Headup GmbH Privacy Policy

Headup GmbH, including its affiliates collects, stores, and uses your personal information as a data controller in connection with Headup GmbH’s products, services and websites (together “Services”) according to this privacy policy (“Privacy Policy”).
For questions and information about Privacy Policy, please contact us at info[a]headupgames.com or alternatively at Headup GmbH, Nordstr. 102, 52353 Dueren, Germany..
All Headup GmbH Services are governed by this Privacy Policy and by using or accessing a Service You give consent to the processing, use and disclosure of your data. Please do not install or use the Services if you do not agree to this Privacy Policy. 
Headup GmbH reserves the right to modify this Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

1.  Your data
Likely situations when you make personal data available to Headup GmbH include, but are not limited to: (i) registration for Services, contests and special events; (ii) accessing Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) purchasing a product or services through Headup GmbH’s online stores; (v) using “tell a friend,” "email this page," or other similar features; (vi) requesting technical support; and (vii) otherwise through use of Headup GmbH Services where personal data is required for use and/or participation.
Headup GmbH may use Flurry analytics tool in order to develop and analyze use of the Services. If you wish to opt-out from Flurry analytics, please follow this link: http://www.flurry.com/resources/privacy.html.
Headup GmbH may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services.

2. Ad Serving Technology
Headup GmbH reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Headup GmbH or Headup GmbH’s partners and contractors.
Headup GmbH may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.
Headup GmbH or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. Headup GmbH or third parties may collect and use data for this purpose including, but not limited to IP address (including but not limited to for purposes of determining your coarse location), Device ID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-game information.
The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.
Headup GmbH may display to you behaviorally targeted advertising. If you wish to "opt out" of certain targeted advertising, please visit http://www.youradchoices.com and/or www.networkadvertising.org. Please note that the links above may not reach all Headup GmbH’s advertising partners and certain behaviorally targeted advertising may still be displayed to you. If you want to be certain that no behaviorally targeted advertisements are not displayed to you, please do not use or access the Services.
Additionally please note that if you “opt out” it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you.
In particular we may use the following third-party software - see their privacy policies and a description how to opt-out here:
- OneAudience: http://www.oneaudience.com/privacy/   
- Ogury: http://www.ogury.co/privacy.html

3. Location Data 
To the extent Headup GmbH makes location enabled Services available and you use such Services, Headup GmbH may collect and process your location data to provide location related Services and advertisements. For example, some add-ons or offers may be available at dedicated locations.
Headup GmbH may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address.
Your GPS geo-location is not accessed without your consent. Notwithstanding Headup GmbH’s partners who are providing location related parts of the Service, Headup GmbH will not share your GPS geo-location with third parties without your consent. To the extent Headup GmbH makes available GPS geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously.

4. Disclosure and Transfer of Personal Data
Personal data may be disclosed to third parties in accordance with applicable legislation and this Privacy Policy.
Headup GmbH may use third parties to collect and process personal data on Headup GmbH’s behalf and in according to Headup GmbH’s instructions. Headup GmbH is not liable for the acts and omissions of these third parties, except as provided by mandatory law.
Headup GmbH may also disclose your personal data to third parties when Headup GmbH has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Headup GmbH’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Headup GmbH believes that such disclosure is necessary to protect Headup GmbH’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Headup GmbH. To the extent permitted by applicable law, Headup GmbH will make reasonable efforts to notify you of such disclosure through Headup GmbH’s website or in another reasonable manner.

5. Data Retention and Correctness
Headup GmbH retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter Headup GmbH deletes all aforementioned data in its possession within a reasonable timeframe. Headup GmbH does not verify the correctness of personal data.
Please note that some data may be further retained if necessary to resolve disputes, enforce Headup GmbH user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

6. Cookies, beacons and tracking
The Services may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Headup GmbH treats information collected by cookies and similar technologies as non-personal data.
Cookies: A “cookie” is a small bit of record-keeping information that websites often store on a user's computer. Headup GmbH’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” you. You can disable cookies or set your browser to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
Flash cookies & HTML5: Headup GmbH may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate. You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or visit www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.
Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image that allows Headup GmbH to count users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications Headup GmbH sends to you may contain pixel tags that enable Headup GmbH to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any.

7. Third Party Terms and Conditions  
Please note that your access to and use of the Services may be subject to certain third party and Headup GmbH is not liable for any such third party terms and conditions and their use of your personal data.
Certain Services that Headup GmbH may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID or gaming network account. In connection with such use, certain personally identifiable user and/or membership data may be transferred automatically to and from Headup GmbH. 
Headup GmbH may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Headup GmbH’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.

8. Safeguards
Headup GmbH follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Headup GmbH’s possession.

9. Other
You may choose to disclose data about yourself in the course of contributing user generated content to the Services.
Any data that you disclose in any of these forums, blogs, chats or the like will become public information, and there is no expectation of privacy or confidentiality.
Headup GmbH does not knowingly collect any personal information from children under 13 years of age and if Headup GmbH learns that Headup GmbH has inadvertently gathered personal data from children under 13 years of age, Headup GmbH will take reasonable measures to promptly erase such personal data from Headup GmbH’s records.
Headup GmbH may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.

10. Further information
This Privacy Policy is governed by German law excluding its choice of law provisions.
Headup GmbH makes good faith efforts to enable you to review, update or correct your personal data in Headup GmbH’s possession.
Headup GmbH will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request.

This Privacy Policy may be updated from time to time. You are advised to consult this policy regularly for any changes.

Date of last changes: September 18th, 2018