Privacy policy

We take data protection very seriously. Our services are designed with the GDPR in mind and as a minimum standard for data protection. In addition, we ensure that we comply with local data protection rules and regulations wherever we operate. 

In the following, we inform you about the processing of personal data by us as the responsible party when using the games published by us, the customer support offered by us in this context and the use of our website under the domain https://www.starberry.games/. The processing of personal data (e.g. name, address, e-mail address or telephone number of a data subject) is carried out in accordance with the statutory provisions, in particular in accordance with the requirements of the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

In the context of the further development of data protection law as well as technological or organisational changes, our data protection information is regularly reviewed for the need to adapt or supplement it. 

Version May 2024

I. Name and address of the responsible person 

The responsible party within the meaning of the General Data Protection Regulation (GDPR) of the European Union and other national data protection laws of the member states as well as other data protection regulations is:

Starberry Games GmbH

Managing Director: Antti Hattara

Boxhagener Str. 18

10245 Berlin

Germany

E-Mail: contact@starberry.games

II. Data Protection Officer

You can reach the data protection officer of the data controller as follows:

Starberry Games GmbH

-Data Protection Officer -

Boxhagener Str. 18

10245 Berlin

Germany

E-mail: privacy@starberry.games

III. What personal data is collected?

Personal data is any information relating to an identified or identifiable natural person, such as your name or e-mail address. Processing of data means in particular the collection, storage, use and transmission of your data. Within the scope of our various services, personal data is processed by us as follows:

1. Using our Website

Each time our website is accessed, our system automatically records the following data and information from the computer system of the calling end device:

  1. name and version of the browser

  2. name and version of the operating system 

  3. device type

  4. IP address

  5. date and time of access

  6. website from which our website was accessed

  7. geolocation of the visitor by IP address

  8. number of clicks on a page and views on pages

This data is stored in the log files of our system.

The legal basis for the processing of this data is Art. 6 para. 1 lit. f GDPR. If the processing of the data is based on your consent, the legal basis is Art. 6 para 1 lit. a GDPR.

2. Downloading and accessing our games

When downloading and accessing a game we publish, we process player data as part of the provision of the game. The processing in the game operation concerns the following data:

  1. IP address 

  2. date and time of access

  3. device type

  4. operating system and its version

  5. duration and frequency of use

  6. player ID (that is generated by us)

  7. in-game activity: interaction within the app and events such as game session timing and length, in-app purchases, progress in the game (e.g. game level and achievements in the game), avatar name, amount of club chat messages

  8. mobile device advertising identifier when available (e.g., Google Advertising ID or Apple ID for Advertising (IDFA)

The legal basis for the processing of this data is Art. 6 para. 1 lit. b and lit. f GDPR. If the processing of the data is based on your consent, the legal basis is Art. 6 para 1 lit. a GDPR.

3. Customer support

If you submit a customer support request (via e-mail or the game’s in-app support function) the data you provide (e.g. your name, your e-mail address, the content of your request) will be processed by us in order to process or answer your request. 

The legal basis for the processing of this data is Art. 6 para. 1 lit. b and lit. f GDPR.

4. Saving function

You have the option to save your game progress to the cloud using your Apple ID, Google Play ID or Facebook login. Within the scope of the provided saving function, the respective third party provider acts as the data controller. The processing of personal data is governed by their data protection regulations.

We will use a token associated with your Google Play ID or your Game Center ID as well as your e-mail address stored with the respective third-party provider if you use this option.

The legal basis for the processing of this data is Art. 6 para. 1 lit. b and lit. f GDPR.

5. Using the in-game club chat

If you write a message in the in-game club chat, this message is visible  to all other club members and our chat moderators. You can no longer change or delete the message after it has been sent. Messages in the club chat are automatically deleted after 90 days at the latest.

The legal basis for the processing of this data is Art. 6 para. 1 lit. b and lit. f GDPR.

