PRIVACY POLICY FOR BUST

Last Updated: [Date]

This privacy policy ("Privacy Policy") informs the user in what way, to what extent and for what purpose the processing of personal data by the responsible provider BUST, [Address] (hereinafter together and individually referred to as "BUST" or "we") takes place. You can access, save and print this Privacy Policy in the current version at any time via our website https://bustdicegame.com/.

We collect, process or use personal data exclusively within the applicable legal framework. Therefore, the high data protection level of the EU General Data Protection Regulation (GDPR), the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG) and the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz – TDDDG) applies.

1. SCOPE OF THIS PRIVACY POLICY

1. In the following, we inform you about the processing of personal data when using BUST and related applications, including browser game (collectively our "Game"). Insofar as individual services of BUST have different privacy policies, these apply.

2. Likewise, third-party services to which the BUST may refer by links are excluded from the field of application. BUST is generally not responsible for content therein or compliance of these third parties with any data protection regulations, unless otherwise stated in the respective privacy policy of the content linked. This includes, for example, links to social networks such as LinkedIn. Information on the use and protection of the user's personal data on these platforms can be found in the privacy policy of the respective platform.

2. CONTROLLER OF YOUR PERSONAL DATA

1.

3. STARTING THE GAME (LOG FILES)

When you start and use Game, a connection to our servers may be automatically established to retrieve new content or updates. Information that your device automatically transmits to us is logged in the process. This includes the IP address of the device you are using, referrer URL, browser type and version, data on the operating system, its version (client build, client data version), volume of data transmitted, date and time (including time zone) of the respective access to the contents of the BUST as well as the information on which specific contents have been requested. In addition, BUST may process user profile information (see below for details) and certain technical data, e.g., as part of a Game start, in order to fulfil its contractual obligations to the user. This data includes name and IP address and data identifying the user's device.

BUST collects and processes this data in order to provide the Game, its features and any (new) content of the Game. Therefore, the basis of this data processing for the fulfilment of contractual obligations is Art. 6 (1) lit. b) GDPR.

4. PLAYER ACCOUNT

Some features of the Game require a player profile or account (collectively "Account"). BUST allow you to use user account login details from other services (e.g. Google or X) to create an Account or link an existing Account to the relevant service. In detail:

1. ACCOUNT CREATION AND PROCESSING OF ACCOUNT DATA

You can link your Account to third-party services such as Google, Discord, or X by using the respective login features (see below).

BUST collects and processes the Account data in order to provide the Game and its features. We also use the Account data and further collected information to manage our relationship with you and provide you with our Account services. For example, we may also use your contact information (e.g. your e-mail address) to send you relevant communications in connection with your contract with us or your Account, e.g. to inform you about an upcoming deletion of your inactive Account (see sect. 24 below).

To the extent that above services are provided within the framework of a contract with you, the basis of this data processing is the fulfilment of contractual obligations pursuant to Art. 6 (1) lit. b) GDPR. In individual cases, the legal basis can be Art. 6 (1) lit. f) GDPR, whereby our legitimate interest is the management of our relationship with you.

2. GOOGLE LOGIN

We offer you the option of creating an Account or linking an existing Account by entering the login data of your Google user account (so-called "Google Login"). The Google Login is subject to your consent, which you can express by clicking on the corresponding button to connect to Google. The Google Login function is offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

The login data of your Google account will be sent directly to Google. We do not have access to your login data. After verification of your login data, Google only informs us about the following data from your Google user account: the registered first and last name, email address, and profile picture. BUST receives and uses the aforementioned data to set up your player Account in the Game.

By using the Google Login function, Google receives the information that you have created or linked an Account for the relevant Game and can link this information to your Google user account. Google processes this information under its own responsibility; we have no influence on data processing at Google. Google may also transfer the information to its parent company in the USA, Google LLC. Since the parent company is certified under the EU-US Data Privacy Framework, such a data transfer could be based on the adequacy decision pursuant to Art. 45 GDPR. Information on how Google handles your personal data can be found in Google's privacy statement at: https://policies.google.com/privacy

Data processing with the Google Login function is legally based on your consent (Article 6 (1) lit. a) GDPR) which you give when calling up Google Login and subsequently entering your login data to your Google account. You can revoke your consent to data processing when using Google Login at any time with effect for the future.

3. DISCORD LOGIN

We offer you the option of creating an Account or linking an existing Account by entering the login data of your Discord user account (so-called "Discord Login"). The Discord Login is subject to your consent, which you can express by clicking on the corresponding button to connect to Discord. The Discord Login function is offered by Discord Netherlands B.V., Schiphol Boulevard 195, 1118 BG Schiphol, Netherlands ("Discord").

