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PRIVACY NOTICE
(Last updated 27 September 2023)
1. INTRODUCTION
Who are we?
We are Prismatika GmbH, a company incorporated and registered in Germany with registered
address at Neue Schönhauser Str. 3-5 Berlin, 10178, Germany (“Prismatika”, “we” or “us”), and we
are a videogame publisher.
Where we decide the means or purpose of processing your personal data, we are the “data
controller.”
What’s this notice
about?
This notice explains how we process personal data, as a data controller, relating to:
• visitors to our website (“Website Users”): https://prismatika.games (“Website”);
• users of our games (“Game Users”) when they access any of Prismatika’s games (“Games”),
including, but not limited to, any game alongside which we make this Privacy Notice
available;
• people who volunteer to play, evaluate and provide feedback on our Games (“Playtesters”);
and
• people who sign up for one or more of our email mailing lists to receive news and other
information from us (“Mailing List Subscribers”).
and together the Website Users, Game Users, Playtesters and Mailing List Subscribers shall be the
“Users” (and “you” and “your” shall refer to any User).
Note that we may offer each Game through third party application and/or games stores including,
without limitation, Steam, Epic Game Store, GOG, Humble Bundle, Apple App Store, Google Play,
Xbox, PlayStation, Nintendo Switch (each a “Store”). That may mean that you need a Store account to
play the Games, and your use of each Store is subject to the terms of use and privacy policy
applicable to that Store.
We update this notice from time to time, so Users should check back in on a regular basis. Where
appropriate, we will actively notify you.
Please note that other websites or services mentioned or linked to on the Website or in-Game are not
operated by us, and you should refer to the privacy policies on those websites to understand how
their personal data is being used.
What are your rights?
Users have the following rights, although these rights may be limited in some circumstances:
● Ask us to send a copy of your personal data to you or someone else
● Ask us to restrict, stop processing, or delete your personal data
● Object to our processing of your personal data
● Object to use of your personal data for direct marketing purposes
● Ask us to correct inaccuracies in your personal data
If we rely on consent to process personal data you can withdraw consent at any time.
To make a request for your rights, please let us know by sending an email to the email address set out
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in the next section below.
You also have the right to submit a complaint to a supervisory authority. For example, in Berlin, you
can get in contact with the Berliner Beauftragte für Datenschutz und Informationsfreiheit:
https://www.datenschutz-berlin.de/buergerinnen-und-buerger/beschwerde. If you live in the UK or a
European country , you can alternatively submit a complaint to the supervisory authority in your
country/state. If you live outside of those territories, you may have a supervisory authority in your
country whom you can also turn to.
How do you contact
us?
If you have any questions concerning this notice, including how you can exercise your rights, please
contact us at: [email protected]
2. YOUR PERSONAL DATA AND HOW WE USE IT
Your personal data
Our legal justification for using your
personal data
Sources
Gameplay Data
We process the following personal data about our
Games:
● Your Store username and other profile details
● Your Device ID
● Your device operating system & version
● Your device make and model
● Game play attempts, progression and results
● Session game time start, end and duration
● The country of your Device
● The time, date and install source of your first
download
● Identification of crashes and defects
We use this personal data to allow Game Users to
use our Games (including certain functionalities on
our Games), identify and correct any problems in
our Games (such as bugs or problems preventing
in-Game progression); understand how Game Users
use our Games; and perform essential business
operations.
We process this personal data where it is
necessary for the performance of a contract
which Game Users are a party to.
We also process this personal data to
pursue our legitimate interests, including
to:
● Improve the delivery of our Games
● Operate our business and promote its
success
Sources
We collect this data
directly from Game
Users.
Enquiry Data
We process the following personal data in relation
to Website Users when they get in touch with us.
For example, when they submit any enquiries,
complaints or questions about our Games,
Website, events, products or services:
● Name;
● Contact information (such as email address);
● Any other information that Game Users submit
as part of their enquiries, complaints or
questions.
We use this personal data to communicate with
you and provide our support services.
We may process this data in accordance
with the terms of our contract with you
(where we need this information to provide
the Games to you) or to take steps at your
request prior to entering into a contract.
We also use this to pursue our legitimate
interests, including:
● Our interest in responding to enquiries
to ensure smooth operation of our
business and services
● To understand our customers and
improve our Services, by taking on-
board your feedback
Sources
We collect this data
directly from Website
Users.
