Privacy Policy

I. General Information

This privacy policy applies to the use of our games on all platforms. Additional privacy information may be available for individual games. In such cases we provide that individual information in the respective games or their respective websites.

1. Responsible Entity

Below we explain to you which personal data is collected and processed by us when using our games and services.

Painless Developments GmbH
Bessemerstraße 82, 10. OG Süd
12103 Berlin

E-Mail: info@paindevs.com

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person, this means all information that relates to a person.

2. Legal Basis

As far as a legal basis is mentioned in this Privacy Policy, they relate to the General Data Protection Regulation.

We collect and process personal data based on the following statutory regulations:

• Consent according to Article 6 paragraph 1 (a) General Data Protection Regulation (GDPR). Consent is any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, which indicates that the data subject consents to the processing of his personal data.
• Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 (b) GDPR, this means that the data is required so that we can fulfill the contractual obligations to you or we need the data to prepare a contract closure with you.
• Processing to fulfill legal obligations under Article 6 para. 1 (c) GDPR, this means that a processing of the data is required by law or other regulations.
• Processing for the protection of legitimate interests in accordance with Article 6 para. 1 (f) GDPR, this means that processing is necessary to safeguard legitimate interests on our part or by third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail.

3. Rights of the Data Subjects

You are entitled to the following rights with regard to the processing of data by us in accordance with the respectively listed articles of the General Data Protection Regulation:

• Information Right pursuant to 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 of rectification pursuant to Article 16 GDPR - i.e. the right to request the rectification of inaccurate personal data relating to you without undue delay, including the completion of incomplete data,
• Right to erasure ("right to be forgotten") pursuant to Article 17 GDPR - i.e. the right to request the erasure of your personal data, provided that certain conditions are met,
• Right to restriction of processing pursuant to Article 18 GDPR - i.e. the right to request the restriction of the processing of your personal data, provided that certain conditions are met,
• Right to data portability pursuant to Article 20 GDPR - i.e. the right to demand that you receive your personal data that you have provided in a structured, common and machine-readable format and the right to transfer it to a third party, provided that certain conditions are met,
• Right to object in accordance with 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 that certain conditions are met.
• Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating 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 the storage is deleted. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the processor is subject. Blocking or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

II. Actual data processing

All data transfer is encrypted.

1. Data collected when using our game in single player mode

We do not currently collect and process any personal data ourselves when you use our game. Depending on the platforms you use to play our game (e.g. Steam, Google Play, iOS, Microsoft Xbox, Sony PlayStation), these platforms may collect data independently of us, but this data is not collected by our software or by us. In this case, the relationship is governed by the terms of use and privacy policy of the respective provider.

Our game uses the so-called "Unity" engine from Unity Technologies Inc. based in the United States of America. We ourselves have not activated any data collection in the software, but refer to Unity's privacy policy to the extent that the engine also offers additional services for users where data may be collected by Unity:

Unity Game Player and App User Privacy Policy

2. Contact via e-mail or contact form

A. Scope of the data processing

You can contact us via the e-mail addresses provided on the websites or in the game. In this case, your personal data that you send to us by e-mail will be stored.

The data will be processed and stored by an e-mail provider based in Germany and commissioned by us.

B. Legal basis

The legal basis for the processing of data transmitted in the course of sending an e-mail or a contact enquiry via the contact form is Art. 6 para. 1 lit. f GDPR. If the contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b and c GDPR.

The legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR lies in answering a customer enquiry or answering a contact enquiry on other topics.

Processing by our email provider is carried out on the basis of Art. 28 para. 6 GDPR.

C. Purpose of the data processing

The purpose of data storage is to contact you at your request.

D. Duration of storage

The data will be stored for as long as is necessary to deal with your enquiry. After answering an enquiry, we store the data for 6 months in case of further enquiries. Insofar as these are commercial letters subject to retention under commercial and tax law, they will also be stored in accordance with the statutory retention periods.

E. Right of objection and cancellation

You have the right to object to further use at any time. You can declare your objection by e-mail to: info@paindevs.com.

Deletion can only take place if there is no statutory retention obligation or other right to store the data; in this case, however, the data will be blocked for other use. In the event of an objection, the conversation cannot be continued.

Updated: 12. Feburary 2024