The login data of your Discord account will be sent directly to Discord. We do not have access to your login data. After verification of your login data, Discord only informs us about the following data from your Discord user account: the registered username, email address, and avatar. BUST receives and uses the aforementioned data to set up your player Account in the Game.

By using the Discord Login function, Discord receives the information that you have created or linked an Account for the relevant Game and can link this information to your Discord user account. Discord processes this information under its own responsibility; we have no influence on data processing at Discord. Discord may also transfer the information to its parent company in the USA, Discord Inc. Since the parent company is certified under the EU-US Data Privacy Framework, such a data transfer could be based on the adequacy decision pursuant to Art. 45 GDPR. Information on how Discord handles your personal data can be found in Discord's privacy statement at: https://discord.com/privacy

Data processing with the Discord Login function is legally based on your consent (Article 6 (1) lit. a) GDPR) which you give when calling up Discord Login and subsequently entering your login data to your Discord account. You can revoke your consent to data processing when using Discord Login at any time with effect for the future.

4. X LOGIN

We offer you the option of creating an Account or linking an existing Account by entering the login data of your X user account (so-called "X Login"). The X Login is subject to your consent, which you can express by clicking on the corresponding button to connect to X. The X Login function is offered by Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland ("X").

The login data of your X account will be sent directly to X. We do not have access to your login data. After verification of your login data, X only informs us about the following data from your X user account: the registered name, username (handle), email address, and profile picture. BUST receives and uses the aforementioned data to set up your player Account in the Game.

By using the X Login function, X receives the information that you have created or linked an Account for the relevant Game and can link this information to your X user account. X processes this information under its own responsibility; we have no influence on data processing at X. X may also transfer the information to its parent company in the USA, X Corp. Since the parent company is certified under the EU-US Data Privacy Framework, such a data transfer could be based on the adequacy decision pursuant to Art. 45 GDPR. Information on how X handles your personal data can be found in X's privacy statement at: https://x.com/en/privacy

Data processing with the X Login function is legally based on your consent (Article 6 (1) lit. a) GDPR) which you give when calling up X Login and subsequently entering your login data to your X account. You can revoke your consent to data processing when using X Login at any time with effect for the future.

5. IN-APP PAYMENTS

In order to conclude the contract and the associated payment processing, it is necessary to enter bank details or other payment-related data (e.g. credit card). For payment processing, we use the services of a payment service provider (for example, Suraway Inc. (also known as Xsolla)). The use of payment services provided by a Platform operator is often mandatory for us to be allowed to offer the Game on the respective Platform and also serves to provide you with an easy and smooth payment process in the Game.

The aforementioned information will be processed accordingly together with the necessary usage data by the respective Platform operator or payment service provider, insofar as this is necessary to process the payment. Details on the handling of your personal data in connection with the payment processing can be found in the privacy statement of the respective Platform operator or payment service provider, which is available on the corresponding Platform or website.

When you make a payment through one of these services, the Platform operator or payment service provider may share with us the following information: your name, user ID, email address, IP address, and the amount of the payment. We may store this data for tax purposes. We collect and process this data in accordance with Article 6 (1) lit. b) of the GDPR, in order to provide you with secure, reliable and user-friendly online payment processing and fulfil our contractual obligations to you.

6. PLAYER COMMUNICATION

Game offers a emotes chat or other features for player communication. BUST transmits and processes the communication content (e.g. text or emote messages) from players only to the extent that this is technically necessary to provide the corresponding service. The communication content is encrypted. BUST collects and processes this data in order to provide the communication features. Therefore, the basis of this data processing for the fulfilment of contractual obligations is Art. 6 (1) lit. b) GDPR.

7. SUPPORT REQUESTS, FEEDBACK AND CONTACT VIA A GAME

If you notify our customer support, provide feedback, or otherwise contact BUST (e.g. with a contact form in the Game), the information you provide in your message, including the contact details (e.g. email address) or purchase information (e.g. receipt, name of the purchased items) given there, will be processed for the purpose of handling your enquiry and processing it, including investigating and rectifying any problems in the Game and in the event of follow-up questions. In the event of a request to our customer support via the Game, information on the Game (e.g. game, build version, in-game events), your ID and Account, your game progress and, if applicable, the problematic part of the Game as well as information on your device (e.g. IP address, operating system version and language, settings, IMEI, device location) may also be processed automatically. Your data will be automatically deleted as soon as it is no longer required to answer your request.

We process this data in accordance with Art. 6 (1) lit. b) GDPR, as far as you contact us within the framework of an existing contract for the use of the Game or for the purpose of initiating such a contractual relationship. Otherwise, the storage and use of the data takes place on the basis of Art. 6 (1) lit. f) GDPR, whereby our legitimate interest is the careful processing of your respective request or feedback and the solution of any technical problems.

