processing for contract performance

9.1 To process the contract we work with the service provider(s) below who support us, in whole or in part, in performing concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

9.2 Use of payment service providers — Stripe. One or more online payment methods of the following provider are available on this website: Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. When you select a payment method of the provider in which you pay in advance (e.g. credit card), the payment data you provide during the order process (including name, address, bank and payment card information, currency and transaction number) and information about the content of your order is passed to the provider pursuant to Art. 6(1)(b) GDPR, solely for the purpose of payment processing and only to the extent necessary. Where a payment method involves the provider paying in advance (e.g. invoice or instalment purchase, or direct debit), you will also be asked to provide certain personal data during the order process, which may be forwarded to the provider pursuant to Art. 6(1)(f) GDPR for a credit check; such a credit report may contain probability values (score values) based on a scientifically recognised mathematical-statistical procedure. You can object to this processing at any time by a message to us or to the provider; however, the provider may remain entitled to process your personal data where this is necessary for contract-compliant payment processing.

9.3 Electronic cancellation option for continuing obligations with consumers. Consumers who have entered into contracts on this website for paid continuing obligations (e.g. subscription contracts) have the option to cancel these via an electronic button in accordance with the applicable cancellation periods. Activating the button leads to a confirmation page where the consumer can provide further details about the cancellation, clearly identify themselves and then declare their cancellation electronically. The collection of personal data and its transmission to us is carried out pursuant to Art. 6(1)(b) GDPR and only to the extent necessary for the proper handling of the cancellation; a further legal basis is Art. 6(1)(c) GDPR, as we are legally obliged to provide an electronic cancellation option for such contracts.

9.4 Electronic withdrawal function for distance contracts. Consumers who conclude contracts on this website for which a statutory right of withdrawal exists have the option to declare the withdrawal via an electronic withdrawal function in accordance with the applicable withdrawal provisions. When using the withdrawal function, in addition to details identifying the contract to be withdrawn, further personal information such as the consumer's first and last name and e-mail address must be provided or confirmed. The collection of this information and its transmission to us is carried out pursuant to Art. 6(1)(b) GDPR and only to the extent necessary for the proper handling of the withdrawal; a further legal basis is Art. 6(1)(c) GDPR, as we are legally obliged to provide an electronic withdrawal function for paid consumer distance contracts.

10) Rights of the data subject

10.1 Applicable data protection law grants you the following data-subject rights vis-à-vis us as the controller regarding the processing of your personal data, with reference to the cited legal basis for the respective conditions of exercise: right of access (Art. 15 GDPR); right to rectification (Art. 16 GDPR); right to erasure (Art. 17 GDPR); right to restriction of processing (Art. 18 GDPR); right to notification (Art. 19 GDPR); right to data portability (Art. 20 GDPR); right to withdraw consent given (Art. 7(3) GDPR); right to lodge a complaint (Art. 77 GDPR).

10.2 RIGHT TO OBJECT. IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST IN THE COURSE OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON GROUNDS ARISING FROM YOUR PARTICULAR SITUATION. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS. WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT-MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME; IF YOU DO SO, WE WILL CEASE PROCESSING THE DATA CONCERNED FOR DIRECT-MARKETING PURPOSES.

11) Duration of storage of personal data

The duration of storage of personal data is determined by the respective legal basis, the purpose of processing and — where applicable — additionally by the relevant statutory retention period (e.g. commercial and tax retention periods). Where personal data is processed on the basis of express consent pursuant to Art. 6(1)(a) GDPR, the data concerned is stored until you withdraw your consent. Where statutory retention periods exist for data processed under Art. 6(1)(b) GDPR, that data is routinely deleted after the retention periods expire, unless it is still required for contract performance or initiation and/or we have a remaining legitimate interest in continued storage. Where personal data is processed on the basis of Art. 6(1)(f) GDPR, that data is stored until you exercise your right to object under Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. Where personal data is processed for direct-marketing purposes under Art. 6(1)(f) GDPR, that data is stored until you exercise your right to object under Art. 21(2) GDPR. Otherwise, stored personal data is deleted once it is no longer necessary for the purposes for which it was collected or otherwise processed, unless the other information in this declaration about specific processing situations provides otherwise.

