Privacy Policy - Website


1.    AN OVERVIEW ON DATA PROTECTION

1.1  General information about this privacy policy

We take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy.
The term „personal data” (or “Data”) comprises all data that can be used to personally identify you, either directly (such as your first and last name, your email address or your telephone number), or indirectly (such as cookie identifier or technical data).
The following information will provide you with an overview of which personal data, how it is collected as well as the purposes we use this Data for when you visit this website.

1.2  Data Recording on this Website

How do we record your Data?
We collect your Data as a result of your sharing of your Data with us. This may, for instance, be information you enter into our contact form or information you provide in connection with job applications.
If you opt-in to cookies and tracking, our IT systems automatically record other Data upon visiting our website. This Data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed).
For more information regarding cookies and opt-out options, please consult section 4.2 of this Privacy Policy.
What are the purposes we use your Data for?
We can use your Data for the following purposes:

  • The existence of a contract between you and Broken Pony Studios UG (haftungsbeschränkt) to provide you with Services. You enter into this contract with Broken Pony Studios UG (haftungsbeschränkt) by accepting the Terms and Conditions of our Services.

  • Broken Pony Studios UG (haftungsbeschränkt)’ 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 personalized content depending on your user profile.

Broken Pony Studios UG (haftungsbeschränkt) 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.
How long do we keep your Data?
Unless the law specifies a different retention period, we will only keep your Data for the time necessary to carry out the operations for which the corresponding Data has been collected.
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 we have a legal obligation to keep the Data.

2.    GENERAL INFORMATION

The responsible party (referred to as the „controller” in the GDPR) is the natural person or legal entity that single handedly or jointly with others determines  purposes of and resources for the processing of personal data.
The controller according to data protection laws is:
 
Broken Pony Studios UG (haftungsbeschränkt)
Zollernweg 3
78628 Rottweil

If you have any questions or suggestions about data protection, you can send us an email at business@brokenponystudios.com Our data protection officer can be reached here.

3.    HOSTING

This website is hosted by an external service provider: https://www.squarespace.com. Personal data collected on this website are stored on the servers of Squarespace. These may include, but are not limited to, IP addresses, metadata and communications, contact information, names, web page access, and other Data generated through a website.

Squarespace is used for the purpose of fulfilling the contract with our potential and existing customers and in the legitimate interest of secure, fast and efficient provision of our online services by a professional provider.

Our host will only process your Data to the extent necessary to fulfil its performance obligations, in compliance with our instructions with respect to such Data.

4.    COLLECTION AND USE OF YOUR DATA

4.1  Server log files

When you visit our website, we collect and store information in server log files, which your browser communicates to us automatically, if cookies are being used. The information could comprise:

  • The type and version of browser used

  • The used operating system

  • Referrer URL

  • The hostname of the accessing computer

  • The time of the server inquiry

  • The IP address

This Data is not merged with other Data sources.

This Data is recorded on the basis of a legitimate interest in the technically error free depiction and the optimization of the operator’s website.

4.2 Cookies

If you opt-in to cookies and tracking, we use cookies to offer you a range of features and to make our websites more convenient to use. Cookies are small files that your web browser stores on your computer when you visit our website. You can opt-in and -out of cookies at any times by clicking on the corresponding on- and off icons in the overview below if any cookies are being used:

Essentials

  • None, as of yet

Statistics

  • None, as of yet

External Media

  • None, as of yet

Alternatively, you can always opt-out of non-essential cookies by clicking on “Your Cookie Settings” in the footer of our website, if cookies are being used.

Please note that these settings may reduce the functionality of our site.

4.3 Support Requests

If you contact us by e-mail or telephone, we collect Data such as your name and the contents of your request.

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

4.4 Plug-ins and Tools

4.4.1. YouTube

This website embeds videos of the website YouTube. The website operator is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

If you visit a page on this website into which a YouTube has been embedded, a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified about which of our pages you have visited.

Furthermore, YouTube will be able to place various cookies on your device. With the assistance of these cookies, YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud. These cookies will stay on your device until you delete them.

If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

The use of YouTube is based on our legitimate interest in presenting our online content in an appealing manner. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on this basis; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under:
https://policies.google.com/privacy?hl=en.

4.4.2. Google Web Fonts

To ensure that fonts used on this website are uniform, this website uses so called Web Fonts provided by Google. When you access a page on our website, your browser will load the required web fonts into your browser cache to correctly display text and fonts.

To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. The use of Google Web Fonts is based on our legitimate interest in presenting our online content in a uniform and appealing way.

If your browser should not support Web Fonts, a standard font installed on your computer will be used. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.

4.4.3. Google Maps

Via an API, this website uses the mapping service Google Maps. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.

We use Google Maps on the basis of our legitimate interest to present our online content in an appealing manner and to make the locations disclosed on our website easy to find.