8. SECURITY AND FRAUD PREVENTION

We may process any collected information to maintain the security of our Game and other systems or services, prevent fraud, potentially illegal or offensive activities, or to enforce our rights or the rights of our users. This includes ensuring the confidentiality of personal data of our users, preventing unauthorized access or modifications to our systems and otherwise maintaining the security of personal data. Suspicious activities can lead to Accounts being reported and blocked. The legal basis for this processing is Art. 6 (1) lit. f) GDPR. We and our users have a legitimate interest in protecting our Game, systems, networks and users’ Accounts and personal data, preventing fraudulent or illegal activities, and exercising or defending our rights (including legal claims) or the rights of our users.

9. INVITING PLAYERS VIA LINKS

You may be able to create an invitation to a shared gaming session with a direct link to the specific gaming session to send this invitation to a contact via a messenger app or by other means (e.g. e-mail, message shared on a social network). When the invitation to a game is created, a specific link is generated that leads directly to the gaming session in the Game.

The data processing in connection with the direct link to the gaming session is carried out to provide players with an easy and direct way to start a gaming session with others. The data processing is based on Article 6 (1) lit. f) GDPR. Our legitimate interest is to make it as easy and convenient as possible for our users to start playing games together, thereby providing them with a special gaming experience. This benefits both the sender and recipient of invitations to play a game.

10. STORE AND/OR ACCESS INFORMATION ON A DEVICE (COOKIES)

Cookies and similar technologies (collectively “Cookies”) are used in our Game. Cookies are small text files that are stored on your device. Cookies may be set by us as the provider of the Game (so-called first-party Cookies) or by third parties whose services are integrated on our Game (so-called third-party Cookies).

Cookies do not contain viruses or otherwise harmful software. They collect and store certain information related to the specific device or to the usage of our Game, e.g. the duration of usage, and they might contain pseudonymized identifiers like an ID. However, this does not mean that we are immediately aware of your identity.

Regarding the storage period, Cookies used on our Game can be distinguished as follows:

  • Session Cookies: These Cookies are automatically deleted when the Game is closed.
  • Persistent Cookies: These Cookies are not automatically deleted when the Game is closed, but stored on your end device and are automatically deleted after a certain period (depending on the specific cookie, up to two years).

Regarding their purposes and legal bases, Cookies used on our Game can be distinguished as follows:

  • Necessary Cookies: These Cookies are strictly necessary in order to use the basic functions of a Game or service and to ensure its security; they do not collect information for statistical analytics or marketing purposes. The storage of necessary Cookies on your device and access to these Cookies is based on Section 25 (2) No. 2 TDDDG. Any subsequent data processing is based on Art. 6 (1) lit. f) GDPR, whereby the achievement of the above-mentioned purposes is our legitimate interest.
  • Optional Cookies: These Cookies can, among other things, record your interactions with the Game, advertisements, or other content. The tracked user behavior and other collected information can be used for purposes of delivery of advertising or content, personalization, performance measurement and market research, or improvement of products and services (see sections 13-17 of this Privacy Policy below). We only use these Cookies with your express, active, and freely revocable consent in accordance with Section 25 (1) TDDDG. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Optional Cookies are only used in conjunction with another service implemented in the relevant Game (e.g. for analytics or marketing purposes). Such services are often provided by third-party vendors (collectively “Vendors”).

The types of information collected and processed by our Vendors in the course of providing their services can be broadly categorized as follows. Not all of the following information is collected by Cookies. Some of it is, for example, accessed on the device or automatically transmitted to our Vendors in the event of server contact:

  • Device-related data such as the IP address and further logfile data, manufacturer and type of the device, operating system version, the language setting, non-precise location of the device (country), Mac Address (only for iOS devices);
  • Game-related information such as the general content, client build, client data version, configuration of the Game;
  • Ad or (non-advertising) content-related information such as the displayed ad or content, time, amount, and duration of display;
  • User-related information such as pseudonym identification numbers (e.g. a Cookie-ID, Android advertising ID, Android device ID, iOS device Unique ID) or user behavior in our Game, including engagements with ads or content (e.g. for how long, when, and how user interacted with a specific piece of content);
  • Precise geolocation: Only with your explicit consent, the precise geolocation (with a radius of less than 500 meters) might be used for the purposes stated below. The legal basis for the collection of this data is Section 25 (1) TDDDG and for its subsequent processing Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

Details on the Cookies, Vendors and services used in our Game and the relevant data processing can be found in the following sections of this Privacy Policy.

