Privacy policy

The use of this website may involve the processing of personal information. Our intention is for the following information to provide you with an overview of these processes so that you can understand them. In order to ensure fair processing, we would also like to inform you about your rights under the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG).

PHANTOMEDIA, Owner Tim Hertel, Talstrasse 5b, 21680 Stade (hereinafter referred to as “we” or “us”) is responsible for the data processing.

1. Contact Us
If you have any questions or suggestions about this information or would like to contact us to exercise your rights, please contact us via: https://phanto.media/

2. General Information on the Processing of Personal Data
The use of the products and services we offer may result in the processing of personal data. The term “personal data” under data protection law refers to all information relating to a specific or identifiable person. An IP address can also be considered personal data. An IP address is assigned to each device connected to the internet by the internet service provider, so that it can send and receive data. When you use the website, we collect data that you provide yourself. In addition, when you use the website, we automatically collect certain information about your use of it. We process personal data in compliance with the relevant data protection regulations of the GDPR and the German BDSG. We will only process data where we are legally permitted to do so. When you use this website, we will process personal data only with your consent (Art. 6 paragraph 1 sentence 1 letter a GDPR), for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract (Art. 6 paragraph 1 sentence 1 letter b GDPR), for compliance with a legal obligation (Art. 6 paragraph 1 sentence 1 letter c GDPR) or if the processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data (Art. 6 paragraph 1 sentence 1 letter f GDPR).

3. Duration of Storage
Unless otherwise stated in the following sections, we will store the data only as long as necessary to achieve the purpose of processing or to fulfill our contractual or statutory obligations.

4. Transmission of data
Unless otherwise stated in the following sections, data will be processed on the servers of technical service providers commissioned by us for this purpose. These service providers will only process the data after having received express instructions and they are contractually obliged to guarantee adequate technical and organizational measures for data protection. Insofar as we refer to integrated services of other providers in this Data Protection Declaration, it can be assumed that personal data will be transmitted to the specified headquarters of these providers. These providers may be based in a so-called third country outside the European Union or the European Economic Area. Further information can be found in the sections describing each service.

5. Contact Form
Our website contains a contact form with which you can send us messages. The transfer of your data is encrypted. The legal basis for processing this data is Art. 6 paragraph 1 sentence 1 letter b GDPR. All data fields marked as mandatory are required for processing your request. If they are not provided, your request cannot be carried out. The provision of any additional data is voluntary. Alternatively, you can also send us a message to the contact e-mail address.

6. Registration and Login
In order to use certain functions within the app, registration via the website is required. The information required can be seen on the registration screen. It is absolutely essential to provide the information marked as mandatory in order for you to complete the registration process. The data provided will be processed for the purpose of providing the service. The legal basis of this processing is Art. 6 paragraph 1 sentence 1 letter b GDPR. We store your data for as long as you are registered with us, unless you delete it beforehand.

8. Data Processing in our Games
In our games we are able to track and evaluate various actions at the player level. This especially includes contact data provided during registration and your actions during the games. For this purpose, we collect your connection data, such as your IP address. We need to be able to process this information to execute gaming operations. It is, therefore, processed on the basis of Art. 6 paragraph 1 sentence 1 letter b GDPR

9. Newsletter
In the following section, we will inform you about our newsletter as well as other types of business emails and electronic communications and your right to object. By subscribing to our newsletter, you agree to receive it and you agree to the processes described below. The legal basis is your consent pursuant to Art. 6 paragraph 1 sentence 1 letter a GDPR and Section 7 paragraph 2 no. 3 of the German Act against Unfair Competition (UWG). We do not include the following information under the term “advertising communication”: Information about technical and organizational processes and information relating to the provision of services to our users.

To subscribe to our newsletter, we use the double opt-in procedure, which serves to confirm your e-mail address. This confirmation is required so that no one can register with an e-mail address that does not belong to them. Subscriptions to the newsletter are logged in order to be able to provide evidence of the registration process in accordance with statutory requirements. This includes the storage of the login itself, the time of confirmation, as well as the IP address. Any changes to your data stored with the service provider that sends the newsletters are also logged. The processing of this data is necessary in order to be able to prove that consent has been granted. The legal basis results from our legal obligation to document your consent (Art. 6 paragraph 1 letter c in conjunction with Art. 7 paragraph 1 GDPR).

