Privacy Policy

We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations and this privacy policy. This privacy policy applies to the processing of personal data by us on our website and the use of our games (“Little Army Manager” and “Amnesia Island”). It explains the type, purpose, and scope of data processing within the context of the website.
We would like to point out that data transmission over the Internet can have security gaps. Complete protection of data against access by third parties is not possible. 

Controller

The “controller” refers to the natural or legal person, authority, institution, or other body that, alone or jointly with others, decides on the purposes and means of processing personal data.
The controller responsible for data processing for the provision of the Website and the Games is: 

Valerij Astafev
Lorenbeckstraße 18
48324 Sendenhorst
Mail: deload.business@gmail.com 

Ivan Kalthoff
Bremer Str. 10
48155 Münster
Mail: deload.business@gmail.com 

General Information on Data Processing 

Scope of Personal Data Processing 

We collect and use personal data of our users only to the extent necessary for the provision of our website, our content, and our services (especially games). The collection and use of our users’ personal data are generally based on the user’s consent. An exception applies in cases where obtaining consent in advance is not possible for factual reasons and the processing of the data is permitted by legal regulations. 

Legal Basis for the Processing of Personal Data 

If we obtain the consent of the data subject for processing personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for processing personal data.
When processing personal data necessary for the performance of a contract to which the data subject is party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations necessary for carrying out pre-contractual measures.
Insofar as processing of personal data is required to fulfill a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.
If processing is necessary to protect the vital interests of the data subject or another natural person, Article 6(1)(d) GDPR serves as the legal basis.
If processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, and if the interests, fundamental rights, and freedoms of the data subject do not override the first-mentioned interest, Article 6(1)(f) GDPR serves as the legal basis for processing. 

Data Deletion and Storage Duration 

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws, or other provisions to which the controller is subject. The data will also be blocked or deleted when a storage period prescribed by the mentioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract. 

Contact

You can contact us via our contact form on our website, by email, or by letter. In this process, your details from the inquiry, including the contact information you provided there, will be stored by us exclusively for the purpose of processing the inquiry and in case of follow-up questions. In this context, there is no transfer of data to third parties.
The legal basis for processing the data is Article 6(1)(f) GDPR. Our interest in responding to your inquiry outweighs your interest; since you are contacting us, a response is also in your interest, and you are aware that we need to process your data to respond to your inquiry.
If the email contact aims at concluding a contract, then the legal basis for processing is Article 6(1)(b) GDPR.
The data will be deleted as soon as they are no longer required for the purpose for which they were collected. This is the case when the respective conversation with the user has ended. The conversation is considered to have ended when it can be inferred from the circumstances that the relevant matter has been conclusively resolved. 

Use of Cookies

 We use so-called session or flash cookies on our website. Cookies are text files that are stored on the user’s computer system by or from an internet browser. When a user visits a website, a cookie may be saved on the user’s operating system. This cookie contains a distinctive string that allows the browser to be uniquely identified the next time the website is accessed. Some features of our website cannot be offered without the use of cookies. It is necessary for the browser to be recognized even after a page change. The user data collected with technically necessary cookies are not used to determine the user’s identity or to create user profiles. The legal basis for processing personal data using technically necessary cookies is Article 6(1)(f) GDPR. Due to the technical necessity, there is no possibility of revocation. 

Social Media Links

We maintain online presences in social networks and platforms to communicate with customers, prospects, and users active in these networks, and to inform them about our services.
Therefore, our website includes links to the Instagram website, operated by Meta Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Meta Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Meta”). Apart from this, no data is exchanged with Facebook via our website.
Our website also links to the website of X, operated by X Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, or, if you are based in the EU, X International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland.
When you access the aforementioned networks or platforms, the terms and conditions and data processing policies of the companies that operate these networks or platforms apply. Unless otherwise specified in our privacy policy, we process data of users who communicate with us via social networks or platforms, e.g., when they post on our Instagram pages or send us messages.

Games

When using our games, personal data is processed. Besides the processing operations already described above in the context of games, we further explain the functions and services used in this process and specify which games are concerned individually. 

Platform Services and Hosting
Our games are made available for download through the platforms of Google, the Google Play Store, and Apple, the Apple App Store. The data required for provision are processed by the respective platform operator acting as the data controller. Their terms of use and privacy notices apply.
You can find the privacy notice of the Google Play Store here: https://policies.google.com/privacy?hl=de
You can find the privacy notice of the Apple App Store here:
https://support.apple.com/de-de/HT211970