11. USE LIMITED DATA TO SELECT ADVERTISING OR CONTENT

1. PURPOSE

We display advertising and (non-advertising) content in our Game that is selected and delivered by our Vendors, including advertisers, publishers, ad networks or other content providers. Only limited data is used in this process, mainly to ensure that a specific ad is displayed in a suited (online) context or context/country and to control the frequency or sequence order of displayed ads or pieces of content.

Please note that the data processing described in this section does not include personalization or retargeting measures, where users’ advertising profiles are used to tailor the selection of ads to their perceived interests. For information on such personalization services, please see section 14. of this Privacy Policy.

2. COLLECTED INFORMATION

To select and display advertising or other content to a user, certain limited data might be collected, including by means of first-party and third-party Cookies (see section 12 of this Privacy Policy for details on Cookies), and shared with our Vendors. This can include the IP address of your device and other technical data related to your device (e.g. manufacturer and model of the device, the language setting), basic information about the Game (e.g. its basic content), previously displayed advertisements or content, and a non-precise location of the device (e.g. the country). Vendors may also store your past interactions with certain ads or content served by them and take these into account when selecting ads or content, over which we generally have no control. However, there is no detailed tracking of user behavior, and no advertising profiles of users are created.

3. DATA PROCESSING

The collected information is processed to decide which specific ad or piece of content is played. We have no influence on the selection and display of the specific ads or content in our Game. We only provide our Vendors with some basic parameters and criteria to set some general boundaries for the selection of ads. Our Vendors alone decide which specific ads or content is played.

Certain Vendors might combine the collected information with further data about the user available in the specific moment, link different devices of the user, or identify the user’s device based on characteristics in order to select an advertisement in the specific moment (see section 17. of this Privacy Policy for details on these features).

The data processing in the context of the selection and display of advertising or content is determined independently by our Vendors who process the collected information in their own responsibility and for their own purposes according to their privacy policy.

4. THIRD COUNTRY TRANSFER

The collected information may be transferred to servers in third countries (e.g. the USA). However, we only work with vendors who, in the event of a data transfer to a third country, ensure an adequate level of protection in that third country in accordance with the provisions of Art. 44 et seq. GDPR. The relevant data processing is often based either on an adequacy decision of the EU Commission for the relevant country (Art. 45 GDPR) or standard contractual clauses concluded between the parties of a data transfer (Art. 46 (1) lit. c GDPR). Both safeguards ensure that the level of data protection in the third country is substantially equivalent to that of the GDPR. Details on data processing to a third country can be found in the privacy policy of the relevant Vendor.

5. ADVERTISING OR CONTENT IN YOUR SPECIFIC GAME

It depends on the respective Game whether and which specific tools and Vendors are used and to which extent advertising or content is selected and displayed to players.

Please refer to the Vendor list of your specific Game for details of the Vendors and tools that select and display ads or content based on limited data in your specific Game.

The list is available in the consent banner of your Game. The consent banner is displayed to you, inter alia, when you first start the Game. Here you can adjust your settings for advertising or content for the respective Game.

6. LEGAL BASIS

The data processing as described above is usually based on your consent pursuant to Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

Depending on the specific Vendor and the extent (and limitation) of the relevant data processing when serving advertising or content, the data processing may in individual cases be based on legitimate interests pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is to display advertising to our users in order to finance the creation and further development of free Game, which is also in the interest of our users.

12. CREATE AND USE PROFILES TO PERSONALIZE ADVERTISING AND CONTENT

1. PURPOSE

With your consent, our Game may contain personalized advertising or (non-advertising) content. We want to provide users with interest-based and relevant advertising and content in our Game wherever possible. Personalization usually takes place on the basis of pseudonymous profiles of the user, from which conclusions can be drawn about the content, products or services in which the individual user may be interested. We have implemented tools and services (collectively “Personalization Tools”) provided by our Vendors in our Game which help to:

  • track user activities on our Game (e.g. the use of certain features or items, purchase of items),
  • analyze this information to draw conclusions about user’s potential interests,
  • store the information collected and analyzed in pseudonymous user profiles, and
  • use these profiles to select and display personalized content or advertising to the individual user.

The Personalization Tools are therefore used to display personalized (also so-called “targeted”) advertising or content to users of our Game.

2. COLLECTED INFORMATION

The Personalization Tools often use Cookies (see section 12 of this Privacy Policy for details on Cookies) which contain a pseudonym ID to track certain user-related information in our Game, including user behavior (e.g. engagements with ads or content), and content-related information such as the ads or content displayed in our Game. The tracked information includes, for example, the user’s advertising IDs, details on which and for how long an ad has been displayed, details on user interactions with ads or certain pieces of content, user interaction in the Game such as the use of certain features or objects or purchase of certain items. In addition, device-related data (e.g. IP address, manufacturer and model of the device, the language setting) and the location of the device (e.g. country) might be collected. Please note that the precise location of the device is only collected and processed with the user’s separate and explicit consent (see section 12 of this Privacy Policy for details).

