Privacy Policy - Games


Broken Pony Studios UG (haftungsbeschränkt)’s (“Broken Pony Studios” or “we”) team creates original and memorable experiences so that players can have fun, interact with other players, and find enjoyment through our games, applications, websites and online services (collectively hereinafter referred to as our “Services”).

​

We collect your personal data so that you can benefit from our Services and so that we can offer you an optimal experience.

​

This privacy policy is designed to help you understand how your data is used, inform you of your rights and how to exercise your rights.

1. What is personal data?

“Personal Data” (or “Data”), is all information that identifies you:

  • either directly, for example, your last name, first name, email address or telephone number;

  • or indirectly, for example your account ID, IP address, cookie identifier or game data.

For more information about the Data that Broken Pony Studios collects, go to Section 3 “When does Broken Pony Studios collect your Data and for what purpose?”.

2. Can minors access our Services?

If you are a minor, the age at which you can access certain of our services is determined by the data protection laws of your country of residence. You can find out more about this in the article on access to our services for minors in our Terms and Conditions .

3. When does Broken Pony Studios collect your Personal Data and for what purpose?

We may collect your Data when:

a)    You play our games for the first time and create an account (hereinafter referred to as your “Account”).

When you download our games, we collect the time, date and install source of your download along with your country code. When you first play our games, we may automatically generate a user ID (“Player ID”) that you can find in your in-game settings menu. We do not collect any other personal information such as your name, email address, date of birth unless you decide to share it with us (e.g. by changing your in-game name to your real name). Some items of Data, such as your assigned or chosen user name, are made public to allow other members of the game community to find you in our Services.

 

b)    You sign into our Services with a social login or your credentials from a third party platform (for example, Google Play, Apple Game Center).

Some of our Services may also allow you to connect your Account to third-party accounts such as your Google Play or Apple Game Center accounts to participate in social features and highscores.

If you connect your account to your Game Center account or other third-party accounts such as Google, we may collect your user ID for the third-party services and a login token that allows you to verify your identity without re-entering your credentials for third-party platforms as long as the token remains active.

Some of our Services allow you to create invitation links that you may send to your friends to connect directly via the Social Feature. 

 

c)     You make a purchase in our Services.

When you make purchases in our Services, we only collect Data about your transaction (such as transaction ID and timestamp) to authenticate your purchase. We do not collect or store any payment information such as your credit card number. When you make purchases with in-game currency within our Services, we only collect Data about purchase transaction types and spend you have made using virtual items in the Services.

​

d)    You use our games, applications, websites and online services on a computer or mobile telephone.

We collect:

  • Your game data, to improve your experience and the security of our Services such as: unlocked game progress, rewards, rankings, completed game missions, statistics including the game time or the use of the various features as well as the data associated with any bugs and malfunctions.

  • Your login data, to enable the operation and security of our Services, such as:, identifier of your device and the connection (IP address, MAC address), login dates and times, information concerning the device and the operating system you use.

We use various types of technologies such as cookies to collect such Data when you use our Services or visit a third party site where we and our partners provide content or carry out content use analysis.

We allow some of our partners to set and access their Cookies on your device. These partners’ use of Cookies is subject to their own privacy policies and not this Privacy Policy.

To refuse Cookies or request their deletion as well as obtain the list of partners who are permitted to store and/or access these Cookies, please contact us here.

Our Website Privacy Policy describes what data we process when you enter our websites.

 

e)     You interact with other players (forums, chat rooms, Broken Pony Studios social media pages).

We collect Data such as your public profile information (including but not limited to user name, location, avatar), the date, time, and we save the content of your messages to allow you to interact with other players in a secure environment.

 

f)    You are exposed to personalised advertisements or content on our Services or those of our partners.

We collect Data such as the advertisement and the number of times it was watched, its location in the Services and the identifier of your device. We also collect information about your actions in relation to the advertisement.

We can combine the Data collected with our partners when you use our Services. We may also combine this Data with demographic, advertising and market studies or with other analytic surveys.

We may also use all of your Data collected to offer you personalised advertisements, products, services or content (hereinafter referred to as “Personalised Content”) via our Services or those of our partners.

If you wish to withdraw your consent or object to the personalisation of advertisements, please go to Section 6 “What are your rights and how do you exercise your rights”, then to the paragraph “Give and withdraw your consent”.

 

g)    You take part in a contest or survey, or join a program, organised by Broken Pony Studios.

When you participate in a contest, survey or program, we may collect some of your personal data. Prior to collecting any Data for these purposes, we will inform you by means of a  privacy notice about the Data being collected and your rights.  

We use this Data to administer the contest, survey or program, to send you promotional offers and/or for internal statistical purposes.

In the case of contests and giveaways, via our social media pages, we may collect Data such as, but not limited to, your username, first name, last name, game account ID, as well as further information available on your public profile or which you may decide to share with us. Broken Pony Studios will only keep your Data for the time strictly necessary to operate the survey and in case of giveaways and reward you if you are a winner. 