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Playtester Data
We process the following personal data in relation
to Playtesters when you sign up to become a
Playtester. For example, when you complete forms
that we provide for you to do so.
● Name;
● Contact information (such as email address);
● Any other information that you submit as part
of your playtesting, questions or feedback on
our Games.
We use this personal data to allow Playtesters to
use our Games (including certain functionalities on
our Games), identify and correct any problems in
our Games (such as bugs or problems preventing
in-Game progression); understand how Playtesters
use our Games; and perform essential business
operations.
We process this data based on your
consent, and in accordance with the terms
of our contract with you (where we need
this information to provide the Games to
you) or to take steps at your request prior
to entering into a contract.
We also use this to pursue our legitimate
interests, including:
● Our interest in responding to enquiries
to ensure smooth operation of our
business and services
● To understand our customers and
improve our Services, by taking on-
board your feedback
● To make improvements, upgrades and
error correction to our Games
Sources
We collect this data
directly from Playtesters.
Website Analytics
We process the following personal data in relation
to Website Users (collected from your device and
interaction with our Website):
● How often you use our website
● Which webpages/application screens you go
to, how long you spend on certain
webpages/application screens and which
features you use
● Which webpages, emails, search engines or
marketing campaigns referred you to our
website
● Your IP address, and device identifiers
communicated by your device or browser
● Device and browser operating system, version,
make and model
Please see section 3 below for more information
about our use of cookies and similar technologies.
We process this information so that we can
understand usage of our Website and improve it.
We may further process this information for online
marketing and advertising, including:
● Remarketing, which allows us to show ads to
people on third party services (for example,
Facebook), who have previously visited our
website; and
● Ad performance monitoring, meaning that
your information may be used to understand
how ads have performed or how many people
have viewed certain ads.
We process this personal data based on
your consent, which is collected via the
cookie banner on our Website.
Sources
We collect this data from
Website Users via
cookies, please see more
detail on this and the
third parties who may
have access to this data
in Section 3 below.
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Ad Analytics
Where you interact with one of our ads online, the
following personal data may be collected by a third
party:
● Your IP address, and unique device identifiers
communicated by your device or browser
● Device and browser operating system, version,
make and model
This personal data is used by a third party who can
then tell us if someone who clicks on an ad for one
of our Games (for example, on Facebook or
YouTube) then goes on to buy the Game in a Store.
It helps us understand how effective our Ads are
and where our Game Users hear about us. We only
receive aggregated statistics on whether ads have
led to Game sales. We have no way of identifying a
specific Game User from this information. We do
not have access to or control the underlying
personal data (as listed above).
This personal data will be processed based
on your consent, which is collected via the
cookie banners on the websites on which
you see the ads.
Sources
This data is collected via
third party tracking
technologies in the ads.
We only receive
aggregated statistics on
whether ads have led to
Game sales, we do not
have access to or control
the underlying personal
data.
GameAnalytics
Where you give your consent, when you play our
Games on PC, the following personal data may be
collected by our analytics providers:
● Your country based on your IP address
● Device and browser operating system, version,
make and model
● A unique device identifier
● Information about how you play our Games,
including gaming session frequency and length,
and gaming platform
● Game errors
This personal data is used by analytics providers to
provide us with reports and information about how
our Games are played. It helps us understand how
our Games are played, to make improvements to
our Games and to fix errors in our Games. We use a
third-party provider, GameAnalytics, for this
purpose. Read the GameAnalytics Privacy Policy
here and more information about GameAnalytics
services here.
This personal data will be processed based
on your consent, which is collected via a
pop-up on Steam before you download our
Games. You may withdraw your consent by
contacting us or through the settings menu
in relevant Games.
Sources
This data is collected via
third party tracking
technologies in our
Games.
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Game pitch processing activities
Our website has a feature where you can submit a
pitch for a future game. We process the following
personal data in relation to Website Users when
they submit a pitch for a game via our Website:
● Game information
● Submitter contact details (name, email address
and telephone number)
● Website or portfolio link
● Any other information that Website Users
submit as part of their game pitch
We use this personal data to evaluate the pitch
and, where applicable, communicate with you
about the Pitch. We may also share the pitch with
investors and other financial partners.