IV. Cookies and third-party services

1. Cookies

Our website and games are using cookies or similar tracking technologies like software development kits (collectively, “Cookies”). Cookies do not cause any damage to your computer or devices and do not contain viruses. Cookies are used to make our offer more user-friendly, effective and secure and to enable the provision of certain functions. Cookies are small text files that are stored on your computer and saved by your browser. A cookie contains a characteristic string of characters that enables your browser to be uniquely identified when you return to the website.

Mandatory functions that are technically necessary for displaying the website: The technical structure of the website requires us to use technical necessary cookies. Without these cookies, our website cannot be displayed (completely correctly) or the support functions could not be enabled. These are basically transient cookies that are deleted after the end of your website visit, at the latest when you close your browser. You cannot deselect these cookies if you wish to use our website. The individual cookies can be seen in the Consent Manager.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. You can regularly obtain the procedure for deactivating cookies via the "Help" function of your Internet browser. If cookies are deactivated, the functionality and/or full availability of this website may be limited. 

Optional cookies when you give your consent: We set various cookies (optional cookies) only after your consent, which you can select on your first visit to our website by clicking on the corresponding button in the "cookie banner". The functions are only activated in the event of your consent and may serve in particular to enable us to analyse and improve visits to our website, to make it easier for you to use our website via different browsers or terminal devices, to recognise you when you visit us again or to serve advertising (possibly also to tailor advertising to interests, to measure the effectiveness of advertisements or to show interest-oriented advertising). The revocation of your consent is possible at any time without affecting the permissibility of the processing until the revocation. You can revoke the consent you have given us at any time by deactivating the cookie-based tools/plugins. 

2. Google Analytics

Our website may use the functions of Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, on the basis of the consent you have given us (Art. 6 (1) p. 1 lit. a GDPR). You can give us your consent voluntarily when you call up our website by clicking on the corresponding button in the "cookie banner". 

Data is also regularly transmitted to Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) as part of the processing described below. Google Ireland Limited and Google LLC are hereinafter jointly referred to as "Google". Google Analytics uses cookies (first-party cookies), which enable an analysis of your use of the website. However, this does not mean that we gain direct knowledge of your identity as a result. Your IP address is shortened before the usage statistics are analysed so that no conclusions can be drawn about your identity. Google uses the information generated by the cookies on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. 

You can revoke your consent at any time with effect for the future by calling up the cookie settings and changing your selection there. The lawfulness of the processing carried out on the basis of the consent until the revocation remains unaffected.

You can also prevent the storage of Google Analytics cookies from the outset by setting your browser software accordingly (see above). You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

As an alternative to the browser add-on or if you access our website from a mobile device, please use this opt-out link. This will prevent the collection by Google Analytics within this website in the future (the opt-out only works in this browser and only for this domain). If you delete your cookies in this browser, you must click this link again.

3. Youtube

Our website uses plugins from the YouTube video platform to embed videos and play them directly on our website. The operator of the video platform is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA ("YouTube"). YouTube is a company affiliated with Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google").

The YouTube videos are integrated in the so-called "extended data protection mode", which, according to the provider, only starts storing user information when the video(s) is/are played. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. Thus, YouTube establishes a connection to the Google DoubleClick network - regardless of whether you watch a video.

When you activate embedded videos on our website, a connection to the YouTube servers is established and a data transmission is started. We have no influence on the scope and content of the data that is transmitted to YouTube and possibly other YouTube partners by activating the plugin. Among other things, the YouTube server is informed which of our pages you have visited. According to YouTube, this information is used, among other things, to collect video statistics, to improve user-friendliness and to prevent abusive behaviour. YouTube uses cookies to collect information about user behaviour. The cookies remain on your terminal device until you delete them. You can prevent YouTube from storing cookies by making the appropriate settings in your browser software (see above).

If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account before activating the play button.