3. DATA PROCESSING

The collected information is shared with our Vendors as providers of the relevant Personalization Tools. In summary, our Vendors generally process the information to create an advertising profile of the user and to serve ads or content based on that profile. Certain Vendors might combine the collected information with further data about the user, link different devices of the user, or identify the user’s device based on characteristics in order to create and enrich advertising profiles or to select a specific ad (see section 13.4. of this Privacy Policy for details on these features).

We provide our Vendors with some basic parameters and criteria to set some general boundaries for the selection of ads. However, our Vendors alone decide if an advertising profile is created, or which specific ad or content is played. Our Vendors generally process the collected information in their own responsibility and for their own purposes according to their privacy policy. To this extent, BUST has no influence on the data processing by Vendors.

Therefore, the following more detailed information about our Vendors’ data processing is based on our best knowledge and may vary from Vendor to Vendor: Typically, the collected user information is analyzed and stored in pseudonym user profiles, i.e. it is used to create a user profile or to further enrich an already existing user profile. The information may be combined with further information about the individual user which was collected by the Vendor elsewhere, e.g. through websites or apps of third parties. The user information may also be combined across multiple devices. The user profiles are typically tagged with targeting criteria based on the analysis of the collected information. This helps the Vendors to customize content or advertising. However, the Vendor may also process the data for further purposes in accordance with its privacy policy, e.g. to improve or develop new products, to measure the effectiveness of certain advertising or for market research purposes.

The collected information may also be transferred to servers in third countries such as the USA (see section 13.4 of this Privacy Policy for details).

BUST is generally not involved in this data processing by the Vendors. BUST also does not receive any information from Vendors with which BUST could identify individual users. The selection of ads or content displayed to a user is generally made by our Vendors. BUST only receives statistical analyses from Vendors that provide information about which ads or content have been clicked on.

4. PERSONALIZATION IN YOUR SPECIFIC GAME

It depends on the respective Game whether and which specific Personalization Tools and Vendors are used and to which extent content or advertising is personalized.

Please refer to the Vendor list of your specific Game for details of the Vendors and tools that personalize ads or content in your specific Game.

The list is available in the consent banner of your Game. The consent banner is displayed to you, inter alia, when you first start the Game. Here you can adjust your settings for advertising or content for the respective Game.

5. LEGAL BASIS

We only use Personalization Tools with your consent. Therefore, the data processing as described above is based on Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

13. MEASURE PERFORMANCE OF ADVERTISING OR CONTENT AND UNDERSTAND AUDIENCES

1. PURPOSE

We measure the advertising and (non-advertising) content performance, including the user’s interactions and conversion (so-called “Conversion Tracking”), to bill the delivery of advertising or content, to better understand our audience or the reach of the displayed advertising and content and to further improve its relevance.

2. COLLECTED INFORMATION

Our Game use Cookies to collect information about the ads or content displayed to our users (e.g. the displayed ads, number, and duration of display; information on brand suitability) and how our users interact with them. This can include details of how many users interacted with an ad or piece of content, for how long, when, and how (e.g. click, tap, hover, scroll) they engaged with it, and which engagements may have led to a successful conversion (e.g. a sale or certain user interaction at the website of the advertiser). In addition, device-related data (e.g. IP address, manufacturer and model of the device, the language setting), age, gender, and the location of the device (e.g. country) might be collected. Please note that the precise location of the device is only collected and processed with the user’s separate and explicit consent (see section 12 of this Privacy Policy for details).

3. DATA PROCESSING

The collected information is processed to create statistical reports about the reach of the displayed ads or content. These statistical reports can be used to invoice the delivered ads or content or to evaluate its relevance. The statistical information can also be combined with further data sets (e.g. user profiles, statistics, market research or analytics data) such as data regarding user interactions with similar advertising or content to identify common characteristics (e.g. to determine which audiences are more receptive to an ad campaign or certain contents). These insights help our Vendors, advertisers, and publishers to conduct market research and define target groups for their advertising campaigns or content.

Our Vendors process the collected information in their own responsibility and for their own purposes according to their privacy policy. Certain vendors might combine the collected information with further data about the user, link different devices of the user, or identify the user’s device based on characteristics to measure the performance of advertising or content (see section 17 of this Privacy Policy for details on these features). The information may also be transferred to servers in third countries such as the USA (see section 13.4 of this Privacy Policy for details).

Vendors who display personalized advertising or content (see section 14 of this Privacy Policy) might also evaluate the collected information on an individual user profile level, i.e. the data might be combined with user profiles (see section 14.2 of this Privacy Policy for further details).