Payments
We offer the option to process payments for in-app purchases online via the payment service providers of the platforms. These service providers, acting as controllers, process billing data such as card details, payment information, billing addresses, and other legally required information. We will never be able to see sensitive information like your full credit card or bank account number from any of the service providers but will only receive confirmation of payment with association to the user (order ID), country, payment amount, product, and the execution date.
We have a legitimate interest in working with payment service providers and referring you to them as part of the payment process, as they facilitate payment processing and make our services accessible to a wider audience that uses such payment services, and because they also make the payment process easier for you as a user of such a payment provider. The legal basis for forwarding to such a payment provider is our legitimate interest according to Article 6(1)(f) GDPR.
The data processed by us for payment confirmation will be deleted as soon as they are no longer necessary for the purpose of their collection. This is the case once the check on the respective payment process is completed and it has been ensured that the payment was lawfully initiated. The legal basis for this processing is Article 6(1)(b) GDPR.
If data accrue in the context of a payment that we are obliged to store or retain due to tax, commercial, or other legal provisions, deletion will only take place after the expiry of the respective legal retention or storage periods (see III. No. 2). The legal basis for this storage is Article 6(1)(c) GDPR.
Processing via Google Play: When paying via Google Play, we forward your payment data to Google Ireland Ltd. (hereinafter “Google”) as part of the payment processing. All data required for payment processing are transmitted securely via the “SSL” procedure. If you use Google for payments, you agree to Google’s terms of use. Further privacy-related information can be obtained from Google’s privacy notice: https://policies.google.com/privacy.
Processing via AppStore: When paying via the Apple AppStore, we forward your payment data to Apple Distribution International Ltd (hereinafter “Apple”) as part of the payment processing. All data required for payment processing are transmitted securely via the “SSL” procedure. If you use Apple for payments, you agree to the terms of use of Instant Transfer. Further privacy-related information can be obtained from Apple’s privacy notice: www.apple.com/de/privacy.
As payment providers, as well as suppliers and providers of so-called gateways for payment processing, have their own privacy policies regarding the data and information to be provided by us for processing, we recommend reviewing the privacy notices of the respective service provider or provider. 

User Support Requests
You can send us a support request via deload.business@outlook.de. In this process, your details from the support request, including the contact information you provided there, will be stored by us exclusively for the purpose of processing the support request and in case of follow-up questions. In this context, there is no transfer of data to third parties.
The legal basis for processing the data is Article 6(1)(f) GDPR. Our interest in responding to your inquiry outweighs your interest; since you are contacting us, a response is also in your interest, and you are aware that we need to process your data to respond to your inquiry.
If the email contact aims at concluding a contract, then the legal basis for processing is Article 6(1)(b) GDPR.
The data will be deleted as soon as they are no longer required for the purpose for which they were collected. This is the case when the respective conversation with the user has ended. The conversation is considered to have ended when it can be inferred from the circumstances that the relevant matter has been conclusively resolved.

Game-Analytics

For our games, Little Army Manager and Amnesia Island, we utilize Unity Analytics provided by Unity Technologies ApS, Niels Hemmingsens Gade 24, 1st floor, DK-1153 Copenhagen, Denmark (“Unity”), for analyzing game performance and player behavior. This enables us to reproduce the player’s game state in each new session and to continuously develop our game both in content and technology. Unity processes various categories of personal data including unique device identifiers (such as IDFV for iOS devices and Android ID for Android devices), IP address, installation country (determined by the IP address), device manufacturer and model, platform type (iOS, Android, Mac, Windows, etc.) and the operating system and version running on your system or device, language, CPU information (model, number of CPUs present, frequency, and instruction set support flags), type of graphics card and manufacturer name, graphics card driver name and version (e.g., “nv4disp.dll 6.10.93.71”), used graphics API (e.g., “OpenGL 2.1” or “Direct3D 9.0c”), amount of available system and video RAM, current screen resolution, version of the Unity Editor used to create the game, sensor flags (e.g., device support for gyroscope, touch pressure, or accelerometer), application or bundle identification (“App ID”) of the installed game, unique advertising identifiers for iOS and Android devices (e.g., IDFA or Android Ad ID), respective checksum of all transmitted data to verify correct transmission, as well as completed events or actions in the game, including levels, number of credits, time taken to earn them, metadata about in-game communication, and the value and details of purchases.

The legal basis for processing is our predominant legitimate interest in the continuous content and technical development of our games (Article 6(1)(f) GDPR). It also serves the interest of each user in having a current game state at all times or restoring the same. Users can object to the processing of personal data at any time by making appropriate settings in the respective game (see settings/menu) or by making appropriate settings on their mobile device.

Unity uses servers located in the EU as well as in non-EU countries, especially in the USA. Unity processes these data in third countries based on appropriate guarantees within the meaning of Article 46 GDPR (so-called EU standard contractual clauses, a copy of which can be requested here: DPO@unity3d.com).

For more information on the processing of personal data by Unity, please see Unity’s privacy notice: https://unity3d.com/legal/privacy-policy. 