Additional notes for RealPool

The following notes supplement the general information above with the processing operations specific to the online service RealPool. In the binding German version they are a legally binding part of the privacy policy.

Game replays

For networked matches, the course of play is stored on the server as a replay. The replay contains the deterministic course of the match and a link to the accounts involved. The legal basis is Art. 6(1)(b) GDPR (performance of the usage contract), and additionally Art. 6(1)(f) GDPR for anonymous matches.

Upon an erasure request under Art. 17 GDPR, the link between the replay and your account is removed: the account identifiers in the indexed database are set to "empty" so the replay can no longer be attributed to you. The match itself remains in the corpus for the reproducibility of the game simulation, without personal reference.

Ranking rating (Glicko)

For ranked matches we compute a skill rating using the Glicko procedure (rating value, rating deviation and volatility per account) and a record of the ranked matches played. The legal basis is Art. 6(1)(b) GDPR.

While the rating is computed automatically, it does not constitute an automated decision in an individual case producing legal effects or similarly significant effects within the meaning of Art. 22 GDPR: it merely classifies playing strength within the service and has no legal or comparably significant external effect.

Table chat and moderation

During networked matches, short text messages can be exchanged via the table chat. To protect participants, messages are automatically pre-checked against a wordlist before delivery; messages classified as non-compliant are not delivered. Content-free moderation and restriction records are kept about rejected messages and graduated follow-up measures (action, time, match and sequence reference). Further details on the procedure are set out in section 9 ("Moderation and restriction of content") of the Terms and Conditions.

The legal basis for chat messages is Art. 6(1)(b) GDPR, and for the protective pre-check Art. 6(1)(f) GDPR. Upon an erasure request under Art. 17 GDPR, the content of your chat messages is emptied and the account link is removed from the chat and moderation records; the content-free records remain as evidence without personal reference.

Derived gameplay statistics

From ranked matches we derive gameplay statistics per account (such as features of individual shots and aggregated metrics). Matches from private rooms are not included; for individual accounts the statistical evaluation may be excluded. The legal basis is Art. 6(1)(f) GDPR.

Upon an erasure request under Art. 17 GDPR these statistics are not deleted but pseudonymised: the account link is replaced with a pseudonymous identifier. The data thus remains in the corpus in pseudonymised form, based on Art. 17(3)(d) in conjunction with Art. 89 GDPR (statistical purposes).

Backups

For disaster recovery, encrypted backup copies (database, replays and a technical key value) are kept with an object-storage provider outside the production system: Cloudflare Germany GmbH, Rosental 7, 80331 Munich, Germany. The backups are encrypted before upload; the provider holds encrypted data only. A data-processing agreement (including EU standard contractual clauses) is in place with the provider. The legal basis is Art. 6(1)(f) GDPR.

Since an erasure in the production system does not immediately reach backup copies already created, erased data may persist in encrypted backups for the duration of the backup cycle and is removed when the cycle is overwritten in due course.

Monitoring

External monitoring is currently disabled; if it is activated, a data-processing agreement will be concluded and an entry added to this privacy policy beforehand.

Recipients and processors

Within the scope of the purposes described above, personal data is passed to the following processors, with each of whom a data-processing agreement is in place: Hetzner Online GmbH (hosting and storage within the European Union), Brevo GmbH (transactional and promotional e-mail dispatch), and Cloudflare Germany GmbH (encrypted backups outside the production system).

The payment processing via Stripe Payments Europe Ltd. described in Section 9 of the privacy policy above, and the electronic cancellation option (Section 9.3), relate to the paid offerings (cosmetics shop, supporter membership). Until these are activated, no payment data is processed. Once activated, payment data is transmitted to Stripe solely for the purpose of payment processing.

Exercising your data-subject rights

You can trigger access (Art. 15 GDPR) and erasure (Art. 17 GDPR) for your account directly in the Account area via the buttons there ("Datenkopie anfordern" / request a data copy and "Konto-Löschung beantragen" / request account erasure). For other matters, the contact point listed at /legal/contact is available.