4. PERFORMANCE MEASUREMENT IN GAME

Please refer to the Vendor list of Game for details of the Vendors and tools that measure performance of ads or content in Game.

The list is available in the consent banner of your Game. The consent banner is displayed to you, inter alia, when you first start the Game. Here you can adjust your settings for advertising or content for the Game.

5. LEGAL BASIS

The data processing as described above is regularly based on your consent pursuant to Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

Depending on the specific Vendor and the extent (and limitation) of the relevant data processing when serving advertising or content, the data processing may in individual cases be based on legitimate interests pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is to play advertising to our users in order to finance the creation and further development of free Games, which is also in the interest of our users.

14. DEVELOP AND IMPROVE SERVICES

1. PURPOSE

Information on the user interactions with the advertising and (non-advertising) content is processed to improve or develop new products and services, including from our Vendors.

2. COLLECTED INFORMATION

Our Game use Cookies to collect information about how our users interact with the advertisements or content displayed in our Game. This can include details of how many users interacted with an ad or piece of content, for how long, when, and how (e.g. click, tap, hover, scroll) they engaged with it. In addition, the IP address and other device-related data as well as the location of the device can be collected. Please see section 15.2 for further details.

3. DATA PROCESSING

The collected information is processed to create statistical reports about the usage of advertising and content in our Game. These insights help us to improve our Game and our Vendors to improve their products and services, e.g. by improving their performance or adapting them technically. The insights may also be used when developing new Game, products, and services.

Our Vendors process the collected information in their own responsibility and for their own purposes according to their privacy policy. Certain Vendors might combine the collected information with further data relating to the user, link different devices of the user, or identify the user’s device based on certain characteristics to improve and develop their services (see section 17 of this Privacy Policy for details on these features). The information may also be transferred to servers in third countries such as the USA (see section 13.4 of this Privacy Policy for details).

4. YOUR GAME

Please refer to the Vendor list of Game for details of the Vendors and tools that use the collected information to improve their services or products.

The list is available in the consent banner of Game. The consent banner is displayed to you, inter alia, when you first start the Game. Here you can adjust your settings for advertising or content for the Game.

5. LEGAL BASIS

The data processing as described above is regularly based on your consent pursuant to Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

Depending on the individual Vendor and the extent (or restriction) of data processing when collecting and processing information about user interactions, the data processing can also be based on our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest is to play advertising to our users in order to finance the creation and further development of free Games, which is also in the interest of our users.

15. IDENTIFY DEVICES AND COMBINE DATA FROM DIFFERENT SOURCES OR DEVICES

1. PURPOSE

In support of the purposes explained above (see sections 13-16 of this Privacy Policy), certain Vendors might combine the collected information with further data relating to the user, link different devices of the user, or identify the user’s device based on certain characteristics.

2. DATA PROCESSING: MATCH AND COMBINE DATA FROM OTHER DATA SOURCES

Information about your activity in the Game and your interaction with ads or (non-advertising) content may be matched and combined with other information relating to you and originating from various sources (for instance your activity on a separate Game or online service).

Such other information may be derived and collected by the Vendor from other services (e.g. from websites, other applications, direct emailing campaigns or in-store purchase history) that you use. Matching these separately collected data sets with your information collected in our Game can help the Vendor to achieve better results from the data processing for the relevant purpose. For example, Vendors can tailor advertising or content more precisely to the user if the underlying advertising profile contains not only information about activities within the Game, but also information about the user's activities and interests on third-party websites.

3. DATA PROCESSING: LINK DIFFERENT DEVICES

Your device might be considered as likely linked to other devices that belong to you or your household (for instance because you are logged in to the same service on both your phone and your computer, or because you may use the same Internet connection on both devices). This might allow Vendors to collect and combine information related to the user from additional sources to achieve better results from the data processing for the relevant purpose (see section 17.2 of this Privacy Policy).

4. DATA PROCESSING: IDENTIFY DEVICES BASED ON INFORMATION TRANSMITTED AUTOMATICALLY

Your device might be distinguished from other devices based on information it automatically sends when accessing the Internet (for instance, the IP address of your Internet connection or the type of browser you are using).

Certain Vendors use these individual characteristics to create a pseudonym identifier and/or to re-identify your device at a later time, e.g. when your device is re-connected to the Vendor’s service. This identification of your device might allow vendors to link information from additional sources to a certain user, which can help them to achieve better results from the data processing for the relevant purpose (see section 17.2 of this Privacy Policy).

5. LEGAL BASIS

The relevant legal basis for the above-mentioned data processing generally depends on the respective purpose for which the data processing was carried out (see sections 13-16 of this Privacy Policy). However, such data processing is typically more extensive and therefore usually only takes place with the consent of the user in accordance with Art. 6 (1) lit. a) GDPR. You can freely withdraw your consent at any time with effect for the future.