V. What do we use the personal data for?

1. Purposes of data processing

The processing of personal data is necessary for the provision of the website, the games we publish and the support function. In detail, we use the data for the following purposes:

  • Data that we process when you visit our website: The temporary storage of the IP address is necessary to be able to display the website to you. For this purpose, the IP address must remain stored for the duration of the session. The other data is collected for technical reasons to ensure stability and security. In the case you have given us your consent to use your personal data, the data will also be used to provide personalized advertisement and to analyse the performance of our advertising.

Data we process when downloading and accessing our games: The processing of this personal data is necessary for the technical implementation and provision as well as the operation of the game and the improvement of our offer of a customized gaming experience and to inform our players about the availability of game and in-game updates. In the case you have given us your consent to use your personal data, the data will also be used to provide personalized advertisement such as advertising new game content, new products, content or promotional offers and to analyse the performance of our advertising or manage our ad inventory and ad revenue and provide advertising through third parties. 

  • Data we process when you use the support function: The processing of the data is necessary for the provision of customer support and for helping the user with existing problems with the technical operation of the game or other questions about the game.

  • Data we process when using the save function: The processing of personal data is necessary to enable the offer of saving your game progress in the cloud. 

  • Use of technically necessary cookies: The technically necessary cookies are used for monitoring and ensuring the stability of our services, and to provide you with a technically optimized website that is user-friendly and tailored to your needs, as well as to ensure the security of our systems and protection against fraud.

  • Use of third-party software: Third-party software is used to make our website more appealing (e.g. by embedding YouTube videos).

2. Legitimate interest of the data processing

The purposes listed above are also our legitimate interest within the meaning of Art. 6 (1) sentence 1 lit. f GDPR.

3. Data processing with your consent

We process personal data through optional cookies only with your consent. Optional cookies are used to learn how our services are used based on statistical analysis (e.g. by Google Analytics). This allows us to constantly optimise and adapt our services, including our games and website, to user preferences, to develop new content tailored to user preferences and to. We also use the data to analyse and improve the performance and efficiency of our advertising and promotional offers. 

The revocation of your consent is possible at any time.  You can revoke your consent to the use of data that you have given us when using our website at any time by deactivating cookie-based tools / plugins in the cookie manager. If you have given your consent for using your data for serving personalized ads using our gaming app, you can revoke your consent to the use of data at any time by unchecking the "personalized ads" box in the app settings. If you are a user based in the EU or UK, you can withdraw your consent by managing your settings for ads consent in the app settings. In addition, you can prohibit tracking for personalized ads in the privacy settings of your device.

VI. Who do we share the personal data with?

In order to provide our services, we work together with other companies to whom we transfer personal data in order to provide these services. Without your consent, we limit the transfer of your personal data to what is necessary, taking into account the requirements of data protection law. In some cases, the recipients receive your personal data as order processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently under their own data protection responsibility and are also obliged to comply with the requirements of the GDPR and other data protection regulations.

Personal data is transferred to the following categories of recipients: 

  • Hosting-Provider, 

  • Providers of data analysis services,

  • Providers of customer service,

  • Providers of service optimization, 

  • Providers of IT solutions (e.g. embedding of Youtube videos, cookies).

  • Providers of advertising and advertising analysis services (only if we have your consent to use your personal data) 

VII. How long do we store the personal data?

The personal data shall be deleted or the processing restricted as soon as the purpose of the storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed expires, unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.

  • Data that we process when you visit our website: The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymized. If we process the data on the basis of your consent, we will delete or anonymise the data at the latest once you have withdrawn your consent.

  • Data we process when downloading and accessing our games: The personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case as soon as the data is no longer required for the use and provision of the game. For some of the data, this is the case when you have closed the game app, for others when you have deleted the game and any avatar you may have created. If data accumulates in the course of the game operation that we are obliged to retain or store due to tax, commercial or other regulations, it will only be deleted after the respective statutory retention or storage periods have expired. The legal basis for this storage is Art. 6 para. 1 lit. c GDPR. If we process the data on the basis of your consent, we will delete or anonymise the data at the latest once you have withdrawn your consent.