 

h)      You contact our Community Management team via in-game chat, email, or social media.

If you contact us via in-game chat, we collect Data such as but not limited to your last name, first name, user name, country, device identifier, games and their respective progress registered on your Account,  as well as further Data you may decide to share with us, depending on your questions or requests.

By sending support requests via the chat system or email, you understand and agree with the transmission of the Personal Data required to process your support request.

If you contact us via social media, we collect some of the Data included on your public social media profile.

We only use this Data to appropriately analyze your concerns or identify related issues, and then to respond to your questions and requests.

 

i)      You do not comply with the rules of the game.

When you use our Services, you must comply with our Terms and Conditions and the codes of conduct associated with our Services which are intended to protect our users, employees and more generally Broken Pony Studios' rights. If you do not abide by these rules, you may be sanctioned including in the event of inappropriate conduct, cheating or toxic behaviour. We will keep your Data for the time needed to apply these sanctions. This Data may include for example your Account identifier, your game data, your IP address, the identifier of your device and your chat history. 

4. How long does Broken Pony Studios keep your Personal Data?

Unless the law specifies a different retention period, Broken Pony Studios will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected by Broken Pony Studios.

For example, we will keep the Data associated with your Account until the closure of the Account. In some cases, the Data may be kept for a longer period such as when it is needed for us to apply a sanction.

5. How does Broken Pony Studios share your Personal Data?

We may share your Data with:

  • The technical service providers involved in the supply of the Services (for example, product delivery, promotion of the Services, to act against inappropriate conduct, cheating and toxic behaviour). As subcontractors, these service providers are under the same obligations as Broken Pony Studios to comply with applicable personal data protection laws.

  • The partners who use your Data to provide you with personalised advertisements or Personalized Content.

    • To consult a list of Broken Pony Studios' partners, please contact us here.

    • To opt out of the sharing of your Data, please Section 6 “What are your rights and how do you exercise your rights”, then to the paragraph “Give and withdraw your consent”.

  • Other companies, only in the event of transfer of Broken Pony Studios' activities.

  • Administrative or judicial authorities, to verify the proper use of the Data by Broken Pony Studios or for the purposes of an investigation, in compliance with applicable law. Broken Pony Studios always verifies the legitimacy of the request.

In such cases, your Data may be transferred to countries located outside of the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of your Data is especially ensured by the signature of standard contractual clauses approved by the European Commission.

6. What are your rights and how do you exercise your rights?

Obtain a copy of your Data – “Right of access and data portability”

At any time you can request a copy of the Data associated with your Account. You may also consult the Data, use it yourself or transfer it to another service provider. 

If you have been sanctioned in relation to our Services, we will not be able to give you access to the Data regarding your sanction so as to maintain our ability to detect or take action against such behaviour.

 

Correct your Data – “Right to rectification”

You have the right to correct your Data when it is inaccurate or incomplete (for example, change your delivery address).

 

Give and withdraw your consent – “Right to object and withdraw your consent”

At any time, you may withdraw your consent or object to the receipt of newsletters or advertising emails, the personalisation of advertisements or the sharing of your Data with our partners:

  • for some of our mobile games, in the privacy settings,

  • on your telephone or your tablet, in the settings, by activating “Limit Ad Tracking” on Apple telephones, or activating “Opt-out of Ads Personalisation” on Android telephones.

​

Delete your Account – “Right to erasure (right to be forgotten)”

You can request the closure of your Account and the deletion of the associated Data.

If you have been sanctioned in relation to our Services, we cannot delete the Data regarding your sanction as to allow us to maintain your sanction. 

 

Limit the use of your Data – “Right to restriction of processing”

You also have the right to request that your Data no longer be used or not be deleted during the time we are processing your request. To do so, please contact the Broken Pony Studios Customer support department here.

 

To exercise any of your above rights or for any question regarding the exercise of these rights, you can contact the Broken Pony Studios Data Protection officer and their team at any time here.

If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the regulatory authority in your country.

7. When can Broken Pony Studios use your Data?

We can use your Data in one of the following circumstances:

  • Broken Pony Studios' legitimate interest (or reasonable expectations of users), to offer you the best possible user experience, such as to ensure the security of the Services, moderate the community, respond to your requests and questions or to send you newsletters.

  • Your consent to offer you advertisements, products, services or personalised content depending on your user profile.

Broken Pony Studios is entitled to change this policy at any time. We will inform you of the material updates and recommend that you consult this policy on a regular basis or contact us if you have any questions. Using our Services following such a change means that you accept any changes.

8. Contact

If you have any questions about this document, please contact:

  • The Data Protection Officer and their team here.

  • By mail: Broken Pony Studios UG (haftungsbeschränkt) (data controller), Zollernweg 3, 78628 Rottweil

For any other questions, including if your question relates to a problem with online payment or the use of our products and Services, please contact our Community team.

 

Updated: September 2nd, 2024