Data transfer and Data sharing

Detailed information on the transmission of personal data to a third country - consent

  1. Provision of Crowfall
    In order to use the game "Crowfall" and participate in the game, it is necessary to transmit data beyond national borders and to justify the same. The idea of the game and the special characteristic of Crowfall is the global "gaming experience". The player is able to compete and communicate with players from all around the world. It is therefore absolutely essential, including for technical reasons, that user data are handled via various international servers, in order to provide the global game world.
    In the following, we wish to comprehensively and transparently inform the user about the transfer and processing of the affected personal data and remind the user of their existing right of revocation. By accepting and activating the check boxes in the registration process, the user expressly consents to the transfer and sharing of data. Without providing this consent and without the possibility of transferring and sharing data, participation is not possible, nor is provision of the game from a technical perspective.
  2. Purpose of data processing
    In order to use the game Crowfall and participate in the game, it is necessary for the partners indicated under section 3 to transmit and process the personal data provided by the customer. We cooperate with the partners due to the fact that we offer a game that enables players to interact and communicate with each other across national borders. It would not be possible for us to offer this global gaming experience alone.
  3. Involved partners – data protection and data security
    As the publisher of the game, Travian Games is responsible for data processing. Travian Games would therefore like to introduce the partners involved in the provision of the game and explain their roles in the process. We consider the protection and security of personal data processed for the registration and provision of the game to be highly important. For this reason, we take measures to protect the data in each phase.
    a. Cooperation with SoftwareSandbox
    We work closely with the US company SoftwareSandbox, which provides us with the technical portal used for the provision of this game and other games of ours. We have signed standard EU contractual clauses on data protection with SoftwareSandbox, which were prepared by the EU Commission in order to safeguard an appropriate level of data protection from a data processor outside the EU. This system runs on servers in the EU and we alone are permitted to access the system. SoftwareSandbox may access our data only for the purposes of maintenance work; for this reason, we consider it prudent and necessary to secure such access by means of the above-mentioned standard EU contractual clauses. We consider the protection of the personal data of our players to be particularly important and we take all conceivable security measures, both internally and in relation to our partners, in order to ensure their protection.
    b. Cooperation with ArtCraft Entertainment
    ArtCraft Entertainment, Inc. , Austin (Texas), USA, is the developer of the game and therefore closely cooperates with us. ArtCraft Entertainment is also the operator of the game servers that process data in order to make the game available. These servers are also used to host the game worlds, as well as to compile the game data of participating players, in order to be able to realize the shared, global gaming experience. Only game data and personal data stipulated under point 4 are processed using this system; other personal data, especially payment data, are processed on our account servers. We and our carefully selected service providers have exclusive access to these account servers.
    More information about ArtCraft Entertainment can be found at https://www.crowfall.com
    c. ArtCraft Entertainment
    ArtCraft Entertainment, like Travian Games, is a publisher of online and video games, which offers Crowfall and thereby enables the global gaming experience for Crowfall in cooperation with us. In order to be able to provide the game in its form and facilitate the shared game experience with players from this region, however, it is necessary for us to share the game data. Without this shared use, it would not be possible to provide the game in its form and to enable interaction with international players.
  4. Processed personal data and data categories
    We would like to briefly explain which data and data categories are processed on which of our servers and where the consent of the user applies.
    The following data categories are affected by data transmission and the shared use of data for the provision of the game:
    • Username
    • Password in encrypted form
    • Email address in alienated form
    • Registration date
    • Display name in the game
    • Purchased goods and game services in the web shop
    • Transaction history of goods in the game
    • Telemetry data
  5. Determination of suitability
    For the country in which the aforementioned partners have their registered offices and in which the personal data are processed, there is not currently a determination of suitability by the EU Commission in the meaning of Art. 45 Para. 1, 3 of the General Data Protection Regulation (GDPR). This means that the EU Commission has not yet positively determined that the national level of data protection afforded by the respective country accords with the level of data protection afforded by the European Union on the basis of the General Data Protection Regulation.
  6. Appropriate safeguards
    The General Data Protection Regulation stipulates appropriate safeguards (pursuant to Art. 46 Para. 2, 3 GDPR) for data transmission into a third country or to international organizations. Hence, for example, internal data protection provisions approved by a supervisory authority or standard contracts of the EU are not currently implemented by all our partners, which we would like to point out for reasons of transparency.
  7. Potential risks
    Potential risks that cannot be ruled out currently in connection with the above points include the following in particular:
    • It is possible that your personal data could be forwarded to another third party, in excess of the actual purpose of order fulfillment, such as for advertising purposes.
    • You may not be able to sustainably assert or enforce your rights to information against a partner.
    • There may be a higher likelihood of an improper use of data, since the technical and organizational measures of the subcontractor may not fully accord with the quantitative or qualitative requirements of the General Data Protection Regulation for the protection of personal data.
  8. Rights of players
    You have the following rights over us with regard to personal data about you:
    • Right to information
    • Right to correction or deletion
    • Right to limitation of use
    • Right to revocation of use
    • Right to data portability
      You also have the right to complain to a data protection authority with respect to our use of your personal data.
  9. Additional information
    You can find additional detailed information about your above-mentioned rights, other matters of data protection, the data protection measures we have taken, and our data protection officer in the extensive data privacy statement at www.crowfall.com
    Should you have any comments or questions, or in the event you wish to exercise your above rights, please contact privacy@traviangames.com at any time.
    You can also contact us by post:
    Travian Games GmbH
    Wilhelm-Wagenfeld-Str. 22
    80807 Munich
  10. Consent and revocation of consent
    I consent to the transmission of my personal data to the above-mentioned partners for the provision and execution of the game Crowfall and to the service provided in the above-mentioned countries. I may revoke this consent from Travian Games, as the responsible entity, at any time. Revocation shall not affect the lawfulness of any data processing conducted until the revocation of consent. In this case, the responsible entity may no longer continue to fulfill the user agreement and must end the same.
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