Advertising

Unity
For our games Little Army Manager and Amnesia Island, we use Unity Ads provided by Unity Technologies ApS, Niels Hemmingsens Gade 24, 1st floor, DK-1153 Copenhagen, Denmark (“Unity”), to deliver targeted advertising. Unity processes a range of personal data including unique device identifiers (such as IDFV for iOS devices and Android ID for Android devices), IP address, installation country (determined by the IP address), device manufacturer and model, platform type (iOS, Android, Mac, Windows, etc.) and operating system and version running on your system or device, language, CPU information (model, number of CPUs present, frequency, and instruction set support flags), type of graphics card and manufacturer name, graphics card driver name and version (e.g., “nv4disp.dll 6.10.93.71”), used graphics API (e.g., “OpenGL 2.1” or “Direct3D 9.0c”), amount of available system and video RAM, current screen resolution, version of the Unity Editor used to create the game, sensor flags (e.g., device support for gyroscope, touch pressure, or accelerometer), application or bundle identification (“App ID”) of the installed game, unique advertising identifiers for iOS and Android devices (e.g., IDFA or Android Ad ID), and respective checksum of all transmitted data to ensure correct transmission.

Furthermore, Unity processes information about the delivery of advertising and the user’s interaction with it, which can be shared with advertising publishers and suppliers. Specifically, Unity collects data such as whether you click or tap on an ad for a new game, whether you see the ad or frequently play a game, whether others playing a similar game as you have downloaded a specific new game, and whether you download and install the new game you saw advertised. Unity Ads may also collect your session information and monetization events. This data is used to predict the types of new games you might want to download.

The legal basis for processing is the user’s consent (Article 6(1)(a) GDPR). You can revoke your consent at any time through the appropriate settings in the advertisement display or on your mobile device. The legality of the data processing activities that have already taken place remains unaffected by the revocation.

Unity uses servers located in the EU as well as in non-EU countries, especially in the USA. Unity processes these data in third countries based on appropriate guarantees within the meaning of Article 46 GDPR (so-called EU standard contractual clauses, a copy of which can be requested here: DPO@unity3d.com).

For more information on the processing of personal data by Unity, please see Unity’s privacy notice: https://unity3d.com/legal/privacy-policy

External Links
Our games may contain links to external websites or third-party services over which we have no control regarding their content, privacy, and security standards. Therefore, please inform yourself about the privacy policies provided on the websites or services of the respective providers.

The linked sites were checked for possible legal violations at the time of linking. Illegal content was not recognizable at the time of linking. Should we become aware of any legal infringements, we will remove the corresponding link immediately.

These external links are solely for entertainment purposes, and visiting such websites or services is not strictly necessary to complete the game.

Rights

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

Right of Access
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing is taking place, you can request information from the controller about the following:

  1. the purposes for which the personal data are being processed;
  2. the categories of personal data that are being processed;
  3. the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  4. the planned duration of storage of the personal data concerning you or, if specific information on this is not available, criteria for determining the storage period;
  5. the existence of a right to rectification or deletion of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
  6. the existence of a right to lodge a complaint with a supervisory authority;
  7. all available information on the origin of the data if the personal data is not collected from the data subject;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
    You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate safeguards pursuant to Article 46 GDPR in relation to the transfer.

Right to Rectification
You have a right to rectification and/or completion against the controller if the processed personal data concerning you are inaccurate or incomplete. The controller must make the rectification without undue delay.

Right to Restriction of Processing
Under the following conditions, you may request the restriction of processing of personal data concerning you:

  1. if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful, and you oppose the deletion of the personal data and request the restriction of their use instead;
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims; or
  4. if you have objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your reasons.
    Where processing of personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
    If processing has been restricted under the above conditions, you will be informed by the controller before the restriction is lifted.

Right to Erasure
Obligation to Erase
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay if one of the following reasons applies:
(a) The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
(b) You withdraw your consent on which the processing was based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.
(c) You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.
(d) The personal data concerning you have been unlawfully processed.
(e) The deletion of personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(f) The personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
Information to Third Parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) GDPR, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you, as the data subject, have requested the deletion of any links to, or copy or replication of, those personal data.

Exceptions
The right to erasure does not apply to the extent that processing is necessary
(a) for exercising the right to freedom of expression and information;
(b) for compliance with a legal obligation which requires processing under the law of the Union or of Member States to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3) GDPR;
(d) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) GDPR, in so far as the right referred to in section (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise, or defense of legal claims. 

Right to Information
If you have exercised your right to have data corrected, deleted, or processing restricted against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves impossible or involves disproportionate effort.
You have the right to be informed about these recipients by the controller.

Right to Data Portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as

  1. the processing is based on consent according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract according to Art. 6(1)(b) GDPR, and
  2. the processing is carried out by automated means.
    In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.
    The right to data portability does not apply to processing personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions.
The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
You have the option, in the context of the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.

Right to Withdraw Consent
You have the right to withdraw your consent to data processing at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Automated Individual Decision-making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
This does not apply if the decision:

  1. is necessary for entering into, or the performance of, a contract between you and the data controller,
  2. is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
  3. is based on your explicit consent.
    However, these decisions must not be based on special categories of personal data referred to in Article 9(1) GDPR, unless Article 9(2)(a) or (g) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.
    In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view, and to contest the decision.

Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged will inform the complainant of the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.