PRIVACY POLICY FOR KINETARIUM 

 I. General information 

  

1. Responsible body, introduction 

We are  

halbautomaten Kommunikationsdesign GmbH 
Silberburgstraße 183, 70178 Stuttgart, Germany

and you can reach us by post or e-mail at hello@halbautomaten.com. 

 

The protection of your privacy is very important to us. We therefore explain below which personal data we collect and process when you use our services or make use of our offers. Personal data is individual information about the personal or factual circumstances of an identified or identifiable natural person. This includes, for example, the name, e-mail address or telephone number. 

 

The collection, processing (including storage, modification, transmission, blocking and deletion) and use of your data is carried out in compliance with the provisions of data protection law. Personal data is only collected, used and passed on if this is permitted by law or if the users give their consent to the collection of data and if this is technically or legally necessary for the provision of the service. Under no circumstances will the data collected be sold or unlawfully passed on to third parties for any other reason. 

 

2. Legal basis 

We collect and process personal data based on the following legal bases: 

- Consent pursuant to Article 6(1)(a) of the General Data Protection Regulation (GDPR). Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her 

- Necessity to fulfill the contract or to carry out preparatory measures in accordance with Article 6(1)(b) GDPR, i.e. the data is necessary so that we can fulfill our contractual obligations towards you or we need the data to prepare the conclusion of a contract with you. 

- Processing for the fulfillment of legal obligations pursuant to Article 6 (1)(c) GDPR, i.e. that e.g. processing of the data is required by law or other regulations. 

- Processing for the purposes of legitimate interests in accordance with Article 6(1)(f) GDPR, i.e. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. 

We store and access information in your terminal equipment based on the following legal bases: 

- Consent pursuant to Section 25 (1) of the Telecommunications Digital Services Data Protection Act (TDDDG). 

- absolute necessity according to Section 25 (2) no. 2 TDDDG, so that we can provide a digital service expressly requested by you. 

  

3. Rights of data subjects 

You are entitled to the following rights with regard to data processing by us to the extent specified in the respective articles of the General Data Protection Regulation: 

  • - Right of access in accordance with 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 to rectification pursuant to Article 16 GDPR - i.e. the right to obtain without undue delay the rectification of inaccurate personal data concerning you, including the completion of incomplete data,

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

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

  • - Right to data portability in accordance with Article 20 GDPR - i.e. the right to request that you receive the personal data you have provided to us in a structured, commonly used and machine-readable format and the right to transmit those data to a third party, provided that certain conditions are met,  

  • - Right to object under 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 certain conditions are met.  

 

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. 

 

4. Data erasure and storage duration 

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract or you have expressly consented to the further use of your data. 

 

II. Specific data processing 

1.Analytics 

a) Scope of data processing 

As part of the use of our game, we use analytics functions to enable you to access the game smoothly and to continuously improve your gaming experience as well as to review license compliance. This software collects information about how you use the game and uses it to compile various statistics. The usage data collected includes in particular the country of origin, the installed operating system, the language settings, version of the software, name of the games played, ShowURL, duration of each game, number of players, number of NPC bots, game results, geolocation based on IP address, IP address.  

We use services (Unity Analytics) from Unity Software Inc. to process this data. Unity Software Inc. is based in the United States of America and describes its data processing under this link: https://docs.unity.com/ugs/en-us/manual/analytics/manual/privacy-overview.  

b) Legal basis 

The legal basis for the processing of the data for use for analysis purposes is Art. 6 (1)(a) and f GDPR and Section 25 (1) TDDDG. The legal basis for the transfer of data to Unity Software Inc. is Art. 28 (3), (6) in conjunction with Art. 46 (2)(c) GDPR by means of the standard contractual clauses of the EU commission (SCC). The legitimate interest is to use the IP address and the geolocation to verify license compliance in particular for test versions of the game.  

c) Purpose of the data processing 

The purpose of analysing user behaviour is to optimize and troubleshoot the game offering with regard to the expectations and use by clients and to ensure that the game runs smoothly as well as verification of compliance with license limitations (e.g. location based licenses or limitations on tests versions of the game).  

d) Duration of storage 

The processed data will be stored by us until you withdraw your consent. Data no longer required for license compliance reviews will be anonymized by shortening the respective IP addresses. In case no compliance breach is found, such anonymization will be performed at latest within 3 months.  

e) Possibility of objection and removal 

You can request the deletion of your user data at any time by post or by e-mail to hello@halbautomaten.com without incurring any further costs. In the event of an objection by e-mail, the implementation of the deletion or blocking may take up to 5 working days, unless we are legally obliged or entitled (e.g. to clarify license disputes) to store the data for a longer period. You can prevent the storage of data by rejecting its collection. This will not apply to the data collected for license compliance. You can do this when we ask for your consent or later in the options menu of the game.   

 

Last update:  05.03.2026