Privacy Policy Chips & Crowns

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) for the processing of data in connection with the app Chips & Crowns is:

Ozan Caglayan – CGN-Games
Elisenstr. 24
46147 Oberhausen
Germany
Email: info@cgn-games.de

No data protection officer has been appointed, because the legal requirements for a mandatory appointment (Section 38 BDSG, Art. 37 GDPR) are not met. The contact for all data protection matters is the controller named above.

2. Overview

Chips & Crowns is a casino game with play money only. We (CGN-Games) do not collect, store or transmit any personal data on servers of our own – we do not run any servers for the game. The game contains no ads, no tracking, no analytics and requires no user account.

This policy applies to the app on Android (Google Play). Our website www.cgn-games.de has a separate privacy policy.

3. Data stored on your device only

To work, the game stores the following data only locally on your device (in the app storage):

• the current run, your permanent progress (reputation, upgrades, album), achievements and high scores,
• the player name you may enter (for high scores and the share card),
• settings (volume, language, game aids, chosen character),
• which cosmetic items you own and have equipped; with the Supporter Pack, the name you may enter for the credits.

This data never leaves your device and we have no access to it. It is deleted when you uninstall the app or clear the app data in the Android settings. No legal basis under the GDPR is required, because we do not process this data.

4. In-app purchases through Google Play

You can buy cosmetic items through Google Play Billing. Google handles the purchase completely. For users in the European Economic Area, Switzerland and the United Kingdom, the contracting party for Google Play and the controller for the data processed in the purchase is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (a subsidiary of Google LLC, USA). Google processes the data needed for payment (e.g. your Google account and payment details) under the Google Privacy Policy and the Google Play Terms of Service.

We do not receive any payment data or any information about you. The game only asks Google which items are offered at which price and which ones you have already bought, in order to unlock them (also for “Restore purchases”). No data is transmitted to us. For this the app needs the permissions “Internet”, “network state” and “Google Play Billing”. Where data flows between your device and Google for technical reasons, Google is responsible for it; on Google’s side the legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

5. Feedback by email

“Options → Send feedback” opens the email app of your device with a pre-filled subject (game version, device model, Android version). The app itself sends nothing; only when you send the email do we receive your email address, the technical details from the subject and whatever you write.

We use this data solely to answer your message and to look into the reported issue. The legal basis is our legitimate interest in answering enquiries and fixing bugs (Art. 6(1)(f) GDPR) or, if your enquiry concerns a purchase, the performance of the contract (Art. 6(1)(b) GDPR). We delete the email as soon as your request has been dealt with, unless statutory retention obligations require otherwise. Our mailbox is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; a data processing agreement under Art. 28 GDPR is in place with IONOS.

6. Sharing your run statistics

When you tap “Share”, the game creates an image of your run statistics (including your player name) and opens the Android share dialog. You decide what happens to the image by choosing an app; from then on that app’s privacy policy applies. Nothing is shared or sent without your action.

7. No sharing with third parties, no profiling

We do not pass any data to third parties, build no user profiles and make no automated decisions within the meaning of Art. 22 GDPR. We do not transfer data to third countries.

8. Children and young people

The game is not directed at persons under 18. It contains simulated gambling with play money. There is no way to win real money or prizes.

9. Your rights

Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and the right to object to processing based on Art. 6(1)(f) GDPR (Art. 21). As we do not store any data about you other than an email you send us, we are generally unable to link any data to you; you can delete your game data yourself at any time (see section 3). For questions about purchases, please contact Google.

You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany, www.ldi.nrw.de.

For questions, reach us at info@cgn-games.de.

10. Changes

If the game changes (for example through new online features), we will update this policy. The version published here applies.