PRIVACY POLICY 


1. Introduction

In the following, we provide information about the collection of personal data when using

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is Wolvesville GmbH & Co. KG, Peter-Händel-Straße 10, 91334 Hemhofen, Germany, email: howl@wolvesville.com. We are legally represented by Wolvesville Verwaltungs-GmbH with the managing director Philipp Eichhorn.

Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Competitions

Occasionally, we offer competitions via our website or in other ways. We process the data requested in these competitions in order to determine and notify the winners. Afterwards, we delete the data. It may also be that we only offer competitions for existing customers. In this case, we only process the name to determine the winners and the contact data to notify the winners. It is our legitimate interest to offer competitions to attract customers or to interact with our existing customers. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

1.10. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Data processing on our applications

2.1. Downloading the app

Our app is ready for download at ​Apple's App Store, Google's Play Store and Huawei AppGallery​ (hereinafter "Stores"). When users download the app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

2.2. Informative use of our applications

During the informative use of our applications, i.e. when users do not separately transmit information to us, we collect the personal data that the terminal device transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

2.3. Hosting and provision

Our applications are hosted by Amazon AWS. The provider is Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA. In doing so, the provider processes the personal data transmitted via the applications, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.

It is our legitimate interest to provide our applications, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

On the website we use a content delivery network to help provide our website. The provider is as well Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA (privacy policy: https://aws.amazon.com/de/privacy/?nc1=f_pr). The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

2.4. Registration and provision of functions

Users can open a user account. We process the e-mail address, user name and gender requested in this context for the fulfillment of the respective user contract concluded for the account, so that the legal basis for the processing is Art. 6 para. 1 p. 1 lit. b GDPR. We delete the data when users delete their user account.

We also process text and voice messages to provide the user with features of the game. Various persons - "Mentors" and "Guardians" - are given access to the username and text messages to advise other players or to check compliance with rules. The legal basis for the processing is the usage contract concluded with the user.

The legal basis of the processing with respect to Guardians is the user agreement concluded with the user, which provides that the compliance with rules of the game will be verified by Guardians. The data transfer to Mentors is based on the consent of the users (Art. 6 para. 1 p. 1 lit. a GDPR). Users can revoke their consent at any time by contacting us at the above contact details. The withdrawal does not affect the lawfulness of the processing until the withdrawal.

2.5. Access to functions or data

The app requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the app. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.

The functions or data processed to this extent are

2.6. Single sign-on procedures

Site visitors can log in to our applications using a single sign-on procedures. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the user is logged in with the provider and the provider receives information that the user is using the single sign-on procedure on our website. Depending on the settings of the user in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who logs in to our site with the account (Art. 6 para. 1 s. 1 lit. a GDPR).

The provider of these procedures are

Which data we receive from Facebook is communicated to users by Facebook as part of the registration process. Information about Facebook and the contact details of the data protection officer, as well as further information about how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject against Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing taking place through Facebook in the context of the use of the procedure and have concluded a joint controller agreement (Art. 26 GDPR) with Facebook. There we have defined the respective responsibilities for the fulfillment of the obligations under the GDPR with regard to joint processing. We are required to provide the above information and Facebook has assumed responsibility for the other data subject rights under Art. 15-20 GDPR.

2.7. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

2.8. Technically necessary cookies on the website

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies that payment providers set for payment processing and do not analyze user behavior.

2.9. Third parties

2.9.1. Vivox voice chat

We use Vivox voice chat as chat in the game. The provider is Unity Software Inc, 30 3RD St San Francisco, CA, 94103-3104, USA. The provider processes access and log data and voice messages in the US.

The legal basis of the processing is consent, Art. 6 para. 1 p. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future, e.g. by e-mail to howl@wolvesville.com.

The data transfer to the third country is also based on consent.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://unity3d.com/de/legal/privacy-policy.

2.9.2. Mailbox.org

We use Mailbox.org for sending e-mails. The provider is Heinlein Hosting GmbH, Schwedter Str. 8/9B, 10119 Berlin. The provider processes the content of the e-mail, the e-mail address and opening and click rates in the EU.

The legal basis of the processing is Art. 6 para. 1 p. 1 lit. f DSGVO. We have a legitimate interest to communicate with our users via email.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://mailbox.org/en/data-protection-privacy-policy.

2.9.3. Google AdSense

We use Google AdSense for advertising on the website. The providerGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and tracker.

The legal basis of the processing is consent, Art. 6 para. 1 p. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future, e.g. by e-mail to howl@wolvesville.com.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

2.9.4. Google AdMob

We use Google AdMob for advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes unique device identifiers for advertising (e.g. Google Advertiser ID or IDFA), usage data (e.g. web pages visited, interest in content, access times) and tracker.

The legal basis of the processing is consent, Art. 6 para. 1 p. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future, e.g. by e-mail to howl@wolvesville.com.

The data will be deleted when the purpose of its collection has ceased to apply and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

2.9.5. ​Firebase Cloud Messaging​

We use Firebase Cloud Messaging to communicate with users. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://firebase.google.com/support/privacy.

2.9.6. ​Sentry​

We use Sentry to monitor applications and to track errors in applications or on websites. The provider is Functional Software, Inc., 132 Hawthorne Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://sentry.io/privacy/.

2.9.7. ​Cloudflare​

We use Cloudflare for application security. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in increasing the security of our app by preventing malicious traffic from reaching our server.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at .

2.10. Notice for users from Germany

Our applications store information in the terminal equipment of visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the sections above.

This storage and access is based on the following provisions:

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3. Data processing on social media platforms

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

3.1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

3.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

3.3. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

3.4. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

4. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

5. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.