16. ENSURE SECURITY, PREVENT AND DETECT FRAUD, AND FIX ERRORS

Your data can be processed to monitor for and prevent unusual and possibly fraudulent activities (e.g., regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you or our Vendors, including publishers or advertisers, may encounter in the delivery of content and in your interaction with them.

For details on the collected information, please see sections 12-17 of this Privacy Policy. The information can be processed, inter alia, to monitor or prevent invalid traffic, manipulations, hidden ads, or advertising spam, to identify product errors and ensure operability of the Game and systems.

For details about the tools and Vendors processing data for these purposes, please refer to the Vendor list of Game.

To the extent our Vendors collect the information for this purpose, they may do so on their own responsibility and for their own purposes according to their privacy policy. The information may also be transferred to servers in third countries such as the USA (see section 13.4 of this Privacy Policy for details).

The legal basis for this processing is Art. 6 (1) lit. f) GDPR. We and our Vendors have a legitimate interest in ensuring the security in our Game, products, and services, preventing and detecting (potential) fraud, and in fixing errors.

17. DELIVER AND PRESENT ADVERTISING AND CONTENT

Certain information is used to ensure the technical capability of the advertising or (non-advertising) content, and to facilitate the transmission of the advertisement or content.

Information processed for this purpose can include data related to the device (e.g. IP address, user agent type, supported language, connection type) and the requested advertising or content (e.g. size and type of the advertisement or content). The data is processed to receive and respond to ad requests, to deliver ad files, to respond to a user’s interaction with an advertisement or content, or to log the delivery of the advertisement or content (without recording any personal data about the user).

To the extent our Vendors collect the information for this purpose, they might do so on their own responsibility and for their own purposes according to their privacy policy. The information may also be transferred to servers in third countries such as the USA (see section 13.4 of this Privacy Policy for details).

The legal basis for this processing is Art. 6 (1) lit. f) GDPR. We and our Vendors have a legitimate interest in delivering and presenting advertising and content to the users of our Game.

18. SAVE AND COMMUNICATE PRIVACY CHOICES

We process data from your consent in the cookie settings to document your consent, to implement your setting and to enable you to manage your consent. The choices you make in our Game regarding the purposes listed in this Privacy Policy and the consent banner are saved and made available to the relevant Vendors in the form of digital signals (such as a string of characters). This is necessary in order to enable both this service and the entities to respect such choices.

The legal basis for this processing is Art. 6 (1) lit. f) GDPR. We have a legitimate interest in providing our users with a compliant consent solution and in documenting and implementing their choices.

19. SHARING OF PERSONAL DATA

We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing, and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. We have concluded corresponding data processing agreements with these service providers in accordance with Art. 28 GDPR so that your data is processed only on our behalf in accordance with our instructions. Before forwarding any personal data, we ensure that service providers have taken the necessary technical and organizational measures to ensure an adequate level of protection. Our main service providers are currently: Fly.io, Cloudflare, Google Cloud and Neon.

Otherwise, data will only be shared with third parties with your consent or insofar as this has been described elsewhere in this Privacy Policy. In individual cases, data may also be transmitted to the following recipients:

  • To state institutions and authorities entitled to receive information, insofar as we are obliged to provide information within the framework of the statutory obligations to provide information or by a court or official decision. In this case, the disclosure of your data is required pursuant to Art. 6 (1) lit. c) GDPR to fulfill a legal obligation to which we are subject.
  • To lawyers and/or external consultants, insofar as this is necessary for the establishment, exercise or defense of legal claims and there is no reason to assume that the user has an overriding interest worthy of protection in the non-disclosure of their data. In this case, the data is forwarded based on Art. 6 (1) lit. f) GDPR to safeguard our legitimate interest, which is the establishment, exercise, or defense of legal claims.

20. INTERNATIONAL DATA TRANSFER

Information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our third-party service providers outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in the country in which you reside or in other parts of the world.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. This includes the use of the EU-U.S. Data Privacy Framework for transfers to the USA as well as the European Commission's Standard Contractual Clauses. Further details can be provided upon request.

21. STORAGE PERIOD AND ERASURE OF DATA

We process personal data of the user 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. Upon the end 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.

Data that we have processed on the basis of consent will generally be erased or made anonymous immediately after consent is revoked.

22. DATA SECURITY

BUST takes technical and organizational security measures to protect your data against accidental or intentional manipulation, loss, destruction, misuse, or access by unauthorized persons or against unauthorized disclosure. Our security measures are regularly reviewed and adapted in line with technological developments. Data transmitted between our server and the terminal is encrypted (HTTPS protocol). Please note, however, that no internet transmission is ever 100% secure or error-free, please take this into account when using the services of BUST.