  • Data we process when you use the support function: Your data will be deleted when the support request has been conclusively resolved.

  • Data we process when using the save function: The personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case as soon as the data is no longer required for the use and provision of the game. This is the case when you have requested us to delete the storage of the game state in the cloud and we have performed the deletion or you have deleted your avatar, if created.

  • Use of cookies: If these are transient cookies: Such cookies, especially session cookies, are automatically deleted when the mobile app is closed or by logging out. If these are persistent cookies: Such cookies are automatically deleted after a predefined duration, which is set differently depending on the cookie. You can view the cookies set and the duration at any time in the settings of your browser and delete the cookies manually.

  • Personal data that we have collected based on your consent: We process data that we have collected based on your consent for as long as we need it to achieve our purposes or until you withdraw your consent to the processing of this data. 

VIII. On what legal basis do we process the personal data?

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 (1) sentence 1 lit. a of the EU General Data Protection Regulation (GDPR) shall apply as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) sentence 1 lit. b of the GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which we are subject, Art. 6 (1) sentence 1 lit. c of the GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of us or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6 (1) sentence 1 lit. f of the GDPR serves as the legal basis for the processing.

IX. Data transfer

Your information may be transferred to and processed in other countries than your country of residence. Our target is to mainly store and process the data within Europe, but we may also transfer data to outside of Europe due to the location and data storages of our third party service providers. The transfer of data to the U.S. is based on the adequacy decision of the European Commission of 10 July 2023 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the adequate level of protection under the EU-U.S. Data Privacy Framework. We also ensure that our contractual partners, if they are located in the USA, are registered under the EU-US Data Privacy Framework list.

X. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the data controller (if applicable, subject to further requirements set out in the relevant provisions). To assert the rights listed below, please contact the contact details listed under I. 

1. Right to information according to Art. 15 GDPR

You can request confirmation as to whether personal data relating to you is being processed by us. 

2. Right of rectification according to Art. 16 GDPR

You have the right to rectification or completion if the personal data processed concerning you are inaccurate or incomplete. The rectification shall be carried out without delay.

3. Right to erasure ("right to be forgotten") according to Art. 17 GDPR

You have the right to have your data stored by us deleted, unless the processing is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.

4. Right to restriction of processing according to Art. 18 GDPR

You have the right to restrict the processing of your data insofar as the accuracy of the data is disputed by you or the processing is unlawful.

5. Right to revoke the declaration of consent under data protection law in accordance with Art. 7 GDPR

You have the right to revoke a declaration of consent granted by you under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

6. Right to data portability according to Art. 20 GDPR

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. Or to request that it be transferred to another controller. 

7. Right of objection according to Art. 21 GDPR

Insofar as we process personal data as explained above in order to protect our legitimate interests which prevail in the context of a balance of interests, you can object to this processing with effect for the future, but only if there are reasons arising from your particular situation (Art. 21 GDPR). If the processing is carried out for direct marketing purposes, you may exercise this right at any time even without grounds. After you have legitimately exercised your right to object, we will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the assertion, exercise or defence of legal claims. This restriction does not apply if the processing is for direct marketing purposes.

8. Right to complain to a supervisory authority pursuant to Art. 77 GDPR

If you believe that we are not respecting your rights to the extent owed, you have the right to complain to a data protection supervisory authority about our processing of your personal data. Before you do so, however, we would appreciate it if you would inform us of your criticism beforehand so that we can remedy the cause of the complaint ourselves if necessary.

XI. Data security

Personal data is protected by us by means of suitable technical and organisational measures in order to ensure an appropriate level of protection and to safeguard the personal rights of the persons concerned. The measures taken serve, among other things, to prevent unauthorised access to the technical equipment used by us and to protect personal data from unauthorised disclosure by third parties. We use standard security practices, including strong passwords and physical security measures, to protect Starberry Games servers and system access from unauthorized access and disclosure. While we follow industry best-practices for system security, we cannot be held responsible for any security incidents beyond our control and we would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is therefore not possible.