Newsletters are sent with the help of an EU-based external service provider, whom we have engaged for this processing activity in accordance with statutory requirements. The newsletters contain pixels that are retrieved by the server of the service provider that sends the newsletter as soon as the newsletter is opened. Within the scope of this retrieval, some information such us your IP address and time of retrieval are collected. This information is used for technical improvement or to analyze the target groups and their reading behavior on the basis of their retrieval locations (which can be determined using the IP address) or access times. The statistical data collection also includes determining if and when the newsletters are opened and which links are clicked and when they are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. These analyses are primarily intended to help us to identify the reading habits of our users and to adapt our content to them or to send different content based on user interests. The personalized analysis is performed with your consent, which we obtain when collecting your email address. The legal basis is Art. 6 paragraph 1 sentence 1 letter a GDPR. You can revoke your consent at any time with effect for the future. You can do so easily by using the link at the bottom of each of our communications or by using our support form. Unfortunately, you cannot request separate cancellations for the service provider that sends the newsletter or for the statistical analysis. If you wish to cancel, you must cancel the entire subscription.

10. Use of email address
We can use the email address you provide during registration or payment to keep you informed about similar products and services that we offer. This serves our legitimate interest in contacting existing customers for the purpose of direct marketing. The legal basis is Art. 6 para. 1 lit. f GDPR in conjunction with. § Section 7 (3) Act Against Unfair Competition. You can revoke your permission at any time without incurring any costs other than transaction costs according to the basic rates. To do this, you can unsubscribe by clicking the link contained in every email.

11. Processing Server Log Files
When using our website for informational purposes only, general data is initially stored automatically (i.e. not via registration) and transmitted to our server by your browser. By default, these include: The browser type/version, the operating system used, the page accessed, the page previously visited (referrer URL), the IP address, the date and time of the server request and the HTTP status code. The processing is carried out for the purposes of our legitimate interests, the legal basis of which is Art. 6 paragraph 1 sentence 1 letter f GDPR. This processing is used for technical administration and website security.

12. Combating Fraud
We process pseudonymous information, such as the IP address or device ID, for the analysis of signals in order to identify fraud by third parties in the context of customer acquisition. To accomplish this, we are supported by external service providers whom we have ensured are committed to the same statutory requirements. The legal basis is Art. 6 paragraph 1 sentence 1 letter f GDPR. This processing contributes to the organizational security of the website.

13. Cookies
We use cookies on our website. Cookies are small text files that are stored by your browser when you visit a website. This identifies the browser used and can be recognized by our web server. Insofar as this use of cookies results in the processing of personal data, the legal basis for this is Art. 6 paragraph 1 sentence 1 letter f GDPR. This manner of processing serves our legitimate interest in making our website more user-friendly, effective and secure.

Most of the cookies we use are known as “session cookies”. They are deleted after the end of you visit. Other cookies (“persistent cookies”) are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser. You can object in principle to the use of cookies through your browser settings.

Please note that by deleting our cookies or disabling future cookies, you may not be able to use certain areas or features.
If you only wish to restrict third-party advertising cookies, you can disable such cookies by visiting Your Online Choices (http://www.youronlinechoices.com/).

14. Google Analytics
We use the Google Analytics service from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”) to analyze our website visitors. Google uses cookies. The information generated by the cookie about the use of the online product or service by users is generally transferred to a Google server in the USA and stored there. Google will use this information on our behalf to evaluate the use of our online products and services by users, to compile reports on the activities within these online products and services and to provide us with further services associated with the use of these online products and services and the use of the internet. Pseudonymous user profiles can be created from the processed data. We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent cookies from being stored by adjusting the settings to their browser software accordingly. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. Users can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

A transmission of your data to the USA cannot be excluded. We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.

15. Google Marketing Services
On our website we use the marketing and remarketing services of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”). These services allow us to display advertisements in a more targeted manner in order to present advertisements of interest to users. Through remarketing ads and products are displayed to users relating to an interest established by activity on other websites within the Google Network. For these purposes, a code is used by Google when our website is accessed and what are referred to as (re)marketing tags are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which apps users have visited, which content they are interested in and which offers have been used. In addition, technical information about the browser and operating system, referring websites, the length of the visit as well as any additional data about the use of the online products and services are stored. The IP address of users is also recorded, although we would like inform you that within the framework of Google Analytics, IP addresses within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area are truncated. All user data will only be processed as pseudonymous data. Google does not store any names or e-mail addresses. All displayed ads are therefore not displayed specifically for a person, but for the owner of the cookie. This information is collected by Google and transmitted to and stored by servers in the USA. One of the Google marketing services we use is the online advertising program Google AdWords. In the case of Google AdWords, each AdWords customer receives a different conversion cookie. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users. We may include third-party advertisements based on the Google Marketing Service called DoubleClick. DoubleClick uses cookies to enable Google and its partner websites to place ads based on users’ visits to this website or other websites on the Internet. Google services make use of Google’s Tag Manager. For more information about Google’s use of data for marketing purposes, please see the summary page: https://www.google.com/policies/technologies/ads, Google’s privacy policy is available at https://www.google.com/policies/privacy. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.