4.4.4. Google reCAPTCHA

We use „Google reCAPTCHA” (hereinafter referred to as „reCAPTCHA“) on this website. The provider is Google Ireland Limited („Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g. information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g. IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

The data is processed on the basis of the website operator’s legitimate interest, to protect the web content against misuse by automated industrial espionage systems and against spam.

For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms of Use under the following links:
https://policies.google.com/privacy?hl=en and
https://policies.google.com/terms?hl=en.

4.5 Newsletter

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent. You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the „Unsubscribe” link in the newsletter.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our legitimate interest in complying with the legal requirements when sending newsletters. The storage in the blacklist is indefinite. You may object to the storage by sending an email to business@brokenponystudios.com

4.6 Job Applications

We offer website visitors the opportunity to submit job applications to us.  We assure you that the collection, processing and use of your Data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

To contact you directly, we may also receive information collected by our Talent acquisition partners on professional social networks. We have a legitimate interest in processing your information to propose you suitable job offers. Unless you object by return email or message, your contact details and profile information will be kept for two years in our candidate pool and will be accessible by our teams. It may be transferred to countries outside the European Union that ensure an adequate level of protection according to the European Commission or within the framework of the standard data protection clauses adopted by the European Commission (available here).

By submitting your application via our careers page, you understand and agree with the transmission of the personal data required to process your job application.

In particular, you understand that data may be transferred outside of the EU, to a country that is not offering the same level of protection of your personal data. In this context, the protection of your Data is especially ensured by an agreement with our partners under the Standard Contractual Clauses, approved by the European Commission.

The processing of your data is necessary to carry out actions before an employment contract can be concluded with Broken Pony Studios UG (haftungsbeschränkt).

Your data may be transferred to non-EU countries that provide an adequate level of protection according to the European Commission, or under the standard privacy clauses adopted by the European Commission (available here.).

Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.) required to make a decision concerning an employment relationship.

The legal grounds for the corresponding data processing are Negotiation of an Employment Relationship (§ 26 BDSDG-neu), General Contract Negotiations (Article 6 Sect. 1 lit. b GDPR) or your consent. You may revoke your consent at any time.

If your job application should result in a recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG-neu and Article 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our IT-systems.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the Data you have submitted on the basis of our legitimate interests for up to 2 years from the end of the application procedure. Afterwards the data will be deleted, and any physical application documents will be destroyed.

Longer storage may also take place if you have given your consent or if statutory data retention requirements preclude the deletion.

Admission to the applicant pool

If you apply to us via our website, you consent to be included in our applicant pool. All documents and information from the application will then be transferred to the applicant pool in order to contact you about further suitable vacancies.

The data from the applicant pool will be irrevocably deleted after 2 years in case you consent to an extended archiving period.

Admission to the applicant pool is based exclusively on your express consent which you grant us at the time of application.

You can revoke your agreement at any time. For that, please contact us under business@brokenponystudios.com. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

You can request a copy of your data, its deletion or rectification, object to the processing of your data, request the restriction of its processing and receive your information in portable form. For more information about your rights and how to exercise them, please refer to section 6 YOUR RIGHTS below.

5.    DISCLOSURE OF DATA

We may share your Data with:

  • The technical service providers involved in the supply of the services. As subcontractors and joint data controllers, these service providers are under the same obligations as ourselves to comply with applicable personal data protection laws.

  • The partners who use your Data to provide you with personalized advertisements or Personalized Content. For more information about these partners and your opt-out options, please contact us at business@brokenponystudios.com

  • Other companies, only in the event of a transfer of our activities.

  • Administrative or judicial authorities to verify the proper use of our services or for the purposes of an investigation, in compliance with applicable law. We always verifiy 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 agreements with our partners under the Standard Contractual Clauses, approved by the European Commission.

6.    YOUR RIGHTS

 

In case you have questions about this Privacy Policy or want to exercise your rights as described below, please contact us via email at business@brokenponystudios.com.

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

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

6.2  Correct your Data – “Right to rectification”

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

6.3  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.

6.4  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.

6.5  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 and advertising emails, the personalization of advertisements or the sharing of your Data with our partners (except for technical service providers):

  • For email advertising directly by following the information provided in our newsletters

  • On our “Your Cookies Settings” page in the footer of our website to manage your Cookies preferences.

  • Or by email request to business@brokenponystudios.com.

We will not discriminate against and, therefore, not deny requests without legal reason, provide a different level of service or charge different prices to players that choose to exercise their rights.
If you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the competent supervisory authority. For the state of Baden-Württemberg, the competent authority is:
Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart


Interne_Meldestelle@lfdi.bwl.de

7.    SSL AND/OR TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from „http://“ to „https://“ and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, Data you transmit to us cannot be read by third parties.

8.    CHANGES TO THIS DATA PROTECTION POLICY

We reserve the right to update this Privacy Policy, if necessary, in compliance with the applicable Data protection regulations. This way, we can adapt it to the current legal requirements and take changes in our services into account, e.g. when introducing new services. The most current version always applies to your visit.
The current version of this Privacy Policy is always available at /website-privacy-policy/

Updated: June 24th, 2021