We process this personal data to pursue our
legitimate interests, being to:
● Operate our business and promote its
success
● Find, promote and launch new Games
● Further our, and the Website User’s,
commercial interests
Sources
We collect this data
directly from Website
Users
Job application processing activities
We process the following personal data in relation
to Website Users when they submit a job
application on our Website:
● Your name
● Your email address
● Your education and qualifications
● Details of your previous work and/or
employment; and
● Any other information you include in your CV
● Any other information that Website Users
submit as part of their job application
We use this personal data to assess whether you
are suitable for a role at Prismatika, including to
consider your skills and qualifications. We’ll also
communicate with you about the role and the
recruitment process and keep appropriate records
of the process.
We process this personal data to pursue our
legitimate interests, being to:
● Hire suitably qualified individuals
● Operate our business and promote its
success
Sources
We collect this data
directly from Website
Users
Email list processing activities
We may process the following personal data in
relation to Mailing List Subscribers when they sign
up for one or more of our email mailing lists (for
example, on our Website, or within a Game):
● Your email address
● Your name
● Any other information that Mailing List
Subscribers provide when signing-up for one of
our email mailing lists
We use this personal data to contact you with news
about Prismatika and our Games, and to market
our Games and related content to you. You can
unsubscribe at any time by clicking the
“unsubscribe” link found at the bottom of all emails
that we send to you.
We process this personal data to pursue our
legitimate interests, being to:
● Share news and other important
information, for example, about
updates to our Games or bugs within
our Games
● Market Prismatika and our Games and
related content to you
Sources
We collect this data
directly from Mailing List
Subscribers
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3. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table
explains their purpose, how long they last, and who else can access their data. We get your consent to use them on our
Website unless they’re essential for our sites to function.
Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox |
Microsoft Internet Explorer | Opera | Apple Safari.
Other settings to disable certain similar technologies: Windows Advertising ID | iOS and Mac OS Ad Tracking | Google Analytics
| Your Ad Choices.
Cookie/data
Duration
Purpose/ Access
SiteCookies
Does not expire
This cookie is used to remember a user’s choice
about cookies on our Website. Where Users have
previously indicated a preference, that User’s
preference will be stored in this cookie. This is an
essential cookie to enable a core functionality of
our site (i.e. managing cookie consents).
Google Analytics
gat_UA-XXXXXXXX-X,_ga
2 years
This cookie is used to collect information about
how Users use our Website. We use the
information to compile reports and to help us
improve the website. The cookies collect
information in an aggregated form, including the
number of visitors to the website, where visitors
have come to the website from and the pages they
visited. Google may receive information about
your activity.
Read more information provided by Google here
Facebook Pixel
_fbp
2 years
This cookie is used to collect information about
how Users use our Website. This cookie is used for
remarketing. Facebook remarketing allows us to
show Facebook ads to users who have previously
visited our Website. This cookie is also used to
understand how our Facebook ads are performing.
Facebook may receive information about your
activity.
Read Facebook Privacy Policy and Cookie Policy
here and here
GameAnalytics SDK
Does not expire
This SDK is used to collect information about how
Game Users use our Games. We use the
information to compile reports, and to help us
improve our Games. The SDK collects information
such as identifying unique users, gaming session
frequency and length, errors, User device make
and models, operating system versions, gaming
platform and country based on your IP address.
Read the GameAnalytics Privacy Policy here and
more information about GameAnalytics services
here.
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4. STORAGE, TRANSFERS AND DISCLOSURE
We hold personal data for as long as necessary bearing in mind the purpose for which it was
collected. At the end of the retention period, we assess whether it is necessary to continue to
retain personal data to achieve the purposes for which it was collected. To determine appropriate
retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk
of unauthorised access, and legal requirements.
We are based in Germany, regularly collaborate with an international network of partners and
may from time to time use subcontractors and service providers based in other countries. Where
we transfer your information outside of the UK and/or EEA, we will have agreements in place with
the recipient which include standard data protection clauses adopted by a data protection
regulator and/or approved by the European Commission to ensure that appropriate safeguards
are in place to protect your personal data. For more information, drop us a line using the contact
details at the start of this notice.
We may disclose your personal data:
● Where required by law, government, competent authorities or the courts or to establish,
exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for
example, we may share personal data with our professional advisors, investigators, or credit
reference agencies).
● With suppliers, business partners and subcontractors, as necessary for the purposes set out in
this notice, including analytics services providers.
● With other members of our corporate group and our international network of partners.
● If involved in an investment, merger, acquisition, or sale of our organisation or assets,
personal data we hold may be shared on the basis of the legitimate interests of us, our
investors, our shareholders, customers and other parties to a transaction, unless those
interests are outweighed by prejudicial impacts upon you.