A transmission of your data to the USA cannot be excluded. We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.

16. Twitter Conversion Tracking
On our website, we use the Conversion Tracking Service of Twitter Inc. (1355 Market Street #900, San Francisco, California 94103, “Twitter”). Twitter stores a cookie on the user’s computer to enable an analysis of the use of our online products and services. Twitter Conversion Tracking tracks the actions of users after they have viewed ads or interacted with ads on Twitter. Twitter’s Conversion Tracking allows you to assign conversions such as link clicks, retweets or “like” data. The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to tracking, you can do so using the Digital Advertising Alliance tool at optout.aboutads.info.

We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.

17. Analysis of advertising on third-party websites
We use advertising spaces on third-party websites as a means of advertising. As an advertiser, we can use these to target certain interest and user groups when displaying our adverts. We cooperate with various third-party providers to display our advertisements.

We use services and systems provided by third parties to allocate the advertising space and select the interest groups. In order to measure and optimize the success of the interest-based advertising, some of the third parties use cookies and other technical means on our site to obtain information about the use of our website.

If personal data is collected while using our website and transferred to a third-party provider, this data processing is based on the legal basis of art. 6 para. 1 letter. f) DSGVO. Processing is carried out to protect our legitimate economic interests in the marketing of our website.

We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.

18. Integrated Services and Third Party Content
We use services and content provided by third parties on our website (hereinafter collectively referred to as “content”). For this kind of integration, it is technically necessary to process your IP address so that the content can be sent to your browser. Your IP address will therefore be transmitted to the respective third party provider. In each case, this data processing is carried out to safeguard our legitimate interests in the optimization and the commercial operations of our website, the legal basis of which is Art. 6 paragraph 1 sentence 1 letter f GDPR. The Java programming language is regularly used to integrate content. Therefore, you can object to data processing by deactivating Java operations in your browser. We have integrated contents from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”) into our website:

“Google Maps” for displaying maps;
“Google Web Fonts” for using Google’s fonts;
“YouTube” for displaying videos.
A transmission of your data to the USA cannot be excluded. We guarantee the adequacy of data transfer to the third country USA through the agreement of EU standard contractual clauses.

19. Advertising in Games
We offer in-game advertising on our web games allowing you to view video sequences from third-party providers funded through advertising. This allows paid content, for example, to be used free of charge.

The data you provide when using advertising media is collected and analyzed, which will be explained in more detail below. Our service provider Google Ad Manager by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) allows us to put this type of ad monetization into practice. The service provider assumes control of the in-game advertising networks. This involves some parameters being shared via an interface with the advertising networks: IP address, browser, operating system, region (more info). The aim of this transmission of information is to display the most relevant advertising material for the user. The advertising networks mentioned may possibly also process personal data, such as the IP address, in order to be able to provide that advertising material.

Opting out from personalized or contextual ads does not remove ads in our games. Limited ads, which do not process any personal data and are less relevant to the users, will still be shown.

The legal basis for the processing of information in connection to the in-game advertisement is your consent (Art. 6 paragraph 1 letter a GDPR). As a user, you can opt out the use of personal data in advertising at any time in our Preference Center (link below). In such a case, all pseudonymous information is anonymized, meaning that only limited ads will be shown.

20. Your Rights
As the person concerned, you are entitled to exercise your rights against us. In particular, you have the following rights:

In accordance with Article 15 GDPR and Section 34 BDSG, you have the right to request information as to whether or not, and to what extent, we process personal data about you.
You have the right to have us correct your data in accordance with Article 16 GDPR.
You have the right to have us delete your personal data in accordance with Article 17 GDPR and Section 35 BDSG.
You have the right to have the processing of your personal data restricted in accordance with Article 18 GDPR.
You have the right, in accordance with Article 20 GDPR, to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format and to transmit this data to another controller.
You can exercise your rights by contacting us via our contact form.

21. The Right to Object
In accordance with Article 21 GDPR, you have the right to object to any processing operations executed that use Art. 6 paragraph 1 sentence 1 letter e and letter f GDPR as their legal basis.

22. Minor’s privacy
The Service is not targeted towards, nor intended for use by anyone under the age of 16. We do not collect personal data from any person we actually know is under the age of 16.

23. Data Protection Officer:
Tim Hertel
Talstrasse 5b
21680 Stade
support@phanto.media

24. Complaints to Government Authorities
If you believe that the processing of your personal data constitutes an infringement of the provisions of the GDPR, you have the right to lodge a complaint with a supervisory authority in accordance with Article 77 GDPR.