23. NO AUTOMATED DECISION MAKING

Our Game do principally not include an automated decision-making process, including profiling, pursuant to Art. 22 (1) and (4) GDPR. Should this change and individual, special features of our Game in individual cases include also an automated decision-making process, we will provide you with relevant information about the logic involved and the scope of such processing.

24. RIGHTS OF THE USER

As a person subject to data processing, you are entitled to the following rights, in each case under the requirements and to the extent stipulated by the GDPR. Please contact us if you wish to exercise your rights.

1. RIGHT TO INFORMATION

You have the right to request free information about the nature, extent and source of the data stored about you, the recipients or categories of recipients to whom your information has been or will be disclosed and the purpose and intended duration of the storage.

2. RIGHT TO RECTIFICATION, DELETION AND/OR RESTRICTION

You have 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 you, unless BUST is legally obliged to retain such data. Insofar as this includes such personal data that is necessary for the provision of services to you, the deletion or restriction of the processing of this data can only take place when you no longer use BUST's services.

3. RIGHT TO DATA PORTABILITY

If you provide data relating to you and BUST processes such data on the basis of your consent or in order to fulfil the contract, you may request to receive such data in a structured, current and machine-readable format from BUST or to make BUST transmit such data to another person responsible, insofar as this is technically possible (so-called right to data portability).

4. RIGHT OF OBJECTION

You have the right to object, on grounds relating to your particular situation, at any time to the processing of the personal data concerning you, which is based on Art. 6 (1) lit. e) or f) GDPR, in accordance with Art. 21 GDPR; this also applies to profiling based on these provisions. BUST will no longer process the personal data concerning you unless BUST can demonstrate compelling legitimate grounds for processing which outweigh your interests, rights and freedoms or the processing is intended to assert, exercise or defend legal claims. If the personal data concerning you are processed for direct advertising purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object to processing for direct advertising purposes, your personal data will no longer be processed for these purposes.

5. RIGHT TO REVOKE YOUR CONSENT

You have the right to revoke your consent at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

6. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the member state where you reside, work or the alleged infringement occurred, if you believe that the processing of the personal data concerning you is contrary to the GDPR.

25. DATA DELETION INSTRUCTIONS

You may ask us to delete your personal data at any time.

1. HOW TO SUBMIT A REQUEST

Email. Write to [email protected] with the subject “Data Deletion Request.” In the email, include the account ID, username, or the email address linked to your account. If applicable, you may also provide the platform ID (for example, Facebook, Apple, or Google ID) to help us verify your request.

2. VERIFICATION

We must verify your identity before acting on a request. If you are logged in, we may verify through your account. If you are not logged in, we may ask for additional information such as account ID, purchase receipts, device identifiers, or other data we already hold, which we will use only to verify your request. Authorized agents may submit requests if they provide proof of authorization, and we may ask the account holder to confirm the request.

3. OUR RESPONSE TIME

EEA and UK users. We will respond within one month of receiving a verifiable request. Where a request is complex or numerous, we may extend by up to two further months. In all cases, we will inform you if we need more time.

California residents. We will respond within 45 days of receiving a verifiable request. If reasonably necessary, we may extend once by an additional 45 days and will inform you.

4. WHAT DELETION MEANS

If your request is approved, we will delete or de-identify personal data we hold about you, and we will instruct our service providers and contractors to do the same. Where we have sold or shared your personal information in the meaning of California law, we will notify relevant third parties to delete your information, unless this proves impossible or would involve disproportionate effort.

5. WHEN WE MAY DECLINE ALL OR PART OF A REQUEST

We may keep data where an exception applies. These include, for example, compliance with a legal obligation, exercise or defense of legal claims, security incident detection and protection against malicious activity, debugging to identify and repair errors, internal uses that are reasonably aligned with consumer expectations or compatible with the context in which the information was provided, and freedom of expression. If we deny your request in whole or in part, we will explain why.

6. BACKUPS AND SUPPRESSION

Certain logs and backups are deleted or overwritten on scheduled cycles. We will isolate your data from active use and complete deletion when the cycle runs. We may keep minimal information about your request, such as your account ID or email, to maintain a record that the deletion occurred and to prevent re-creation of your profile.

7. HOW YOU WILL BE NOTIFIED

We will confirm completion of your request or explain any denial or partial denial. EEA and UK users will also be told about their right to complain to a supervisory authority.

26. UPDATING OF THIS PRIVACY POLICY

Due to the further development of our Game or due to changed legal or regulatory requirements, it may be necessary to change this Privacy Policy from time to time. The current Privacy Policy is always available via a link in the Game.